If you sell packaged goods directly to end customers in another EU country, you will need an authorised representative on the ground in many countries. This overview shows you, for 27 countries, what you have to register, what it costs and where to act first.
The Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) generally applies from 12 August 2026. It harmonises many packaging requirements. In practice, registration, the national registers, the PRO systems, volume reporting and fees remain strongly country-specific and are still being adapted in places.
An existing obligation is not one to postpone. Checking and registering comes first here.
8 countriesClarify status, thresholds and the representative requirement case by case before you ship.
16 countriesA small-quantity rule or exemption may apply. Check your annual volume first.
3 countriesAll figures are guide values based on the national registers and tariff structures available in August 2026. They are no substitute for legal or tax advice.
Baseline for this overview: a retailer that is a producer under the PPWR sells packaged products by distance selling directly to end users in an EU Member State. From 12 August 2026 it must appoint an Authorised Representative for its EPR obligations in that destination country, and the AR must be established in that country - which rules out a single central service provider for all countries.
cross-border EU parcels per year
Packaging per parcel: 250 g cardboard plus 5 g plastic. Total packaging volume around 127.5 kg per year.
The problem is usually not the recycling cents but the number of registrations, minimum fees, ARs and reports.
Existing manufacturer or product packaging is neither requested from the retailer nor weighed at pakajo. What is recorded is the additional shipping packaging and materials that the retailer or pakajo uses for dispatch.
| Information | Provided by / data source |
|---|---|
| Company name and VAT ID | Provided by the customer. |
| Destination country and number of parcels | Provided by pakajo via ESN. |
| Packaging materials (paper, plastic, glass, metal, wood) | Can be entered in the pakajo system. |
| Weight per packaging component | Can be entered in the pakajo system. |
| Existing EPR/producer numbers per country | Provided by the customer. |
| Term | Briefly explained |
|---|---|
| PPWR | EU packaging regulation (Packaging and Packaging Waste Regulation). |
| EPR | Extended Producer Responsibility. |
| Producer | The party legally responsible for placing on the market; not necessarily the physical manufacturer. |
| AR | Authorised Representative - local representative for a foreign producer. |
| PRO | Producer Responsibility Organisation - organisation for collective EPR compliance. |
| SCRAP | Spanish term for a collective EPR system. |
| Volume report | Report of the packaging volumes placed on the market in a country, by material. |
| Eco-modulation | Fees can rise or fall depending on how recyclable the packaging is. |
Destination country and shipment numbers come from the ESN, and you maintain packaging data in the pakajo system. That keeps registrations, representatives and reports in view without working your way through 27 national registers.
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