As of August 2026 · For online retailers

Packaging EPR in the EU. From 12 August 2026 new obligations apply.

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.

0
EU countries with a procedure
0
of those need a representative from 12 Aug
€0.01 to €0.10
EPR per standard parcel
0
countries flagged red for action
What is changing

The PPWR harmonises Europe. Implementation stays national.

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.

Calculation basis for this overview: 250 g of corrugated board or cardboard plus 5 g of plastic per standard shipment. The figure shown is only a guide value for the volume-based EPR contribution. Registrations, minimum contributions, representatives and service costs may apply on top.
How to read this overview

Three levels show you where to act first.

Red · Action required

An existing obligation is not one to postpone. Checking and registering comes first here.

8 countries
Orange · Check

Clarify status, thresholds and the representative requirement case by case before you ship.

16 countries
Green · Threshold first

A small-quantity rule or exemption may apply. Check your annual volume first.

3 countries
Country overview

27 countries at a glance. Filter by urgency.

All 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.

Authorised Representative

Why you need an Authorised Representative in the destination country from 12 August 2026.

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.

A retailer established in the EU needs no AR for its own country of establishment, only for the other Member States it ships to. A retailer established outside the EU needs an AR in every Member State in which it is a producer, Germany included.
If the retailer is not a producer under the PPWR for the packaging concerned, that packaging does not create an AR obligation for it.
Legal basis: EU Regulation 2025/40 (PPWR), Art. 3(20) and Chapter VIII.

Official regulation text on EUR-Lex →

Example: small shipper

500

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.

Preparation

Which data to have ready.

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.

InformationProvided by / data source
Company name and VAT IDProvided by the customer.
Destination country and number of parcelsProvided by pakajo via ESN.
Packaging materials (paper, plastic, glass, metal, wood)Can be entered in the pakajo system.
Weight per packaging componentCan be entered in the pakajo system.
Existing EPR/producer numbers per countryProvided by the customer.
Recommendation for retailers

Five points that keep you on the safe side.

1Do not stop EU cross-border shipping across the board. For most parcels it remains worthwhile.
2Check existing national obligations and available registrations now.
3Start recording packaging data properly from today.
4Do not mistake small-quantity rules for a general exemption.
5Where PPWR procedures are still open, comply with the existing national rules and keep the data for later reports.
Key terms

Briefly explained.

TermBriefly explained
PPWREU packaging regulation (Packaging and Packaging Waste Regulation).
EPRExtended Producer Responsibility.
ProducerThe party legally responsible for placing on the market; not necessarily the physical manufacturer.
ARAuthorised Representative - local representative for a foreign producer.
PROProducer Responsibility Organisation - organisation for collective EPR compliance.
SCRAPSpanish term for a collective EPR system.
Volume reportReport of the packaging volumes placed on the market in a country, by material.
Eco-modulationFees can rise or fall depending on how recyclable the packaging is.

pakajo makes EPR manageable.

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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