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Do I really need an authorised representative in every EU country?

Verified on 2026-09-01 · Packaging law (PPWR)

In short

If you sell at a distance directly to end customers in an EU country where your business has no establishment: under Art. 45 of the EU Packaging Regulation, in principle yes – since 12 Aug 2026, with no de-minimis threshold. Typical costs are €300–500 per country per year, regardless of shipping volume. There is no obligation for countries you do not ship to directly, and in some constellations another party (e.g. your local importer) already fulfils the producer obligations.

What to do now, concretely

  1. Honestly list the countries you actually ship to directly to end customers – the question only arises there.
  2. Do the maths per country: the contribution margin of your orders there vs. the authorised representative (€300–500/year) + licence fees + effort.
  3. Check alternatives per country: selling via marketplace constellations, local importers, or deliberately dropping unprofitable countries.
  4. For the remaining countries: engage an authorised representative (many EPR service providers cover several countries) and complete the registrations.

The anger in the seller communities is real: up to 26 mandates, 26 registrations, 26 reporting cycles – no EU-wide one-stop solution exists, and even 'a single T-shirt to Bulgaria' triggers the obligations there. Many shops are dropping countries from their delivery list right now. That is exactly why the sober per-country calculation beats a blanket decision – often 2–3 markets are highly profitable and the rest never were.

Related country guides

AustriaFranceGermany

Does this apply to you too? Check your specific situation – free.

Check your business

Sources: Wortfilter: Der freie Handel scheitert an einem Pappkarton (accessed 2026-09-01) · e-commerce magazin: PPWR treibt kleine Händler in die Kostenfalle (accessed 2026-09-01) · EUR-Lex: Verordnung (EU) 2025/40 (PPWR), Art. 45 (accessed 2026-09-01)

Legal information, not legal advice. The linked official sources prevail; data marked “draft” has not been finally verified.

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