EU ★ Market GuideBeta

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. Public provider prices are mostly around €250–500 per country per year (volume-dependent also above that, e.g. up to about €880) – and the full base fee applies even for tiny volumes. 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

Your to-dos

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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. Keep two developments in view: at EU level, a softening or removal of the Art. 45 authorised-representative requirement is being negotiated (not adopted as of Sep 2026), and some countries apply it pragmatically – the Netherlands, for instance, currently do not require an authorised representative below the 50,000 kg Verpact threshold. But don't treat that as a free pass: formally, the obligation applies.

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

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