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
0/4The 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.
Related country guides
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Check your businessSources & verification status
- 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)
- verpackungslizenz24: öffentliche Anbieterpreise für Bevollmächtigte (z. B. 299 €/Land; Staffeln 247–877 €) (accessed 2026-09-01)
- Verpact: unterhalb der 50.000-kg-Schwelle derzeit kein Bevollmächtigter nötig; EU-Diskussion über Art.-45-Pflicht (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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