The Library
Everything we've worked out, written so you can use it.
Plain language, no jargon, no paywall and no email gate. If a guide here saves you a €900 consultation, it has done its job — whether or not you ever join. Every piece carries the date it was last checked, because this area changes monthly and an undated guide is worse than none.
Does any of this actually apply to me?
The five questions that decide it: where you're established, where your buyers are, whether you sell through a marketplace, what your packaging weighs, and whether anyone downstream is already covering you. Answer them in order and most people find their situation is simpler than they feared.
The deadline list
A rolling list of what falls due where, kept current rather than written once and abandoned. Pinned, dated, and corrected in public when we get something wrong.
Manufacturer or producer?
PPWR gives you two roles and people keep merging them. Producer is the EPR role, decided per country by who first places packaging on a market. Manufacturer is the conformity role, decided EU-wide by whose name is on the packaging — including the micro-enterprise exception that may push it onto your supplier.
What counts as packaging?
A concrete list for makers. The carton, the tape, the filler, the card an earring is mounted on, the pouch, the belly band — and what doesn't count, like the thank-you card that packages nothing. Plus two edge cases we haven't settled.
GPSR in plain language
The General Product Safety Regulation is the reason most sellers left, and it is widely misread. What it actually requires is a named person or company inside the EU who takes responsibility for your product — the "responsible person" — plus documentation you can produce on request.
EPR and PPWR: who pays for the packaging
Extended Producer Responsibility makes whoever puts packaging on a market pay for collecting and recycling it. The fee itself is weight-based and usually small. The registration and the representative are what actually cost you.
What an authorised representative is — and isn't
An authorised representative is a company established in a member state that accepts specific legal duties on your behalf. They are not a mailbox, they are not a formality, and their fee is the single biggest line in most small sellers' compliance bill. Which is exactly why we buy it together.
Where registration can be delegated — and where it can't
The single most misunderstood point on this file, and it changes at every
border — by design. Art. 44(3) PPWR says member states
may allow registration to be handled under a written mandate, normally
by your authorised representative. It is an option each state either took or
didn't. Germany didn't: registration there is a personal duty you must
complete yourself, and any service offering to do it in your name is selling
you something that isn't compliant. Austria built its route the opposite way
round. So the question to research isn't the folkloric "which countries let
you delegate" — it's the answerable one: which member states exercised the
Art. 44(3) option, and on what terms.
Myth vs fact
Ten things small sellers keep being told that aren't true. Your supplier's compliance doesn't cover your use of their box in another country. The customer is not the importer on a direct sale. Selling from your own site removes the middleman, not the obligation. Recycled packaging is still packaging. Adapted, with permission and with citations added, from a community guide by DippyNikki.
The words, in plain English
A glossary. Producer, manufacturer, placing on the market, making available, distance contract, PRO, dual system, authorised representative — terms that look like ordinary English and are not. Most of the confusion on this file is two people using one word for two different things.
When the marketplace asks for your number
Etsy, Amazon and eBay verify registration numbers because
Art. 45(6) PPWR requires them to, before they may let you sell at
all — and fulfilment providers must run the same check and suspend you if it
fails. What each platform asks for, in what format, and what to do when a
valid number gets rejected anyway. Including the thing nobody asks about: a
platform can lawfully pay your EPR fees under written mandate, even
though it can't do your registration.
Germany — packaging EPR
The only country so far that wants both halves: register in LUCID yourself, and — new since 12 August 2026 — appoint a representative for everything else. Plus dual systems, the 80/50/30 tonne thresholds, marketplace checks and the €200,000 penalty tier.
Austria — packaging EPR
Same format, Austrian specifics: the representative requirement for non-established sellers — which in Austria is all of it, because a foreign seller may not register alone — plus the six approved systems, the 1,500 kg + 1,500 kg small-quantity rule, costs and penalties.
France — packaging EPR
France didn't wait for the PPWR: Law n° 2026-602 of 8 July 2026 made a French mandataire compulsory from 10 July, a month early, with no transition period, for every EPR stream — and for non-established marketplaces too. Plus the mirror image of Germany on registration, the IDU you have to publish on your own website, Citeo's €80 flat rate under 10,000 units, Triman and Info-tri, and a €30,000 fine with a €20,000-a-day astreinte behind it.
Belgium — packaging EPR
The country where 12 August changed who the producer is: Belgian importers largely stopped being it and their foreign suppliers started. Plus the representative that must itself be registered with EPRiBEL, Fost Plus registering members collectively, the split declaration year, and the Green Dot coming off your artwork in February 2027.
Bulgaria — packaging EPR
A free register you may not be able to get into: NISO submissions run on a qualified electronic signature and no foreign-producer route has been published. Plus the three compliance routes, the monthly declaration, and the product-fee liability you can inherit when your own scheme misses its targets.
Croatia — packaging EPR
Croatia required a representative before the EU did — its 2023 ordinance names third-country sellers expressly — so exposure starts well before 12 August 2026. Plus RPPO, a state fee rather than a scheme to choose, monthly reporting and monthly payment, and the rule that makes a marketplace the producer for an unregistered seller.
Cyprus — packaging EPR
One collective system, one deadline at the end of February, €100 for the first tonne — and one unanswered question: which register entry a foreign producer actually needs. The cost of Cyprus isn't money, it's establishing what the route is.
Czechia — packaging EPR
Home of the most misquoted number in EU packaging: the 300 kg exemption, which is two tests rather than one and cannot disapply an EU regulation whichever way you read it. Plus the List of Persons, the representative who may file in its own name, EKO-KOM's CZK 1,600, and quarterly statements.
Denmark — packaging EPR
Fourteen days of lead time before your first shipment, seven days for your representative to accept before the request expires, compulsory scheme membership, and a register that stops you selling rather than fining you. Also the one country in the first nine where a non-EU seller is treated more lightly than an EU one.
Estonia — packaging EPR
§ 12(7) turns on your seat not being in Estonia, so EU and non-EU sellers are equally inside it — and the appointment isn't complete until the mandate is filed in the register. Plus PAKIS, records to the kilogram, 31 March, the audit that starts at 20 tonnes, and fines reaching €200,000.
Finland — packaging EPR
No minimum sales limit, B2B counts, Åland is a different jurisdiction for this
purpose, and the deadline lands on 31 January while you're still closing
the books. Plus the gap worth knowing about: Finnish guidance still calls the
representative a choice for packaging, and Art. 45(3) doesn't.
Greece — packaging EPR
Clear about who you are, vague about how. Greek law names foreign distance sellers expressly — then gives you a register in Greek, a scheme whose tariff isn't published, and a rule that can shift EPR responsibility onto the marketplace unless you hand over proof of registration.
Hungary — packaging EPR
The most machined system in the set: one concession company, no choice of scheme, an eight-digit KF code on every line, quarterly declarations by the 20th and an invoice payable in 15 days. The representative rule is national law from 2023 and would survive any EU suspension untouched.
Ireland — packaging EPR
A certain duty with an unpublished procedure. The national major-producer test is generous — 10 tonnes and €1 million, both — so small sellers were genuinely outside Repak. From 12 August 2026 the PPWR applies with no threshold at all, and Ireland hasn't published the door yet.
Italy — packaging EPR
Italy already makes you label the packaging — material code plus separate-collection information — under a national duty that is live now, not in 2028. Plus CONAI's seven consortia, a €5.16 joining fee, and a plastic tariff running from €40 to €790 a tonne by recyclability band.
Latvia — packaging EPR
Where EPR and tax are the same conversation. Joining a scheme is how you get exempted from the Natural Resources Tax; at 300 kg participation becomes mandatory, and not joining when you must can see the tax charged at double.
Lithuania — packaging EPR
A mature system built for Lithuanian companies. GPAIS, two licensed organisations, a 0.5-tonne pollution-tax relief that is conditional rather than free — and no published route at all for a foreign seller. The thinnest of our desks, and we say so on the page.
Luxembourg — packaging EPR
The easiest market in the Union to comply in and the easiest to skip by accident. National law already made foreign direct sellers responsible before the PPWR did. One accredited organisation, a €50 minimum, one deadline — and non-household packaging now in scope.
Malta — packaging EPR
Better prepared than most: ERA runs numbered forms and already publishes a written-mandate form for representatives. It also makes an approved auditor certify what you report — a standing cost rather than a risk. The under-100 kg declaration is a simplified route, not an exemption.
Netherlands — packaging EPR
The most generous threshold in the Union — 50,000 kg, below which a micro-seller genuinely owes nothing. With a carve-out inside it: single-use plastics and deposit containers must be registered from the first item. And a representative owed even when the contribution is zero.
Poland — packaging EPR
The barrier isn't the fee — it's the login. BDO access normally needs someone who can authenticate through Poland's national system, typically with a PESEL. And the 1,000 kg relief is de minimis aid you must claim in writing by 15 March, every year.
Portugal — packaging EPR
Better prepared than most: SILiAmb already carries an authorised-representative classification and APA says it's mandatory where applicable. Two declarations in one round — correct the past, estimate the future — and no small-volume exemption at all.
Romania — packaging EPR
The only desk where our advice is to stop until the structure is confirmed in writing. Clear obligations, no published foreign-producer route, monthly AFM filing by the 25th — and the RON 2/kg figure everyone quotes is a penalty on missed targets, not a tariff.
Slovakia — packaging EPR
Home of the most-repeated claim in European packaging compliance. Under 100 kg you really are released from the Slovak representative duty — § 54(6) is real law — and you still owe the EU one. Both errors are in circulation; here's the line, with the sections.
Slovenia — packaging EPR
The 15-tonne threshold was abolished in 2021 — if your guide still lists it, it's five years stale, and your exposure predates the PPWR entirely. Plus a second regime most guides never mention: an environmental levy run by the tax authority with its own quarterly return.
Spain — packaging EPR
Art. 17.2 of Royal Decree 1055/2022 named third countries before the EU did. Your ENV number goes on your invoices, like the French IDU — and if you appoint no representative, the first Spanish distributor may become subsidiarily responsible. Which is why they ask.
Sweden — packaging EPR
The most transparent system in the set and one of the least forgiving. Responsibility applies regardless of quantity; the under-1-tonne rule removes a SEK 1,250 fee and nothing else; and failing to appoint an approved PRO carries a SEK 30,000 sanction.
Every desk needs a keeper
All twenty-seven country desks are published and not one of them has a keeper. Each is a draft assembled from official sources and marked with what we could not verify. If you ship to a country and know its register, you can improve that desk faster than we can — and each one lists exactly what we are missing.
The suspension that didn't happen
If you followed the news you may be waiting for the representative obligation to be cancelled. It won't be. The Environmental Omnibus would have suspended it until 2035 for EU-established producers — the Council dropped that from its mandate on 24 June 2026. The rule that took effect on 12 August is live.
Nothing in that topic yet — try “Everything”.
How we write
Four rules, so you can tell how much to trust a page.
Everything carries a date
If a guide doesn't say when it was last checked, don't trust it — including ours. Every entry is re-checked quarterly by whoever keeps it.
Primary sources or nothing
We link the actual regulation or the actual national register. Not a vendor blog summarising a vendor blog.
"Here's what I did", not "here's what you must do"
Shared experience is enormously useful and it is not legal advice. We're careful about the difference, and so should you be.
Corrections in public
When we get something wrong we fix it in the open and say what changed. Quietly editing a page is how bad information survives.
Help us write it
You already know things other sellers need.
If you've registered somewhere, been through a marketplace verification, or simply found out the hard way what a country actually wants — that's a guide nobody else can write. Bring it to the Discord and we'll turn it into one, with your name on it or without, whichever you prefer.