---
title: "We sell to several countries without packaging EPR"
description: "Under the Packaging and Packaging Waste Regulation (EU) 2025/40, a producer registers in every Member State where it first makes packaging available, and may not sell there until it is registered. A seller delivering directly to end users in another Member State appoints an authorised representative for extended producer responsibility in that country. Then report quantities yearly and give marketplaces and fulfilment providers your registration numbers."
type: "problem"
url: "https://www.conphora.com/solutions/problem/epr-registration-country/"
markdown: "https://www.conphora.com/solutions/problem/epr-registration-country.md"
locale: "en"
language: "en"
updated: "2026-10-05"
author: "Conphora compliance team"
publisher: "Conphora"
source: "https://eur-lex.europa.eu/eli/reg/2025/40/oj"
tags: ["PPWR", "PPWD", "labelling-packaging"]
license: "Free to quote with attribution and a link to the page"
---

# We sell to several countries without packaging EPR

Under the Packaging and Packaging Waste Regulation (EU) 2025/40, a producer registers in every Member State where it first makes packaging available, and may not sell there until it is registered. A seller delivering directly to end users in another Member State appoints an authorised representative for extended producer responsibility in that country. Then report quantities yearly and give marketplaces and fulfilment providers your registration numbers.

## Why this happens

Extended producer responsibility for packaging is organised country by country. Under the Packaging and Packaging Waste Regulation (EU) 2025/40, producers have extended producer responsibility, under schemes established in line with Articles 8 and 8a of Directive 2008/98/EC, for the packaging they make available for the first time on the territory of a Member State or unpack without being end users (Article 45(1)). Their financial contributions also cover the labelling of waste receptacles and certain compositional surveys (Article 45(2)). [1]

Registration comes first. Each Member State sets up a national register within 18 months of the first implementing act on its format (Article 44(1)), and producers register in each Member State where they make packaging or packaged products available for the first time (Article 44(2)). The application contains the information in Annex IX, Part A (Article 44(5)). The competent authority receives applications electronically and grants a registration number within twelve weeks of a complete application (Article 44(11)(a) and (b)). Until a Member State's register under Article 44 is in place, how producers register in the meantime is a matter for that Member State; ask its competent authority. [1]

Selling across borders adds a representative. A producer that makes packaging available directly to end users in another Member State, whether it is established in the EU or in a third country (Article 3(1), point (15)(c) and (d)), appoints by written mandate an authorised representative for extended producer responsibility in each Member State where it sells but is not established (Article 45(3)). A Commission proposal of 10 December 2025 (COM(2025) 982) would suspend this obligation until 1 January 2035; as of 4 October 2026 EUR-Lex lists it as a proposal only, so Article 45(3) applies as written. Member States may let that representative register on the producer's behalf (Article 44(3)). Where a producer has entrusted a producer responsibility organisation with its obligations, the organisation meets the registration obligations, unless the Member State provides otherwise (Article 44(2)). [1]

Reporting is yearly. By 1 June, the producer, its representative or its producer responsibility organisation submits the information in Annex IX, Part B, point 1, for the preceding calendar year; producers under 10 tonnes in a Member State submit point 2 instead (Article 44(7) and (8)). Changes and cessation are notified without undue delay (Article 44(12)). [1]

Online channels check the result. Online platforms within the scope of the Digital Services Act's trader rules (Section 4 of its Chapter III, from which micro and small platforms are exempt unless designated as very large) that let consumers conclude distance contracts with producers obtain the registration number in the consumer's Member State and a self-certification before allowing the producer to use their services (Article 45(4)), and fulfilment service providers make best efforts to check the same information (Article 45(7) and (8)). Before the regulation, Directive 94/62/EC already required Member States to have extended producer responsibility schemes for all packaging by 31 December 2024 (Article 7(2)); that directive is repealed with effect from 12 August 2026, with listed exceptions (PPWR Article 70(1)). [1] [2]

## How to solve it

1. **List the countries where you are the producer** Take your sales by destination country for the last year. Every Member State where you first make packaging or packaged products available, including by shipping directly to end users there, is a country where you are a producer and need a registration.
2. **Appoint a representative in each country where you are not established** A producer that sells directly to end users in a Member State other than the one where it is established appoints, by written mandate, an authorised representative for extended producer responsibility in each such Member State. Member States may also require it of producers from third countries.
3. **Register in each national producer register** Submit the application to the competent authority of each Member State with the information in Annex IX, Part A: your names and brand names, address, national identification and tax numbers, and how you meet your extended producer responsibility, including a producer responsibility organisation certificate where you use one.
4. **Report the quantities every year** By 1 June each year, submit the quantities for the preceding calendar year to each register, per the format the country uses. Producers under 10 tonnes a year in a country submit the reduced data set of Annex IX, Part B, point 2, unless that country has set a lower threshold for that year.
5. **Give the platforms and fulfilment providers what they must check** Marketplaces obtain your registration number in the consumer's Member State and a self-certification before you may sell to consumers there. Fulfilment service providers receive the same information when the contract is concluded. Keep both current, and report changes to each register without undue delay.

## What you need to show

- **Registration number per Member State** — The competent authority of each Member State's producer register (PPWR Article 44(2) and (11)(b))
- **Written mandate for each authorised representative for extended producer responsibility** — You and the representative (PPWR Article 45(3))
- **Self-certification of compliance with extended producer responsibility per country** — You (PPWR Article 45(4)(b) and (7))
- **Yearly quantity reports** — You, your representative or your producer responsibility organisation (PPWR Article 44(7) and (8), Annex IX Part B)

## If you do nothing

- **Selling unregistered is not allowed** — A producer may not make packaging or packaged products available on a Member State's territory for the first time if it, or where applicable its authorised representative for extended producer responsibility, is not registered there (PPWR Article 44(4)).
- **Your fulfilment provider can suspend you** — Where your information stays inaccurate or incomplete after a request, the fulfilment service provider swiftly suspends its service for packaging offered to consumers in the Union until the request is complied with (PPWR Article 45(8)).
- **Distributors and retailers will not take the goods** — Distributors verify that the producer is registered in the register of producers before making packaging available (PPWR Article 19(2)(a)).

## Questions

### Is there one EU-wide packaging registration?

No. Each Member State keeps its own register, and the producer registers in each Member State where it first makes packaging available. The registers link to each other to make registration easier (PPWR Article 44(1) and (2)).

### How long does registration take?

The competent authority grants the registration and a registration number within a maximum of twelve weeks from the moment all the required information has been provided (PPWR Article 44(11)(b)).

### Can the marketplace handle this for us?

Where you sell through an online marketplace, the obligations in Article 45(2) may be met by the platform on your behalf on the basis of a written mandate (PPWR Article 45(4), last subparagraph). Article 45(2) concerns the financial contributions, and recital 135 refers to voluntary agreements under which marketplaces accept all or part of those costs. Registration and the other duties are not covered by that sentence, and without a mandate the contributions stay with you.

### Did packaging EPR exist before the regulation?

Yes. Directive 94/62/EC required Member States to establish extended producer responsibility schemes for all packaging by 31 December 2024 (Article 7(2)). The directive is repealed with effect from 12 August 2026, with listed exceptions (PPWR Article 70(1)).

### We ship less than 10 tonnes a year to a country. Do we still register?

Yes. The tonnage only changes what you report: below 10 tonnes in a calendar year the reduced data set applies (PPWR Article 44(8)). Registration itself has no threshold in Article 44(2).

## Regulations involved

PPWR, PPWD

## Sources

1. [Regulation (EU) 2025/40 on packaging and packaging waste](https://eur-lex.europa.eu/eli/reg/2025/40/oj) — EUR-Lex, 2026-10-04
2. [Directive 94/62/EC on packaging and packaging waste (consolidated text of 4 July 2018)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0062-20180704) — EUR-Lex, 2026-10-04