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Customs & Duties

The EU's Packaging and Packaging Waste Regulation started to apply on 12 August 2026. It entered into force back in February 2025, but an eighteen-month transition ran until this month, so the rules now apply across all 27 member states.

PPWR is a regulation rather than a directive. The Packaging Directive it replaces dated from 1994 and left each member state to write its own version, so compliance in France looked nothing like compliance in Poland. A regulation applies directly and identically everywhere, with no national transposition step, so what you learn about one market now largely holds for the rest.

There is also no run-off period for stock you have already produced. Packaging sitting in a warehouse in Rotterdam is judged by the rules as they stand today. We've been hearing from ClearTools customers already that these new rules are so onerous that they've stopped selling into the EU in the short term until they can really get their head around them.

Are you the producer?

Whether the expensive obligations land on you or on somebody else depends less on your product than on how it reaches the customer. Under PPWR, the producer is whoever first makes the packaging available in a given member state.

• Selling to an EU distributor or importer who then sells on. They are the producer in that market. They register, report tonnages and pay the fees. You still need to supply the packaging data and conformity documentation they rely on, but the registrations are theirs.
• Selling direct to EU consumers from your own website, DDP. You are the producer in every country where those orders land. Ship to customers in eight member states and you have eight registrations to make.
• Selling through a marketplace. This depends on the programme and the fulfilment route. Marketplaces are now obliged to check that their sellers have met certain obligations, so it is worth confirming channel by channel what the platform handles and what it leaves with you.

If you are the producer and have no legal establishment in that country — which describes essentially every UK business — you must appoint an authorised representative there under Article 45. One per member state, appointed by written mandate, handling your registration, filing your packaging data and paying your fees. The regulation contains no size exemption. A few national schemes apply their own thresholds, but the safe assumption is that placing packaged goods on a market means registering on that market.

Representative fees commonly run between €2,000 and €5,000 per country per year, though the market is competitive and some providers quote considerably less. On top of that sit the EPR fees themselves, which are eco-modulated: the harder your packaging is to recycle, the more you pay.

This is also worth raising against your Incoterms. A business shipping DAP to an EU customer who acts as importer of record sits in a very different PPWR position from the same business shipping DDP.

Two kinds of representative

PPWR uses two separate representative roles, and appointing one does not give you the other.

The authorised representative for extended producer responsibility (Article 45) is the one described above. Mandatory if you are a producer in a country where you have no establishment, and needed separately in each such country.

The authorised representative for product conformity (Article 17) is a different role. It is optional for non-EU manufacturers, a single mandate covers the whole EU, and its job is to hold your technical file and Declaration of Conformity and respond to market surveillance authorities.

If you have been through CE marking, the second of these will feel familiar and the first will not. They are not interchangeable, and covering one leaves you exposed on the other.

What applies now, and what comes later

Several of PPWR's headline requirements are still years out.

• Now: restrictions on PFAS in food-contact packaging and limits on heavy metals; the Declaration of Conformity and supporting technical documentation for packaging you place on the market; EPR registration and reporting; the authorised representative requirement.
• 2027: member states must have their national producer registers running by October at the latest, which will change how registration works in some markets.
• 2028: harmonised labelling arrives. Material composition and disposal-sorting labels become consistent across the EU rather than country-specific, which should reduce the artwork burden for anyone currently maintaining different versions per market.
• 2030: the substantive design requirements — all packaging recyclable, minimum recycled content in plastics, limits on empty space.

The Commission published formal guidance and an FAQ document at the end of March 2026, both worth reading if your situation sits near any of the edges.

Northern Ireland

If you supply Northern Ireland, most PPWR provisions apply to packaging placed on that market too, under the Windsor Framework. Great Britain meanwhile runs its own separate packaging EPR scheme, with its own thresholds and reporting.

A UK business selling into GB, Northern Ireland and the EU is therefore running two regimes across three markets, with a Declaration of Conformity required for two of them.

Where to start

Build a packaging bill of materials: every SKU, every component, material and weight, and which markets it goes to. That single record feeds the EPR reports, the Declaration of Conformity, the technical file and every registration you make from here. If you already maintain a packing declaration or detailed packing lists, much of the raw data is closer to hand than you think.

Then map your route to market country by country and establish where you are actually the producer. That number determines how many representatives you need, and for exporters selling through EU distributors it is often smaller than expected. Our 27-country EU shipping guide is a useful starting point for working through the markets you sell into.