PPWR Checker: Does the EU Packaging Regulation Apply to You?
The EU Packaging and Packaging Waste Regulation (PPWR) has applied since 12 August 2026, and it has no size test: a one-person shop selling into the EU is covered. What it asks of you depends on where you are based, where you sell and how. Answer four questions and this checker tells you, country by country, whether you are the producer there and what to do: register, pay fees, appoint an authorised representative, and give marketplaces and fulfilment warehouses your registration number.
PPWR applies to any business that makes, imports, distributes or sells packaging or packaged goods in the EU, whatever its size. In each EU country, the producer is the business that first makes the goods available there, which includes anyone selling directly to consumers or business users there from another country, even from outside the EU. The producer must register and pay producer responsibility fees in that country before selling, and, if it is not established there, appoint an authorised representative.
Four questions, under a minute. The EU Packaging and Packaging Waste Regulation has applied since 12 August 2026 and has no size test: it turns on where you sell and how. This tells you, country by country, whether you are the producer there and what that means: registration, fees, an authorised representative and what marketplaces will ask for. If you sell only in Great Britain, PPWR does not apply to you.
- You are the producer in Germany and France. Registration comes first: register in each before you sell there, then pay producer responsibility fees there. The country steps below say where.
- You need an authorised representative for producer responsibility in Germany and France. The Commission has proposed pausing this rule until 2035 (COM(2025) 982), but as of 16 October 2026 it has not been adopted, so it applies.
- As the manufacturer (your name or brand is on the goods, Article 3(13)), place only packaging that meets Articles 5 to 12, run the conformity assessment, draw up the technical documentation and the EU declaration of conformity, and keep them 5 years, or 10 for reusable packaging (Article 15).
- Product safety is a separate duty with a separate representative: a consumer product can only be sold in the EU if an economic operator established in the EU is responsible for it, which is an EU manufacturer or importer, an authorised representative with your written mandate, or a fulfilment service provider (General Product Safety Regulation (EU) 2023/988, Article 16, and Regulation (EU) 2019/1020, Article 4). That person does not cover packaging producer responsibility, and the Article 45(3) representative does not cover product safety.
- Register as a producer with the LUCID Packaging Register (ZSVR) before you sell there (Article 44(2)), and pay producer responsibility fees there, directly or through a producer responsibility organisation (Articles 45(1) and 46).
- Germany’s rules are in the Verpackungsrecht-Durchführungsgesetz (VerpackDG), which replaced the Verpackungsgesetz on 12 August 2026.
- Germany states no minimum quantity for registration. A LUCID registration made before 12 August 2026 still counts, but changes to it must be made by 12 November 2026 (VerpackDG § 68(2)).
- You also need a system participation agreement with a packaging system operator; packaging you ship to customers always needs one. Agreements made before 12 August 2026 end by 31 December 2026 at the latest, so 2027 needs one under the VerpackDG (§ 68(1)).
- Appoint an authorised representative for producer responsibility in Germany, because you sell directly to end users there but are not established there (Article 45(3)).
- Without an establishment in Germany the VerpackDG makes this representative mandatory, appointed in writing and in German before you first sell; it takes on your packaging-law duties, but you still register in LUCID yourself (§ 5).
- Give each marketplace your registration number for Germany and a self-certification that you meet producer responsibility there; marketplaces must ask before letting you sell (Article 45(4)).
- Give your fulfilment warehouse the same registration number and self-certification when you sign with it; it must check them (Article 45(7) and (8)).
- Official site for Germany
- Register as a producer with ADEME’s SYDREP register before you sell there (Article 44(2)), and pay producer responsibility fees there, directly or through a producer responsibility organisation (Articles 45(1) and 46).
- You register by joining an approved eco-organisme for your packaging, which enters you in SYDREP; ADEME then issues your unique identifier (identifiant unique) within two working days.
- Appoint an authorised representative for producer responsibility in France, because you sell directly to end users there but are not established there (Article 45(3)).
- As a company not resident in France, you register with your EU VAT number or your home-country tax number.
- Give each marketplace your registration number for France and a self-certification that you meet producer responsibility there; marketplaces must ask before letting you sell (Article 45(4)).
- Give your fulfilment warehouse the same registration number and self-certification when you sign with it; it must check them (Article 45(7) and (8)).
- Official site for France
- Great Britain itself is outside PPWR and runs its own packaging rules, so what you sell in Great Britain is not covered here.
- Answer the optional questions on the 2030 design rules to see what your packaging itself has to change: recyclability, recycled content, the banned single-use formats and PFAS.
What would change this result
- Selling directly to consumers or business users in another EU country makes you the producer there, with registration first: adding a country adds a registration.
- The authorised representative rule (Article 45(3)) may be paused until 2035 if the Commission’s proposal COM(2025) 982 is adopted. This checker will be updated if it is.
- The 2030 design rules (recyclability, recycled content, format bans) and the harmonised labels are still being detailed in implementing and delegated acts.
Your answers, the result for each, and the rule
| Question | Your position | The rule |
|---|---|---|
| Where you are established | Great BritainOutside the EUmet | Being established in a country, or selling directly to end users in it, decides who is the producer there (Article 3(15)) |
| Where you sell | Germany and France2 marketsmet | Producer duties are per country: one registration does nothing for the others (Article 44(2)) |
| How you sell | online to consumers, through online marketplaces and using a fulfilment warehouseDirectly to end usersmet | Selling directly to end users in another country makes you the producer there (Article 3(15)(c) and (d)) |
| Your packaging | Our own brand, made by us or for usPackaged goodsmet | Role duties: manufacturer Article 15, supplier Article 16, importer Article 18, distributor Article 19 |
| Germany | Selling directly to end users hereProduceropen | Register (Art 44(2)) and pay fees (Art 45(1)); authorised representative (Art 45(3)) |
| France | Selling directly to end users hereProduceropen | Register (Art 44(2)) and pay fees (Art 45(1)); authorised representative (Art 45(3)) |
Why this result: You are the producer in every EU country where you sell directly to end users, even with no office there (Article 3(15)(c) and (d)). Each of those countries needs its own registration and fees, and while the rule stands, an authorised representative in each one where you are not established (Article 45(3)). Marketplaces and fulfilment warehouses have to see your registration number before they serve you, so missing registrations show up as blocked listings rather than letters from a regulator.
Country registers were read on each official site on 13 October 2026 for Germany, France, the Netherlands, Belgium, Spain, Poland and Austria. Italy and other countries get the general duty until we have checked their register. Northern Ireland applies PPWR under Article 13(3) of the Windsor Framework with the producer responsibility articles out of scope; Great Britain is outside PPWR. This checker states no recycled-content percentage: the minimums differ by category.
Parts of PPWR are still being detailed, and the Commission has proposed pausing the authorised representative rule. We will email you when something this checker applies changes, and not otherwise.
This checker applies the producer definition, the registration, fee, authorised representative, marketplace and fulfilment rules, the role duties and the 2030 design rules of Regulation (EU) 2025/40, with the national registers named above. It reads nothing of yours. It is reference information, not legal advice, and does not decide what a national authority would conclude about your case.
Who is the producer in each country
Most of the obligations follow one question, asked separately for each EU country you sell into: who first makes the packaging or packaged goods available there? That business is the producer in that country under Article 3(15) of Regulation (EU) 2025/40, and the producer is the one who registers and pays.
| Your situation | Producer in that country |
|---|---|
| You are established in the country and sell there | You (Article 3(15)(a) and (b)) |
| You sell directly to consumers or business users there from another EU country, online, through a marketplace or from a warehouse | You (Article 3(15)(c) and (d)) |
| You sell directly to end users there from outside the EU, for example from the UK or the US | You (Article 3(15)(c) and (d)) |
| You sell to a business based there that resells the goods | Usually that business, because it first makes them available there |
| You supply empty packaging that your customers fill or brand | Your customers, for the packaged goods; you, for transport, service and primary production packaging you supply directly |
Your other duties depend on your role, whoever the producer is. A manufacturer (anyone whose name or brand is on the product) must make packaging that meets the design rules and keep the technical documentation and EU declaration of conformity (Article 15). An importer must check that the manufacturer did so and put its own name and address on the packaging (Article 18). A distributor must check, before selling, that the producer is registered and the packaging is labelled (Article 19).
Selling into the EU from the UK, US or elsewhere
A business outside the EU that sells directly to consumers or business users in an EU country is the producer there. Three duties follow, all in Article 45:
- Register and pay fees in each country you sell into (Articles 44(2) and 45(1)), directly or through a producer responsibility organisation (Article 46).
- Appoint an authorised representative for producer responsibility in each EU country where you sell directly to end users but are not established (Article 45(3)). The European Commission proposed in December 2025 to suspend this rule until 1 January 2035 (proposal COM(2025) 982). As of 13 October 2026 it has not been adopted — the EU’s official record lists no act amending the regulation — so the rule applies.
- Give marketplaces and fulfilment warehouses your registration number for each country, with a self-certification that you meet producer responsibility there. Online marketplaces must collect these before letting you sell to consumers in that country (Article 45(4)), and fulfilment service providers, such as Amazon FBA or a third-party warehouse, must check them when you sign up (Article 45(7) and (8)).
Great Britain is outside PPWR and runs its own packaging rules. In Northern Ireland PPWR applies under Article 13(3) of the Windsor Framework, but a named list of articles, including the producer responsibility ones, is outside scope there: the product rules apply, registration and fees under PPWR do not.
Where to register in the main markets
PPWR has each EU country set up a producer register (Article 44(1)). Countries already run packaging registers and schemes under their existing laws, and these are where producers register today. We read each of these on its official site on 13 October 2026.
| Country | Where to register | What the official source says |
|---|---|---|
| Germany | LUCID Packaging Register (ZSVR) | Anyone distributing packaged goods in Germany registers; no minimum quantity is stated. Producers also need a system participation agreement; packaging shipped to customers always needs one. A company not established in Germany appoints an authorised representative but still registers in LUCID itself. |
| France | ADEME’s SYDREP register, through an approved eco-organisme | Joining an approved eco-organisme registers you; ADEME issues your unique identifier within two working days. Non-resident companies register with their EU VAT number or home-country tax number. |
| Netherlands | Verpact (formerly Afvalfonds Verpakkingen) | Runs the Dutch producer responsibility scheme for packaging. |
| Belgium | Interregional Packaging Commission (IRPC, becoming EPRiBEL) | Companies placing more than 300 kg of packaging a year join Fost Plus (household packaging) and Valipac (industrial and commercial), or report to the IRPC themselves. |
| Spain | Registro de Productores de Producto, packaging section (MITECO) | Set up under Royal Decree 1055/2022. MITECO published a note on who counts as a packaging producer under PPWR on 13 August 2026. |
| Poland | BDO register | Register before you start, with the marshal of your voivodeship. Authorised representatives are a registrable category. |
| Austria | A licensed collection and recovery system (VKS coordinates) | Producers take part in a licensed system; the VKS, a federal company, publishes the list of participants. |
| Italy | Not yet verified by us | We could not read the official source; check Italy’s packaging scheme before you sell there. |
Sources: verpackungsregister.org (mail order and online retailers), the French decree of 11 February 2022 on registering producers (published by INERIS on AIDA), business.gov.nl, ivcie.be, miteco.gob.es, bdo.mos.gov.pl and vks-gmbh.at, all read 13 October 2026. National schemes change; check the official site before you register.
There is no size test
Most rules on this site turn on a number: turnover, employees, energy use. PPWR does not. Whether it reaches you depends on what you do with packaging and where, so a small seller is covered in the same way as a large one. Some national schemes do set quantity thresholds for fees or take-back, such as Belgium’s 300 kg a year, but those are national rules, not a threshold for PPWR itself.
What changes on 1 January 2030
Two dates do different work. 12 August 2026 is when the regulation started applying, along with registration and the PFAS limits. 1 January 2030 is when most packaging has to be different:
- Recyclability becomes a condition of sale. From 1 January 2030, or 24 months after the Commission’s design-for-recycling rules if that is later, packaging must reach grade A, B or C (at least 70% recyclable), and grade A or B (at least 80%) from 1 January 2038 (Article 6). Where the choice is close, design for the 2038 threshold to avoid redesigning twice.
- Minimum recycled content applies to plastic packaging, set by category and rising again in 2040 (Article 7).
- Six single-use formats are banned (Article 25 and Annex V): plastic grouped packaging such as shrink wrap around multipacks; plastic packaging for fresh fruit and vegetables under 1.5 kg; plastic packaging for food and drink filled and consumed on the premises in hospitality; plastic single portions of condiments, sauces, sugar and creamer in hospitality; single-use toiletry packaging for individual hotel bookings; and very lightweight plastic carrier bags. Each has exceptions set out in the annex.
The PFAS limits do not wait for 2030: they have applied to food-contact packaging since 12 August 2026 (Article 5). The usual source is intentional use, such as grease-resistant papers, barrier coatings and some moulded fibre, so ask your suppliers first.
Why there is no recycled-content percentage here
The recycled-content minimums differ by category: contact-sensitive packaging, PET, other plastics and single-use plastic drinks bottles each have their own, and they rise in 2040. One headline figure applied to the wrong category gives a confident and wrong answer, and a portfolio average can sit above it while one category falls short. So the checker asks whether you know your figure by category and never says what it should be. Imported plastic must meet the same standards as plastic made in the EU, so buying packaging from outside the EU does not lower the requirement.
What this checker does not do
It reads nothing of yours and calculates nothing: it applies the regulation’s rules to your four answers. It names the register only for the countries we have verified, and it does not decide what a national authority would conclude about your particular case. It is reference information, not legal advice.
How we keep it current
The checker applies Regulation (EU) 2025/40 as our reviewed standards page records it, and the national registers as we last read them. Three things are moving: the Commission’s proposal to pause the authorised representative rule, the implementing and delegated acts that fill in recyclability criteria, labels and recycled-content rules, and the national schemes. The “Tell me when these rules change” box in the result emails you when something the checker applies changes, and not otherwise.
Frequently asked questions
Yes. PPWR has no turnover, employee or tonnage threshold: it applies to any business that makes, imports, distributes or sells packaging or packaged goods in the EU. Some national schemes set their own quantity thresholds for fees, such as Belgium’s 300 kg a year, but those do not take you out of the regulation.
Usually, yes. If you sell directly to consumers in an EU country, through your own shop or a marketplace, you are the producer there, wherever you are based. You must register and pay fees in that country, and the marketplace must collect your registration number and a self-certification before letting you sell there (Article 45(4)).
If you sell directly to end users in an EU country where you are not established, Article 45(3) requires one for producer responsibility in that country. The Commission proposed in December 2025 to suspend this until 2035, but as of 13 October 2026 the proposal has not been adopted, so it applies.
To what they sell into the EU, yes: a UK business selling directly to consumers in an EU country is the producer there. Great Britain itself is outside PPWR. In Northern Ireland it applies in part: the product rules apply, but the producer responsibility articles do not.
Your producer registration number for each EU country you sell into, and a self-certification that you meet producer responsibility there. Fulfilment service providers, such as Amazon FBA or a third-party warehouse, must check these when you sign with them (Article 45(7) and (8)).
Since 12 August 2026, including registration and the PFAS limits on food-contact packaging. Most design rules start on 1 January 2030: recyclability, minimum recycled content for plastic packaging, and the bans on six single-use formats.
No. Imported plastic must meet the same standards as plastic placed on the market from within the EU, including minimum recycled content. Buying from outside the EU moves the work of showing compliance onto you and your supplier rather than removing it.