Vivifex

Blog · 2026-09-03

Packaging EPR in all 27 EU countries, in one table

Register, threshold and authorised representative for each member state. Rows dated. Where the authority has not answered, the cell stays empty.

The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 — has applied since 12 August 2026. The product rules are the same in every member state. Registration is not.

Article 44 says you register in the national producer register of each country where you first make packaging available. There is no EU window. The implementing act that would even describe a common format was due on 12 February 2026. It has not been adopted. Until it exists, and for eighteen months after it does, you use whatever that country already runs — or you find that the country has no packaging producer register at all.

Most guides skip the second half of that sentence.

What we actually compiled

The table is here: Packaging EPR by EU country.

Each of the 27 rows carries the same fields: the register if one exists, the authority that runs it, whether it is live, who has to register, the threshold where one is written down, whether a producer established abroad needs an authorised representative, the reporting cadence where we found it, the household and industrial schemes, the sources, and the date the row was checked.

A source is typed as authority, scheme or third party. Authority wins. Where two official pages disagree, or the page we read does not answer the question, the row records an open question and shows it. A blank cell is information. A guessed kilogram figure is not.

What is the same in every country

These sentences come from the regulation, not from a ministry.

Registration is a condition of placing packaging on that market (Article 44). A producer that makes packaging available in another member state directly to end users must appoint an authorised representative there (Article 45(3)), from 12 August 2026. Penalties are national (Article 68). A central EU register is not before 1 January 2029.

One more fact belongs next to those, because the paid guides treat it as settled. The Commission has proposed COM(2025) 982: suspend Article 45(3) until 1 January 2035 for producers established in the Union. Third-country producers are not covered the same way. The proposal is not law. Until a published regulation says otherwise, Article 45(3) stands. In the table that is an open question, not a verdict.

What changes

The register. Germany's LUCID is live and free. Latvia's State Environmental Service states there is no packaging producer register and it issues no EPR numbers. Ireland's register is not in place yet; Repak runs the scheme. The Netherlands expects a PPWR register from 2027. Calling all of these "register here" is how a firm files in the wrong place.

The threshold. Germany: none. Belgium: 300 kg, household and industrial together. The Netherlands: 50,000 kg for now, and Verpact expects that line to go. Ireland: 10 tonnes and €1 million turnover — both. Tables that print "0 kg" for Cyprus or "50 kg" for Estonia are copying each other. We would rather leave the cell empty.

The authorised representative. Some countries already required a local person for distance sales to consumers. Some apply the duty through the register. Some pages we read do not mention the role. "Mandatory in all 27 from 12 August" is the regulation's sentence. Whether that country has a mandate text and a person you can appoint is a different sentence. The table keeps them apart.

How to read a row

Open the overview. Read the status first. If the register is not live, stop hunting for a PPWR number and read the note. Every URL under the country is the page we used. If "What is not settled" is on the page, that is the part a brochure usually fills in. Do not fill it in from the brochure.

Whether the country asks it of you is a different question. That turns on volumes, first placing, and whether you sell at a distance to consumers. The table does not answer it.

What we are not

Tarafex does not register you. It is not an authorised representative. It does not pay a scheme. It produces the kilograms by material and by country, reusable held apart, from shipments you already record. The number a register asks for is that number. The register itself stays national.

If a cell is wrong, write to hello@vivifex.com with the source. We correct against the source, not against a brochure.

Checked 3 September 2026. Not legal advice.

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