PPWR 2026: What Global Packaging Exporters Need to Know About Article 45

If you export packaged goods to multiple EU Member States from a non-EU base, a US brand on Amazon.de and Amazon.fr, a UK D2C operator with Italian and Spanish customers, a Chinese supplier shipping into Belgium and the Netherlands, Article 45 of the new Packaging and Packaging Waste Regulation is the single most important text you will read between now and 12 August 2026.

It is short, blunt, and EU-wide. By a date now eleven weeks away, every Member State on your shipping list will require what France has required since 2022: a France-established authorized representative for packaging EPR, designated by written mandate, taking on the operational obligations of registration, declaration and contribution. Only it will not be a France-established representative for Germany, it will be a Germany-established representative for Germany, an Italy-established representative for Italy, and so on.

This is the guide your supply chain lead, your tax advisor and your French and German EPR counsel should read together.

What Article 45 actually says#

Regulation (EU) 2025/40 was published in the Official Journal of the EU on 22 January 2025 and entered into force twenty days later. The bulk of its provisions apply from 12 August 2026. Article 45, on authorised representatives for extended producer responsibility, has four operative paragraphs.

The producer of packaging not established in the Member State where it first places packaging on the market must designate, in that Member State, an authorised representative for EPR. The representative is empowered by written mandate to fulfil the producer’s EPR obligations there: registration, declaration of quantities, payment of financial contributions, provision of information to competent authorities. Under the Regulation itself, producer status stays with the producer. National law can go further, and in France it does: since 10 July 2026, Article L. 541-10-9-1 of the Code de l'environnement subrogates the French representative into the EPR obligations whose mandate it accepts. And the producer must designate one representative per Member State.

For a paragraph-by-paragraph interpretation, the /guides/ppwr-article-45 deep dive walks through each clause with its legal basis.

The French overlay, and it is not a detail. That last point, the producer staying legally responsible, is what EU packaging law says. French national law has since gone further on its own territory. Since 10 July 2026, Article L. 541-10-9-1 of the Code de l’environnement (law n° 2026-602 of 8 July 2026) requires any person with no establishment in France to appoint a France-established representative, across every EPR stream and not only packaging, and it subrogates that representative into all the EPR obligations for which it accepts the mandate. So on the French leg of your footprint, the mandate does more than delegate execution: within its perimeter, the obligations are carried by the representative. What does not change: you remain the producer, you answer for the accuracy of the data you supply and for anything predating the mandate, and this is a French rule that does not travel to Germany, Italy or Spain, where PPWR Article 45 and national law apply on their own terms.

Why Article 45 matters more than the AGEC law for global exporters#

France has run an equivalent national rule since 2022 under AGEC. For a brand shipping only to France, PPWR adds nothing operationally. The interesting case is the cross-border exporter with a packaging footprint across four to eight Member States.

Before Article 45, only France, Germany, Italy and a handful of others enforced an explicit representative obligation, with inconsistent rules. Some Member States allowed direct foreign registration. Others tolerated cross-border filings. Some marketplaces enforced; others did not. Article 45 converts that patchwork into a uniform EU-level baseline. Every Member State now must require a local representative, and the regulation has direct effect, no national transposition needed.

The practical implication: a brand that until now was registered only in France, hoping to be tolerated elsewhere, gets a single hard deadline to multiply its compliance footprint across the rest of the EU.

Cost grid per Member State#

The cost of compliance is roughly the same architecture in every Member State, but unit costs vary. Conservative estimates per packaging stream per market for a non-EU brand shipping consumer-volume packaged goods:

• Representative fee: €2,000 to €5,000 per year per Member State is a common market range (fixed-fee providers commit to a written figure; open-ended providers price on volumes). Our French fee is a fixed annual amount per stream, from €190/year excl. VAT for streams under the eco-organism flat-fee regime, confirmed in a written quote within one business day (see pricing).
• Eco-organism membership: €80 to €450 per year per Member State (Citeo in France, Der Grüne Punkt or other in Germany, Conai in Italy, Ecoembes in Spain).
• Eco-contribution: variable, based on declared tonnage and material mix. €0.10 to €1.50 per kilogram of packaging is a reasonable order of magnitude. Lightweight cardboard at the low end, mixed plastics and laminates at the high end.

For a four-market footprint (France, Germany, Italy, Spain), expect €12,000 to €20,000 per year all-in for the packaging stream, plus eco-contributions scaling with volume.

What changes operationally for your business#

Three operational changes hit at the same time.

Marketplace verification multiplies. Amazon.de, Amazon.it, Amazon.es will run the same EPR verification process Amazon.fr already runs. Listings deactivate if no valid registration exists in the relevant Member State. Same for Cdiscount-like national marketplaces in each country. Recovery requires a real, published producer ID in each national registry, not a representative letter, not an eco-organism confirmation. The Amazon France template, see our Amazon FR suspension recovery guide, generalises.

Annual declarations multiply. Each Member State requires its own annual eco-contribution declaration based on tonnage placed on its national market. You need to track packaging quantity by destination market, not just by SKU. If your current system reports French sales by SKU but not by packaging weight per material per market, that gap closes now.

Audit risk multiplies. A national administration (ADEME in France, ZSVR / UBA in Germany, MITE in Italy) can audit your representative independently and demand evidence of the data underlying the eco-contribution calculation. Document your packaging composition declarations, your bill of materials per SKU, weights, material mix, and make sure your representative can produce them on request.

Timeline, what to do in the next 11 weeks#

The compressed schedule looks like this.

Weeks 1 to 2 (now). Build the destination-market view of your packaging output. Which Member States do you ship to? What is the annual tonnage estimate per market and per material type? Even rough estimates are sufficient, you can refine later.

Weeks 3 to 4. Engage representatives in each Member State where you currently have no registration. Mandates are typically electronic, no notary. Sign per market.

Weeks 5 to 8. Eco-organism dossiers filed in each market. France: Citeo. Germany: register with ZSVR (the central German register) and pick a German licensing scheme. Italy: Conai. Spain: Ecoembes. Belgium: Fost Plus. Netherlands: Verpact.

Weeks 9 to 11. Producer IDs published on each national register. Upload to marketplaces in each market before 12 August. Listings stay live.

We cover France directly, with a fixed annual fee per stream confirmed in a written quote within one business day. We act as your authorized representative in France only. For other EU Member States, a separate authorized representative established in each country is required, that is outside our scope. Send us your destination-market footprint at /contact and we will return a written quote.

FAQ#

Do I need a separate representative for every EU Member State I ship packaging to?#

Yes. Article 45(4) of PPWR explicitly requires one representative per Member State where the producer makes packaging available on the market for the first time. There is no single-window or one-stop-shop mechanism, unlike VAT IOSS. A US brand selling packaged goods into France, Germany, Italy and Spain needs four representative engagements.

Does PPWR replace national EPR schemes like AGEC in France or VerpackG in Germany?#

No. PPWR sits on top of and harmonises minimum obligations. National schemes continue to run the registration, declaration and contribution machinery. France will continue applying AGEC and L. 541-10; Germany will continue running LUCID. PPWR adds direct EU-level enforcement of the representative requirement for packaging only, not for WEEE, textile, batteries or other streams. France goes further than PPWR on its own territory: since 10 July 2026, Article L. 541-10-9-1 of the Code de l’environnement makes a France-established representative mandatory for a producer with no French establishment across all 19 EPR streams, and subrogates that representative into the obligations it accepts.

When does the obligation crystallise and is there a grace period?#

The obligation enters into force on 12 August 2026, the general date of application of the PPWR. There is no transitional grace period in Article 45 itself for non-EU producers. Marketplaces in every Member State will start verifying representative designation on or around that date, mirroring the existing Amazon France regime.

Get a written quote in one business day#

PPWR enforcement is a deadline, not a discussion. If you are still represented in fewer EU markets than you ship to, the next eleven weeks decide whether your listings stay live in August. Talk to us at /contact for a written assessment of your full EU packaging footprint, with French coverage at a fixed annual fee per stream, from €190/year excl. VAT for streams under the eco-organism flat-fee regime, confirmed in a written quote within one business day (how the fee is built: /pricing).

Sources & references#

All legal and regulatory claims in this article trace back to the following primary sources (Légifrance, EUR-Lex, ADEME and equivalents). Verified 31 July 2026.

• Article L. 541-10 du Code de l’environnement (cadre général REP), Légifrance
• LOI n° 2026-602 du 8 juillet 2026, article 5, 2°, creating Article L. 541-10-9-1 du Code de l’environnement (JO of 9 July 2026, NOR TECX2407166L), in force 10 July 2026. French statutory subrogation of the representative, all streams.
• Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance
• Regulation (EU) 2025/40 (PPWR), EUR-Lex
• Citeo, éco-organisme emballages ménagers
• ADEME, Agence de la transition écologique
• Amazon EU Seller Central, EPR France requirements
• VerpackG, Verpackungsgesetz (allemand), Gesetze im Internet
• LUCID, Verpackungsregister (Stiftung Zentrale Stelle Verpackungsregister, Allemagne)
• Real Decreto 1055/2022 (España, packaging EPR), BOE
• CONAI, Consorzio Nazionale Imballaggi (Italia)
• Cadre général des filières REP, Ministère de la Transition écologique