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Information only, not legal or professional advice. Provided without responsibility, and no liability is accepted for reliance on it. Verify against the linked sources.

Packaging Rules CheckEU packaging rules for small sellers

Changelog

What changed, and when

A regulatory tool that quietly goes stale is worse than none.

  1. 2026-08-15

    • First version published: obligation checker, country directory and question hub.
    • Recorded that Article 45(3) catches any producer not established in the destination member state, including EU sellers shipping cross-border — not only non-EU sellers.
    • Recorded that Council negotiations on the proposed Article 45(3) suspension (COM(2025) 982 final) were discontinued on 24 June 2026.
    • Recorded that the proposed suspension covered EU-established producers only, so it would not have helped GB or NI sellers.
    • Noted the ENVI committee vote on narrowing relief to micro and small enterprises, expected 1 October 2026 — after the application date.
    • Confirmed harmonised packaging labelling applies from 12 August 2028, not 2026.
    • Recorded that there is no general micro-enterprise exemption from packaging EPR registration.
    • Country directory researched in detail for Ireland, Germany, France, the Netherlands, Spain, Italy, Austria, Belgium, Portugal and Czechia. The other 17 member states are published as outline only and marked unchecked.
    • Recorded the Netherlands 50-tonne threshold, and the open question of whether it survives PPWR's registration duty from 12 August 2026.
    • Recorded the Northern Ireland position: PPWR product rules apply via the Windsor Framework, EPR stays under UK pEPR, and an NI to Republic of Ireland sale is a sale into the EU market.