Commonly got wrong
“Registering once somewhere in the EU covers selling to the whole EU.”
Why this one goes around
The packaging design rules really are the same across the EU, so it is a reasonable guess that the paperwork is too. The part that decides who pays for collecting packaging waste stayed national, and each country runs its own register.
The rules that settle it
A producer has to register in every country where it first makes packaging or packaged goods available, or where it unpacks packaged goods without being the one who uses them. Until that registration is in place, it may not do either of those things in that country. Where a country allows it, an authorised representative registered there can hold the registration instead.
Source: Regulation (EU) 2025/40, Art. 44(2) and Art. 44(4) — read from this source on
A business that sends packaged goods straight to customers in another EU country has to appoint someone based in that country to handle its packaging duties there. The rules call this person an authorised representative for extended producer responsibility. It has to be done in writing, and separately for each country. For businesses based outside the EU the picture is different: each country decides for itself whether to require one.
Source: Regulation (EU) 2025/40, Art. 45(3) — read from this source on
Producer is the word the rules use for whoever first puts packaging onto a country's market. It is worked out country by country, so one business can be a producer in several countries at once. There are five ways to become one, and the first four split by what is being made available rather than only by where. Two cover a business in its own country. One is for packaging on its own: the outer boxes and wrapping goods travel in, the cups and bags filled at a counter, the packaging used in farming and fishing. The other is for goods inside any other packaging. Two more cover the same pair sent to another EU country, but only where the goods go directly to the people who will use them. The fifth catches a business that unpacks goods without being the one who uses them, unless somebody earlier in the chain already counts as the producer.
Source: Regulation (EU) 2025/40, Art. 3(1), point (15) — read from this source on
Work out which of these apply to you · Other things people get told