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 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. Two cover selling packaged goods at home. Two cover sending packaged goods straight to customers in another EU country. 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