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Situation

A shop with branded packaging that ships to customers in other EU countries

The situation

A business puts its own name or logo on the packaging it sends out, and posts orders to customers in more than one EU country. It is not a very small business by the size test, or it is but buys its packaging from abroad.

What appears to apply

  • Packaging that carries a business's own name or logo

    Applies now

    If a business has packaging made carrying its own name or logo, the rules treat that business as the packaging's manufacturer. That is the word the rules use, and it applies even when someone else's brand also appears on the box. Printed tape, a branded mailer or a bag with a logo are enough. Buying plain unbranded boxes is not.

    Source: Regulation (EU) 2025/40, Art. 3(1), point (13) — read from this source on

    There is one exception, for very small businesses buying packaging from a supplier in the same country. It is described separately.

  • The declaration of conformity, and who has to write one

    Applies now

    Anyone counting as the manufacturer of packaging writes a short document saying the packaging meets the design rules. It is called an EU declaration of conformity. The rules fix what goes in it and set out a model to follow. It has to be kept up to date, and written in a language the country where the packaging is sold asks for. Signing it means taking responsibility for what it says.

    Source: Regulation (EU) 2025/40, Art. 39 — read from this source on

    Nothing delays this one, so it applies from the day the rules started. Where a product needs declarations under several EU rules at once, they can be combined into one document or kept together as a set.

  • Checking packaging against the design rules

    Applies now

    Before the declaration can be written, the packaging has to be checked against the design rules. The rules set out the procedure to follow for that check. Somebody else can carry out the check, such as a laboratory, but the business named as manufacturer still carries the responsibility.

    Source: Regulation (EU) 2025/40, Art. 38 — read from this source on

  • Getting packaging details from a supplier

    Applies now

    Most small businesses cannot test what their boxes are made of, and they do not have to. Whoever sells them the packaging has to hand over the information and paperwork needed to show it meets the rules, in a language they can follow, on paper or by email. Asking for it is not a favour. It is something the supplier owes.

    Source: Regulation (EU) 2025/40, Art. 16(1) — read from this source on

    This is how a business gets material details it has no way of measuring itself.

  • Letting someone else hold the paperwork

    Applies now

    A business counting as the manufacturer can appoint someone in writing to deal with authorities on its behalf. The rules call this an authorised representative. That person keeps the declaration and the supporting paperwork available for authorities and answers their questions. They produce documents within 10 days when asked, and can walk away if the business ignores its duties. Records are kept for 5 years for single-use packaging and 10 years for reusable packaging. Writing the technical paperwork is not part of the job.

    Source: Regulation (EU) 2025/40, Art. 17 — read from this source on

    This one is optional. The representative needed for selling into another country is a separate matter, and that one is not optional.

  • When a business counts as a producer, and in which country

    Applies now

    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

    The two about sending goods to customers in another country decide whether a representative is needed there. The fifth, about unpacking, is the one most often missed.

  • Selling to another EU country and needing a representative there

    Applies now

    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

    The rules use the same phrase, authorised representative, for a different job to do with product paperwork. Same words, different role.

    National divergences recorded for this rule

    • Austria requires a foreign seller without an Austrian base to appoint an Austrian representative. Austria also asks for more than a signed letter. The appointment is made by a “beglaubigte Vollmacht” — a power of attorney whose signature has been authenticated. It has to be in German or English, list which collection and treatment categories it covers, and record that the representative agrees to take on the duties. The representative also needs an Austrian address for post.

      Source: Unternehmensserviceportal (USP), Republic of Austria — read from this source on

    • In Germany an authorised representative takes on every extended producer responsibility duty except one: entry in the LUCID packaging register. Registering, and later changing those registration details, stays a duty of the business itself and cannot be handed over.

      Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

    • A business based outside Germany that sells empty packaging or packaged goods straight to end users in Germany, with no branch there, appoints an authorised representative. That representative is entered in the LUCID register before anything is first made available on the German market. The German rules set out no exemption.

      Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

    • Germany sets three conditions on who can act as an authorised representative. The representative needs a registered office or a branch in Germany, the appointment is made by a written agreement in German, and the representative holds their own separate login for the LUCID packaging register.

      Source: Zentrale Stelle Verpackungsregister (ZSVR) — Packaging Act: Authorised representatives — read from this source on

Countries with extra requirements of their own

Only countries that have been checked appear here. A country's absence means nobody has looked at it yet, not that it asks for nothing extra.

Find someone who acts as a representativeThis site lists people and companies who say they act as a representative, organised by the country they act in. Nobody here is checked, rated or ranked — each listing is what that person wrote about themselves, and the conversation happens directly between the two parties.