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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. 2026-09-04

    • Switched off an error-collection feature our analytics provider had turned on by default. It only ever recorded faults from software on visitors' own computers, it was never listed on the privacy page, and nothing about you was collected.

  2. 2026-09-03

    • Added a question mapping which countries require a local representative: six required one for every foreign seller before the EU rules, five let you join the scheme directly, and Slovakia switches at 100 kg.
    • Recorded the mirror rule in Denmark and Finland: it is sellers based in the EU who must appoint a representative there, the opposite of what most guides assume.
    • Added a question on Hungary's product fee: it stopped applying to packaging in January 2025, the EPR fee to MOHU replaced it, and only plastic carrier bags still carry a product fee.
    • Added Hungary's product fee act to the source list.

  3. 2026-08-28

    • The last 12 countries researched in detail — Greece, Hungary, Romania, Bulgaria, Croatia, Slovenia, Slovakia, Estonia, Latvia, Lithuania, Luxembourg and Cyprus. Every EU country page now carries verified facts, sources and costs.
    • Recorded the countries where every foreign seller needs a local representative: Croatia, Hungary, Estonia, Slovenia and Greece required one before the EU rules did.
    • Recorded the real small-seller reliefs: Slovakia's 100 kg line, Lithuania's VAT-registration carve-out and 0.5 tonne tax relief, Cyprus's €100 flat band under 1 tonne, Luxembourg's €50 minimum, Estonia's no-minimum pricing.
    • Recorded the countries with no relief at all: Greece, Bulgaria, Croatia, Hungary and Romania apply duties from the first parcel.
    • Corrected figures that circulate widely: Croatia's 300 kg category and 7 cent deposit ended in 2023 and 2024; Hungary's product fee stopped covering packaging in January 2025; Slovenia's 15 tonne threshold ended in April 2021; Cyprus's 2 tonne exemption is folklore.
    • Recorded that Romania has no self-service route for foreign sellers yet, and that Bulgaria's registration mechanics for UK businesses are not yet published — both flagged on their pages.
    • Recorded Latvia's tax rates, including €44 a kilogram for expanded polystyrene — the expensive trap for foam mailers.
    • Checked the EU rules directly: since 12 August 2026, a foreign seller posting orders to customers in an EU country must register there before selling, and the representative duty covers UK sellers as well as EU ones.
    • Re-checked every source link on the site the same day: all 76 existing links and all 67 new ones resolve.
    • No countries remain outline only.

  4. 2026-08-24

    • Added a question explaining Defra EPR in plain English: what the name means, the £1 million and 25 tonne thresholds, the small and large producer bands, and that UK registration does nothing for EU sales.
    • Added a question on the "packaging licence": no such licence exists. The phrase means a register entry plus a recycling scheme contract, and the "licence numbers" marketplaces ask for are registration numbers such as LUCID, IDU and BDO.
    • Added the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 to the source list.

  5. 2026-08-24

    • Finland researched in detail, completing the Nordic countries.
    • Recorded that Finland's old €1 million turnover limit was removed on 1 January 2024. Many guides still show it — since then there is no minimum.
    • Recorded that Finland is one step, not two: joining a producer organisation — Finnish Packaging Producers through Rinki, or Sumi — covers the register and the reporting. Rinki has a contract written for foreign sellers.
    • Recorded the costs from the published 2026 price list: free registration, a yearly service fee of at least €74, and recycling fees per kilogram and material.
    • Recorded that UK sellers can join a scheme directly or appoint a Finnish representative, while sellers based in an EU country must appoint a representative.
    • Recorded the 50 tonne light-form line, and that the producer register moved to the new Finnish Supervisory Agency on 1 January 2026.
    • 12 countries remain outline only.

  6. 2026-08-24

    • Denmark researched in detail — the EU's newest packaging system, where most existing guides predate the rules.
    • Recorded the two compulsory steps: the DPA producer register, plus membership of a collective scheme such as VANA or Emballageretur. For packaging, a scheme is not optional.
    • Recorded that producers only started paying for collection on 1 October 2025, with registration required since 2024.
    • Recorded that UK businesses register directly and need no Danish representative for packaging — that duty falls on sellers based in an EU or EEA country. The EU rules may extend it.
    • Recorded the costs: DKK 1,000 to register with DPA plus a DKK 250 yearly minimum, and VANA's published 268 euro joining fee and 135 euro yearly fee for the smallest companies.
    • Recorded the 8 tonne line: under it, a totals-only yearly report and quarterly scheme reporting. It changes paperwork, not duties.
    • Recorded the yearly DPA reporting window: 1 January to 31 May.
    • 13 countries remain outline only.

  7. 2026-08-22

    • Sweden researched in detail — the only remaining outline country with its own Amazon marketplace.
    • Recorded that Sweden has no lower limit: scheme membership and registration with the Swedish Environmental Protection Agency apply from the first sale, including stock held in a Swedish warehouse.
    • Recorded the two approved schemes, NPA and TMR, with their published starting costs: SEK 2,500 a year at NPA, a SEK 1,000 a quarter minimum at TMR.
    • Recorded the agency's SEK 1,250 yearly oversight fee, waived under 1 tonne of packaging a year. Nothing else is waived below that weight.
    • Recorded the 31 March yearly reporting deadline and the penalty fees: SEK 10,000 for a late report or registration, SEK 30,000 for selling with no scheme.
    • Recorded that a Swedish representative is optional for foreign sellers under the current ordinance, and that the agency has proposed making one compulsory under the EU rules.
    • Re-checked every Poland link on 22 August 2026: all six sources and all three scheme links resolve to the claimed content. No changes needed.
    • 14 countries remain outline only.

  8. 2026-08-21

    • Added a question explaining packaging compliance schemes: what you pay one for, and that the UK's "compliance scheme" and the EU's "producer responsibility organisation" are the same thing under different names.
    • Recorded that a scheme covers one country only, and that joining one does not replace an authorised representative where one is needed.
    • Noted that some guides call a compliance scheme packaging licensing — the same thing under another name.

  9. 2026-08-20

    • Poland researched in detail — the biggest EU market that was still outline only.
    • Recorded that the BDO register has no lower limit: you register before your first sale to Poland, or before stock arrives in a Polish warehouse.
    • Recorded the 1 tonne relief: at or under it you can be excused the recycling targets and the product fee, but you still register and file the yearly report by 15 March.
    • Recorded the register fees of 200 zł and 800 zł, current since January 2025. Many guides still show the old 100 zł and 300 zł.
    • Recorded that a foreign business with no Polish branch applies on paper to the marshal for the Warsaw region.
    • Noted that Poland's replacement packaging law was still in parliament in August 2026, so these rules will change.
    • 15 countries remain outline only.

  10. 2026-08-19

    • Malta researched in detail — the first country chosen because visitors were reading its page.
    • Recorded Malta's 100 kg threshold: at or under it, a yearly declaration form to ERA is enough. Over it, you register with ERA and join GreenPak or Green MT, or handle recovery yourself.
    • 16 countries remain outline only.

  11. 2026-08-18

    • Also counted now: clicks that visibly do nothing, as a sign a page is confusing. Which element was clicked is recorded, never anything you type.
    • Also counted: how long pages stay open, and how far down them people scroll.

  12. 2026-08-17

    • Started keeping anonymous counts of how the checker is used: which options are chosen, which results appear, and which outside links get used. This decides which countries we research next.
    • Nothing is stored on your device and nothing identifies you. The privacy page explains exactly what is counted.

  13. 2026-08-16

    • Added a question explaining that electricals need separate WEEE registration as well as packaging registration, and that neither covers the other.
    • Recorded the UK WEEE small producer route: under 5 tonnes a year, registered directly with the regulator.
    • Recorded that UK WEEE registration does not cover sales into the EU, where you register per country.
    • Flagged as unconfirmed whether EU WEEE applies to a Northern Ireland producer alongside the UK rules.
    • Added a United Kingdom entry to the country directory, covering who you register with, the turnover and tonnage bands, and what large producers pay.
    • Recorded that UK registration does not cover the EU, and EU registration does not cover the UK.
    • Rewrote the "register with" line for each country in plainer English.
    • Checked all 30 source links against the live pages. Replaced four that were wrong or out of date: the Windsor Framework page, the NIEA producer responsibility page, and the Etsy and Amazon EPR help pages.
    • Pointed the Germany entry at the LUCID portal where you actually register, rather than the information site about it.
    • Recorded that UK Packaging PRO, appointed by PackUK in March 2026, runs day-to-day producer services from 1 April 2026. PackUK stays the scheme administrator.
    • Started counting page views with cookieless analytics. No cookies, and no tracking of individual visitors. The privacy page has the details.

  14. 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.