Questions
Common questions
Mostly correcting bad information. Several widely repeated claims are wrong, and a few are expensive to get wrong.
Reviewed 2026-09-03
I sell electricals. Is packaging the only thing I have to register for?
Registering for one producer scheme covers the others.
No. The product and its packaging are two separate schemes, with separate registrations and fees.
Am I exempt from EU packaging EPR as a micro business?
Micro-enterprises are exempt from the new EU packaging rules.
No. There is no general micro exemption from EPR registration.
Do I need new packaging labels from August 2026?
The new EU packaging labels are required from 12 August 2026.
No. Harmonised EU labelling starts 12 August 2028.
I'm in Northern Ireland. Which packaging rules apply?
PPWR product rules apply. For EPR you stay in UK pEPR. NI to Republic of Ireland is a sale into the EU.
If I turn off EU countries in my shop, am I sorted?
Switching off EU shipping makes the problem go away entirely.
It stops new sales. It does not settle obligations from sales already made.
Do I have to register in every EU country I ship to?
Yes. There is no single EU-wide packaging registration.
What's the difference between PPWR, EPR and GPSR?
Three separate regimes with three separate deadlines.
What is an authorised representative, and do I need one?
Someone established in a country who takes on your EPR duties there. Needed in any member state where you are not established.
What is a packaging compliance scheme?
A company you pay to take on your packaging recycling duties. The UK says compliance scheme; the EU says producer responsibility organisation, or PRO. Same job.
What is Defra EPR?
Defra EPR means every business now pays packaging fees.
Defra EPR is the UK's packaging recycling rules — extended producer responsibility. Under £1 million turnover or under 25 tonnes of packaging a year, you are out of scope. Above that, you register and report on GOV.UK.
Do you need a packaging licence?
You cannot sell into Europe without a packaging licence.
There is no such licence. What sellers call a packaging licence is really two things: an entry in a country's packaging register, and a paid contract with a recycling scheme. Which ones you need depends on where you sell.
Which EU countries make you appoint a local representative?
Only sellers outside the EU need local representatives.
More than you'd guess — and EU-based sellers need them too. Six countries required one for every foreign seller before the EU rules did, five let you join the national scheme directly instead, and the EU rules now expect one everywhere for posted orders.
Do you still pay Hungary's product fee?
Selling into Hungary means paying the environmental product fee on your packaging.
Not for packaging — that ended in January 2025. Packaging now runs through the EPR fee instead, paid to MOHU, the state concession company. Guides describing the product fee, or offsetting one fee against the other, are out of date.
Will the 12 August 2026 date be pushed back?
Not as things stand. The main suspension track was discontinued in June 2026.
What does EU packaging EPR cost a small seller?
Recycling fees are small at micro volumes. The per-country fixed costs are what hurt.
Is there a 50 tonne threshold that exempts me?
There is a 50-tonne EU-wide threshold below which small sellers are exempt.
Only in the Netherlands. It is not an EU-wide threshold.
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