Germany proposes lighter PPWR EPR rules for smaller cross-border sellers
Germany has proposed removing the authorised-representative requirement for sellers placing under 10 tonnes of packaging on the market each year and pausing registration in the new PPWR system until mid-2028. No EU change has been adopted.
- Who this affects
- UK and other non-EU sellers placing packaged goods directly on EU markets, particularly smaller cross-border businesses.
- Seller action
- No immediate general seller change
No change today. Continue following current national EPR and PPWR requirements while the proposal is considered at EU level.
- Effective dates / current position
- Proposed; no effective date agreed
- Last reviewed
- 8 Sept 2026 — an editorial source check, separate from automatic timing.
- Official source
- Open the primary source ↗
What has Germany proposed?
Germany’s Federal Environment Ministry says the German Government prepared a specific amendment to the EU Packaging and Packaging Waste Regulation, known as the PPWR. It presented the proposal in Brussels on 7 September 2026 during preparations for the EU Environment Omnibus.
The proposal would:
- Remove the requirement to appoint an authorised representative for sellers placing less than 10 tonnes of packaging on the market each year.
- Suspend registration in the new PPWR system until around mid-2028, when Germany expects a central EU producer-registration system to become available.
What is not changing?
This is an official German proposal, not an agreed amendment to EU law. The German ministry says the PPWR itself would need to be changed and that Germany is seeking support from other EU Member States.
There is therefore no new small-seller exemption today and no agreed effective date. Businesses should not cancel authorised-representative arrangements, registrations or reporting on the strength of this proposal.
Why UK sellers should watch it
A business established outside the EU that sells packaged products directly to end users in EU countries can have producer and Extended Producer Responsibility obligations. These requirements are still administered through national systems, so the practical position can differ between destination countries.
If the German proposal becomes EU law, it could reduce some authorised-representative costs for smaller cross-border sellers and delay the new PPWR registration process. The official announcement does not set out all the detail needed to decide how the proposed 10-tonne test would apply to an individual seller, so businesses should not assume they qualify.
What to do now
- Continue following the current packaging and EPR rules in every EU country where you place packaged goods on the market.
- Keep existing registrations, representatives, reporting and compliance records in place where required.
- Watch for an EU-level legislative proposal and final wording before changing your compliance arrangements.
- Check any future threshold rules carefully, including how packaging quantities are measured and which markets are included.
Official source
German Federal Environment Ministry: PPWR proposal, 8 September 2026 (German) ↗