Do Small Sellers Still Need an EU Packaging Representative? What the Committee Vote Means

The European Parliament's environment committee has voted 74 to 0, with four abstentions, to pause a packaging rule that requires sellers to appoint an "authorised representative" in each EU country they sell into without being established there, but only for small and medium-sized businesses established in the EU. A second vote covering textiles, footwear, electronics and single-use plastics passed 72 to 0 with five abstentions, according to a 6 October report by 2eu.brussels.

If you sell packaged goods across EU borders, this matters. Under the Packaging and Packaging Waste Regulation (PPWR), the representative rule has applied since 12 August 2026, and for a small webshop shipping to several countries it can mean several contracts and several sets of fees. But this is a committee position, not law. Here's what was voted, who it would and wouldn't help, what each side argues, and what to do while it's decided.

What the committee actually voted for

The rule in question is part of extended producer responsibility, or EPR: the principle that companies placing products on the market keep some responsibility for them after the sale, including when they become waste. One administrative piece of that is appointing an authorised representative in member states where you sell but aren't established.

The European Commission had proposed suspending the representative requirement generally until 2035 as part of its Environmental Omnibus simplification package. The Committee on the Environment, Climate and Food Safety (ENVI) narrowed that. According to 2eu.brussels:

• The pause would apply only to SMEs established in the EU, defined here as companies with fewer than 250 employees and annual turnover below €50 million or a balance-sheet total below €43 million.
• Companies established outside the EU would still need authorised representatives.
• EPR itself stays. Producers keep their obligations; only the extra representative requirement would be suspended.
• The pause would end automatically once comprehensive EU circularity rules take effect. The Commission is expected to propose a circular economy act later in 2026.

MEPs also called for information already given to one national authority to be pooled, for national digital systems to work together and for more consistent reporting. Rapporteur Ingeborg ter Laak presented the change as an interim fix so smaller firms don't wait years for a permanent one.

Committee position, not law

This is the most important point for sellers. The committee votes do not exempt anyone yet. Both positions still need confirmation by Parliament's plenary, expected during the 19 to 22 October session. If confirmed, Parliament can then negotiate with the Council, the member states' side. The legal situation changes only once that process is complete and the final act enters into force.

Until then, the PPWR rule applies as written.

What the rule requires today

PPWR guides from two compliance firms, Eprrepresentative and Clearo Systems, describe Article 45 the same way. Since 12 August 2026, a producer that makes packaged products available directly to end users in a member state where it isn't established must appoint an authorised representative there by written mandate. Nationality doesn't matter, so a German shop selling to French consumers is in the same position in France as a company from outside the EU.

There's no single window: a seller shipping to France, Germany and Italy needs three separate representatives, one per country, each working within that country's national scheme. Clearo Systems notes that in Germany the representative's details go into the LUCID packaging register before products are first made available, and that marketplaces ask sellers for the resulting registration number. Both firms sell compliance services, so read their guides as practical explainers, not legal advice.

Who would benefit, and who wouldn't

Under ENVI's version:

• A small Dutch, German or Spanish webshop selling directly to consumers in other EU countries would get relief, as long as it meets the SME definition.
• A large EU company would not.
• Sellers established outside the EU, including those in the UK, the US, Canada and Australia, would still need representatives where they're required. For UK sellers, that's one more post-Brexit difference with EU competitors.

What each side argues

The debate is genuinely split, and Packaging Insights gathered several views.

EuroCommerce, which represents European retailers, called the representative requirement one of many practical hurdles in implementing the PPWR. Its adviser Nick Dornheim said businesses still face uncertainty about how other provisions will be applied, and the group wants a 12-month grace period for outstanding implementation problems.

Thuiswinkel.org, the Dutch e-commerce association, argues the rule is disproportionate for small volumes. CEO Marlene ten Ham said a business selling limited quantities into several countries "may need to appoint and manage multiple authorized representatives, each with separate contracts, reporting obligations, and costs," and warned some smaller firms may simply stop selling cross-border. Her group favours exemptions for micro and small businesses, a single EU-wide representative or mutual recognition, and a digital one-stop shop. She also asked enforcement authorities to focus on guidance rather than sanctions while the rule is under review.

The European National Registers for Packaging (EUNR) sees it differently. President Gunda Rachut called the debate "very one-sided" and argued it gives relief to online sellers outside the EU, where enforcement isn't possible. She warned that when sellers don't pay for packaging waste, someone else does: "those who comply with the law end up subsidizing those who do not."

ShopperCove takes no side. Both concerns, cross-border red tape for small firms and free-riding by non-compliant sellers, are real.

What to do now

1. Keep complying. The current rule applies until the law actually changes. Don't drop representatives you've already appointed.
2. Map where you sell directly to consumers. List every EU country you ship to and whether you have an establishment there.
3. Keep your paperwork in one place: mandates, registration numbers and the details marketplaces ask for.
4. Watch the plenary on 19 to 22 October and the Council negotiations that follow. The final text could still differ from ENVI's.
5. Budget as if the rule stays. If you're an EU SME, treat any pause as a saving that may arrive later, not now. If you're outside the EU, plan for representatives regardless.

If you also sell on Amazon in other EU countries, our post on Listimo's seller toolbox and EU product-safety checks covers a related compliance area, the General Product Safety Regulation.

Disclosure: some links are affiliate links; ShopperCove may earn a commission at no extra cost to you.

If cross-border paperwork is under control and you're expanding into other EU Amazon stores, local-language listings are a separate job. Listimo's offer page says it writes listings for 12 Amazon marketplaces directly in the target language rather than translating, with measured search-term data for amazon.de, .fr, .it, .es and .nl among others, and turns a single product photo into listing images and copy. To be clear, Listimo doesn't handle packaging registration, EPR or authorised representatives; its own page says issues such as a missing packaging registration can only be settled between you and Amazon. ShopperCove did not test Listimo for this article. Listimo link: Open link (affiliate link)

Tools that help

• Listimo, AI Amazon listing builder for local-language listings, images and A+ content (not a packaging or EPR compliance tool). Its offer page lists a seller pack of 1,800 credits for $229, about 10 complete listings, with refunds under ClickBank's 60-day return policy. Listimo link: Open link

How this was made: facts were gathered on 8 Oct 2026 (IST) from 2eu.brussels' and Packaging Insights' 6 October reports on the ENVI votes and from Eprrepresentative's and Clearo Systems' PPWR guides, then written up with AI help and checked line by line against those sources. Parliament's own pages blocked automated access, so they're not listed. This is general information, not legal advice. ShopperCove did not test Listimo for this article.

Sources

• 012eu.brussels/index.php/en/news/meps-want-simpler-waste-rules-for-eu-smes-while-keeping-authorised-representatives-for-non-eu-companies
• 02packaginginsights.com/news/eu-parliament-committee-backs-epr-reprieve-for-smes-packaging.html
• 03eprrepresentative.com/guides/ppwr-article-45
• 04clearosystems.com/blog/ppwr-authorised-representative-every-export-country
• 05listimo.ai/en/offer-usd.html

Related

• 01shoppercove.com/blog/listimo-amazon-listing-ai-vs-site-seo-2026
• 02shoppercove.com/blog/amazon-stores-layoffs-selling-partner-services-sellers-october-2026
• 03shoppercove.com/blog/prime-big-deal-days-2026-what-sellers-do-next