Is the PPWR representative rule being suspended? Latest update: November 2026
The European Parliament and the Council have both now voted for an exemption from the representative obligation — and they voted for two different ones. Neither is law. Meanwhile a German deadline falls on 12 November, and it has nothing to do with either of them. Here is what applies today, what is still being argued about, and what to do in the next ten days.
Article 45 of the Packaging and Packaging Waste Regulation has applied since 12 August 2026. If you place packaging on the German market and are not established here, you must appoint an authorised representative in Germany by written mandate. Nothing that happened in October changed that.
The European Commission has asked member states to enforce this particular obligation pragmatically and to hold off on penalties while the amendment is being negotiated. That is a request about enforcement. It is not a change in the law, and it is not something you can rely on in a dispute with a marketplace.
Two exemptions are on the table, and they do not match. On 20 October 2026 the European Parliament adopted its position by 616 votes to 9, with 39 abstentions: micro and small businesses established in the EU would be exempt until 1 January 2035.
One day later the Council adopted a different position. Under it, an EU-established business would be exempt in a given country if it places less than one tonne of packaging a year on that country's market, and the suspension would end in 2032.
Parliament and Council now have to agree on a single text. Until that text is adopted and published, neither version applies to anyone.
The deadline on 12 November is a separate matter
Section 68(2) of the German Packaging Law Implementation Act gives companies that were already registered in LUCID before 12 August 2026 a transition period. Any changes their registration needs under the new rules have to be made by 12 November 2026.
For a seller outside Germany without a branch here, the change that is usually needed is exactly the one being argued about in Brussels: appointing an authorised representative. The EU discussion does not pause the German deadline.
No, LUCID accounts are not deleted on 12 November
This claim is going round and it is wrong. The law does not provide for a blanket deletion of every registration without a representative on that date.
What the deadline does mean is that from 13 November a registration that still lacks required information may no longer meet the requirements. That matters for placing packaged goods on the German market lawfully, and it is the kind of thing a marketplace can act on without warning you first. Take the date seriously; just do not panic about the wrong thing.
What to do in the next ten days
- Check whether the obligation applies to you at allYou need a representative if you are established outside Germany, have no branch here, and send packaged goods directly to customers in Germany. Supplying only a German wholesaler, or selling through a platform that places the goods itself, is a different case and worth checking rather than assuming.
- Open your LUCID account and read your own dataCompany name exactly as it appears in your commercial or trade register, the registered address, your national company or tax number, and every brand name you sell under in Germany.
- If a representative is required, check the appointment is actually completeThis is where it goes wrong most often. Entering a number is not an appointment. The representative has to accept it on their side. If nobody has confirmed it, you are not appointed, however complete the form looked.
- Check the packaging itself is licensed and the quantities are rightThe representative files the reports. The quantities still have to be yours, and they still have to be correct.
What does not go away, even if an exemption passes
The proposals concern one thing: the obligation to appoint a representative. They do not touch the packaging obligations underneath it.
Registration in LUCID stays. Participation in a dual system for system-participation packaging stays. Quantity reports stay. If you ship in a cardboard box with paper padding, a plastic bag and tape, someone still has to work out who is responsible for those materials and report them.
An exemption from appointing a representative would remove a formality. It would not make packaging licensing free.
Should you cancel what you already have?
An existing contract does not end because a parliament voted for a future exemption. Whether you can leave it early depends on the final legislation and on your own contract terms, and neither of those is settled today.
There is also a practical question underneath the legal one. Even without a statutory appointment, somebody has to calculate the materials, keep the system participation current, file the quantity reports and watch the deadlines. Some sellers would rather do that themselves. Others would rather sell their products. Both are reasonable answers; they are just different answers.
What happens next in Brussels
Parliament and Council negotiate a joint text. Only once it is adopted, published and in force will it be possible to say who is exempt and from when. The two positions differ on both points — who qualifies, and how long it lasts — so the outcome is genuinely open.
This page is updated when something actually changes, not when something is announced. The date at the top tells you when it was last checked.
Official sources
Work out where you stand
Three questions tell you whether the obligation applies to you, and the calculator tells you what it would cost. If the answer is that Germany isn't worth it at your volume, I'll say so.
Check in thirty secondsGeneral information, not legal advice, current as of 2 November 2026. Legislative files move; where this matters to a decision you're making, check the current status at eur-lex.europa.eu or ask a lawyer.