Is the PPWR authorised representative rule suspended until 2035?
A headline has been going round that the PPWR representative requirement is suspended until 2035. There is something real behind it — but it's a proposal, it hasn't been adopted, and it was never written to cover sellers outside the EU. Here is the difference between what applies today and what is still being argued about in Brussels.
From 12 August 2026, Article 45 of the Packaging and Packaging Waste Regulation applies. If you place packaging on the German market and aren't established here, you must appoint an authorised representative in Germany by written mandate. The regulation applies directly, without any national implementation step. If you want the whole picture rather than this one question, start with the overview for small shops selling into Germany.
A suspension until 1 January 2035 has been proposed, not decided. In December 2025 the Commission published COM(2025) 982 as part of the Environmental Omnibus package. Article 2 of it would suspend Article 45(3) until 2035.
Council negotiations on that proposal were discontinued in June 2026. The file sits with the European Parliament's environment committee, with a vote expected around October 2026. Until something is adopted and published, it changes nothing.
The part most summaries leave out
The proposed suspension was drafted for producers established in the Union who sell across a border into another member state. A Dutch shop selling into Belgium, a French one selling into Germany.
Producers established outside the EU were never in scope. The Commission's own text keeps that door firmly open: member states may either require third-country producers to appoint a representative, or ensure traceability and enforcement by other means. So even in the version most favourable to sellers, a shop in the United States, Canada, Turkey or China is unaffected.
| Where your business is registered | What the proposal would mean for you |
|---|---|
| United States, Canada, Australia, Turkey, China, India — anywhere outside the EU | Nothing. Not covered by the proposal. |
| France, Italy, Spain, Poland, Netherlands, Austria — inside the EU | Possibly relevant, if it is adopted. |
| Germany | You don't need a representative anyway. |
Where the headline comes from. "Commission proposes suspension until 2035" is accurate. It becomes wrong in the shortening: the qualifier about EU-established producers falls away, and "proposes" turns into "has". If a summary tells you the requirement is postponed, check whether it mentions who it applies to.
Why it was proposed at all
Because the criticism is fair. As the rules stand, there is no EU-wide desk: a representative is needed in each member state where you're not established. Sell into eight countries and that's eight appointments, eight contracts, eight annual fees. The Commission's own reasoning names the administrative burden of appointing a representative in up to 26 member states as a barrier.
That's a real problem, and it hits small sellers hardest — a company with a compliance department absorbs it; a two-person ceramics studio doesn't. Whether suspending the obligation for a decade is the right answer is exactly what's being argued about. Recycling associations and industry groups have objected publicly, on the grounds that without a local point of contact, the obligations become unenforceable against distance sellers.
So what should you do while it's unresolved?
The unhelpful truth is that waiting isn't a neutral option. The obligation applies now; a proposal that might change it in October doesn't suspend it in August. If a marketplace checks your listings next week, the answer "there's a proposal in Parliament" won't restore them.
The more useful framing is that the representative question is only one of four, and the other three don't move at all:
- Are you registered? Registration in the German packaging register applies regardless of any of this, and has for years. Free, ten minutes, and personal to you — the screens, step by step, in English.
- Is your packaging licensed? You have to be in a contract with a recycling system before your packaging reaches a German consumer. No proposal touches this — what that costs at a small scale.
- Are your quantities reported? By weight and material, to the recycling system and to the register, matching, twice a year. How the reporting works.
- Who does that for you? This is the only one under discussion — whether someone local must do it, or whether you may do it from abroad.
Even in the suspension scenario, voluntary appointment stays possible. The proposal removes an obligation; it doesn't ban the arrangement. If having someone in Germany handle the registrations, contracts and deadlines is useful to you, that stays available whichever way the vote goes.
Whether it's worth it at your size
Here's the part most providers won't tell you. Below roughly a hundred parcels a year, the maths is unkind: the fixed costs — the annual fee, the recycling system's minimum charge — get spread over very few orders. Sixty parcels a year works out at around €1.50 per parcel. Eight hundred works out at around 26 cents.
So if Germany is a handful of orders a year for you, the honest question isn't which provider to choose. It's whether that market earns its paperwork at all. Turning Germany off in your shipping settings is a legitimate answer, and for some shops it's the right one. The calculator will tell you your own figure before you commit to anything.
What I actually do
You sell to Germany. I handle the German packaging side of it. In practice that means I choose and hold the contract with a recycling system, turn your parcel counts into the kilograms the law asks for, file the reports in both places, watch the two annual deadlines and deal with the register authority when they have questions.
What you do is confirm a number twice a year. That's it — no German required, no deadlines in your calendar, no compliance department.
Sources, so you can check rather than take my word for it
- Current law: Regulation (EU) 2025/40 (PPWR), Article 45. In force 11 February 2025, applies from 12 August 2026.
- The proposal: COM(2025) 982 of 10 December 2025, Environmental Omnibus package. Article 2 would suspend Article 45(3) until 1 January 2035. Not adopted.
- Status: Council negotiations discontinued 24 June 2026; the file remains with the European Parliament's environment committee, vote expected around October 2026.
- German register: Stiftung Zentrale Stelle Verpackungsregister, verpackungsregister.org.
If the position changes, this page changes with it — the date at the top tells you when it was last checked.
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 12 August 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.