Yes, since 12 August 2026. Article 45 of Regulation (EU) 2025/40 requires you to appoint an authorised representative for extended producer responsibility in each Member State where you sell without being established there. Article 44 adds registration in those countries' national registers of producers, with existing registers applying until the PPWR registers are in place. Selling from France to Germany, Spain and Italy therefore requires 3 separate appointments and 3 separate registrations. A Commission proposal, the environmental omnibus, would suspend this obligation until 2035 for producers established in the Union, but it has not been adopted and the Council broke off negotiations on this part on 24 June 2026.
Read the source article: PPWR timeline: key dates and packaging deadlines explained