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Packaging EPR in Luxembourg
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Checked 2026-09-03 · 4 sources · 4 open questions
- Register
- registration with the Administration de l’environnement (AEV) — filed BY the approved organism, not by you
- Authority
- Administration de l’environnement (AEV)
- Law
- Loi du 9 juin 2022 relative aux emballages et aux déchets d’emballages, art. 8you cannot comply alone: a packaging responsible party must contractually charge an APPROVED ORGANISM with its obligations, and Valorlux is currently the only approved organism for packaging. Valorlux then registers your company with the AEV. Three duties: take-back, information, and a prevention plan with a public annual report.
- Who registers
- The approved organism registers you
- Reporting
- Annually, by 28 FebruaryLATE FILING IS PRICED: one per cent of your last declaration for every month late. Industrial packaging is declared between the start of January and the end of February for the previous year, in four materials — paper/board, WOOD, metal and plastic — and covers both your finished products and the packaging of imported goods where the supplier is not itself a Valorlux member. Industrial packaging includes tertiary and secondary, plus primary packaging for products over 10 kg or litres.
- Also required
- An approved organism — you cannot comply alone
- Household packaging schemes
- Valorlux
- Industrial packaging schemes
- Valorlux
What is not settled
- Law The authority contradicts itself\ud83d\udd34 THE AUTHORITY CONTRADICTS ITSELF. Our row cites the law of 9 June 2022 on packaging and packaging waste. EUNR cites the consolidated law of 21 March 2017.
- Threshold Sources disagreeOne commercial guide states there is no volume threshold and registration is required from the first unit. No threshold is mentioned on the Guichet.lu or Valorlux pages either way.
- Authorised representative Not established at sourceAn authorised representative established in Luxembourg is described as a PPWR requirement for foreign producers by a commercial guide, not from a Luxembourg instrument. In practice the approved organism performs the registration.
- Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.
The same in every EU country
- PPWR Art. 44 — registration is a precondition for placing packaging on that market
- PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
- set nationally, Art. 68; national rules due by 12 Feb 2027
- Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029
Sources
Countries with the same answer
We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.
Tarafex
The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.
See what Tarafex does →
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