A company in New York, Shenzhen or Sydney that ships a packaged product to a customer in the EU has the same packaging obligations as a company in Berlin. The rule attaches to the packaging that reaches the market, not to the address of the company that filled it. Your industry does not change it either: food, cosmetics, electronics, machinery, furniture, chemicals, e-commerce — if it arrives in a box, it is in scope.
Regulation (EU) 2025/40 applies from that date. Registration in the national packaging register is a precondition for putting packaging on that market at all — not a formality to catch up on afterwards.
There is a widely repeated headline that the representative requirement was pushed to 2035. Read it carefully before relying on it. The December 2025 Omnibus proposal would have suspended the obligation for producers established in the Union selling across a border. It never covered producers established outside the EU. And in June 2026 the Council decided not to proceed with the suspension at all, a large majority of member states opposing it. Work from the law in force.
Where you place packaging on a market in which your business is not established, that member state can require you to appoint an authorised representative there. It is an appointment per country, not one appointment for the Union: Germany and France are effectively universal for a seller from outside, and the trigger and the timing differ elsewhere. Twenty-seven registers, twenty-seven sets of rules.
It is also a waste role, not a product-safety one. A company that already holds an authorised representative for CE marking or REACH cannot assume the same entity covers this. It is a separate written mandate.
Tarafex is not an authorised representative. It does not register anyone in any country, it is not a compliance scheme, and it does not decide whether your packaging complies. Anyone who tells you a piece of software can do those things is selling you something else.
What it does is the part nobody else will do for you. A representative cannot file anything without numbers: how many kilograms, of which material, into which country, business or consumer, single-use or returnable. Those numbers come out of your own shipments, and they are the reason most of this becomes a scramble in the last week before a deadline.
Start with the countries. The obligation, the register and the representative rule are national, and in a few member states the register does not exist yet in the form the regulation assumes. Our table gives each of the 27 — the register, the threshold, whether a foreign producer needs a representative — dated, with the source on every line and the open questions named rather than smoothed over.
Packaging EPR by EU country · Does the obligation apply to me?
Then hold your packaging data in one place, so that whoever asks — a customer, a representative, an authority — gets the same answer without you rebuilding it. That is the whole of what Tarafex does.
If your packaged product reaches an EU market, yes. The regulation follows the packaging, not the company's address. Where you sell into a member state without being established there, that state can require an authorised representative before the packaging may be placed on its market at all.
That proposal covered producers established in the Union selling across an internal border, not producers outside it. In June 2026 the Council decided not to proceed with it, opposed by a large majority of member states. Nothing about it removed the obligation for a seller from outside the EU.
That is a product-safety role. This is a waste role, under a different article and usually a different provider, and it needs its own written mandate. Do not assume one covers the other.
No. Tarafex does not register anyone anywhere, is not a compliance scheme, and does not decide whether packaging complies. It holds the packaging data your representative needs in order to file, and produces the data sheet and the declaration from that same record.
The appointment is per member state where you place packaging and are not established. One provider may act for you in several countries, but it is not a single EU-wide appointment.