Last updated: 20th August 2026
Since 12th August 2026, the European PPWR (EU 2025/40) on packaging and packaging waste has been applicable.
It introduces, among other things, obligations relating to Extended Producer Responsibility (EPR) for businesses placing packaging or packaged products on the market.
Who is concerned?
A merchant may be considered a “producer” under the rules when they make packaging or packaged products available for the first time on the market of a Member State.
- the import of packaged products;
- packaging added by the merchant, such as boxes, envelopes or filling material;
- distance sales to customers located in other EU Member States.
Sales in Luxembourg
If you only deliver within Luxembourg, you should verify your EPR obligations in Luxembourg.
This may include joining Valorlux and declaring the packaging that you place on the Luxembourg market.
If the relevant packaging is already properly covered in Luxembourg by your supplier, it should generally not have to be declared a second time.
Sales to other EU countries
If you deliver to other Member States, the applicable obligations must be checked country by country.
- register with a national register;
- obtain an EPR registration number;
- submit declarations and pay contributions;
- retain evidence of compliance;
- appoint an authorised EPR representative in the country concerned.
This does not mean that you automatically have to register in all 27 Member States. Only the countries in which you actually place products or packaging on the market are relevant.
To identify the competent organisations and national registers in the different EU Member States, you may consult the following resources:
1. Approved Producer Responsibility Organisations by EU Member State
- Household and commercial packaging – EPR schemes by Member State: https://www.europen-packaging.eu/publication/overview-of-member-states-epr-schemes/
- Waste Electrical and Electronic Equipment (WEEE) & Batteries: https://weee-forum.org/members/
2. National registers of EU Member States
- European National Registers for Packaging (EUNR) – national registers and competent authorities: https://www.eunr.org/national-members
Authorised representative requirement: situation still evolving
The PPWR currently provides, in certain cross-border sales situations, for the appointment of an EPR authorised representative in the Member State concerned.
The European Commission has, however, proposed to suspend this requirement until 1 January 2035.
This proposal has not yet been adopted, so the rules currently in force continue to apply.
You can follow the development here: COM(2025) 982 – EUR-Lex
What should you do now?
If you only sell within Luxembourg, check your EPR obligations in Luxembourg.
If you also deliver abroad, identify your delivery countries and verify the applicable EPR obligations in each of them.
If you wish to temporarily restrict deliveries to Luxembourg while clarifying your situation, please contact the Letzshop team.
This page will be updated regularly as the regulation evolves and as new information becomes available from European and national authorities.
