PPWR — EU Regulation 2025/40: harmonised rules, national registration

The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, in force since February 2025 and applying in the main from August 2026 — replaces the old packaging directive. Because it is a regulation, the requirements are the same in every member state. What it does not do is centralise registration or payment, and that is the point most cross-border sellers get wrong.

What PPWR harmonises

  • Design requirements: recyclability criteria, recycled content in plastic packaging, limits on excessive empty space.
  • Labelling: harmonised material and sorting marking across the single market.
  • Definitions and calculation rules, so the same packaging is classified the same way everywhere.
  • Reuse and refill obligations for certain sectors and formats.
  • Restrictions on certain single-use formats.

What stays national

  • Producer registration: one registration per member state where you place packaging on the market.
  • The producer responsibility organisation contract, concluded with a scheme licensed in that country.
  • The fee level and its calculation basis, set nationally — in Romania through the Environmental Fund.
  • Reporting frequency, format and deadlines. Romania is monthly, by the 25th.
  • Enforcement: the national authority inspects and fines.

An EU webshop selling into Romania

QuestionYour home countryRomania
Who is the producer?You, for goods placed on your home marketYou, for goods shipped to Romanian customers
RegistrationYour existing national registrationA separate Romanian registration
Local presenceYour own companyAn authorised representative established in Romania
FeesTo your national systemTo the Environmental Fund Administration, via a PRO contract
ReportingUnder your national rulesMonthly, by the 25th of the following month

The same logic applies in reverse for a Romanian seller shipping abroad, and for every other pair of EU markets.

The distance-selling point that matters

PPWR makes explicit what enforcement had already been moving towards: a seller who ships directly to consumers in another member state is a producer in that member state and needs a representative established there. Marketplaces are increasingly required to verify that their sellers hold valid national registrations, which is why registration numbers are now being requested at onboarding.

For a seller, the practical consequence is simple. Selling into six markets means six registrations, six local contacts and six reporting calendars — not one European filing.

What to do before enforcement reaches you

  1. 1
    Split your volumes by destination country

    Shipment data by destination is the basis of every national declaration.

  2. 2
    Build a packaging weight table per SKU

    One table serves every market; only the volumes differ.

  3. 3
    Register where you actually sell

    Starting with the markets where you have the highest volumes or a marketplace request pending.

  4. 4
    Regularise past periods

    Voluntary correction costs far less than being found during an inspection.

  5. 5
    Review packaging design

    Recyclability, recycled content and empty-space rules will affect what you may ship, not just what you pay.

Our scope

We cover Romania: registration, authorised representation, PRO contract and monthly filings. We are happy to say plainly which parts of your European obligations we do not cover, so you can arrange them elsewhere.

Frequently asked questions

Does PPWR mean one EU-wide registration?
No. It harmonises requirements and reporting content, but registration, the local representative and payment remain per member state.
When does it apply?
The regulation entered into force in February 2025 and its main body of obligations applies from August 2026, with several requirements phased in later. National EPR duties, including Romania's, apply already and independently.
Do we need to change our packaging now?
Design requirements phase in over several years, so this is planning work rather than an emergency. Registration and reporting are the immediate items.
Where can we read the regulation?
Regulation (EU) 2025/40 is published in full on EUR-Lex, in every official EU language including English, Hungarian and Romanian.

Related

Get your Romanian registration in order before it is asked for