Yes, if the business is the producer. Since 12 August 2026, Article 44 of the PPWR has required each producer to register in every Member State where it first makes packaging available, before selling there. There is no single EU-wide register, because each Member State keeps its own.
Registration is separate from showing that the packaging itself complies. The manufacturer shows that with the EU declaration of conformity and the technical documentation, which it keeps and shows to the authorities on request.
Who registers depends on who first sells the packaging in each EU country:
- An Indian exporter that sells to an EU importer or distributor that resells the goods is normally not the producer. The EU business that first sells the packaging in its country registers there. An exporter that sells directly to end users in a Member State, whether consumers or businesses using the goods, is the producer there and registers in that country.
- An EU-based producer that sells directly to end users in another EU country must also appoint an EPR authorised representative there, under Article 45(3) of the PPWR. For a seller based outside the EU, the same article lets each Member State decide, so the national rule applies. A Commission proposal of 10 December 2025 would pause this duty until 2035. The Council stopped work on it on 22 April 2026, so the rule applies as written.
Article 44 gives each Member State 18 months after the Commission’s format act to set up its register under the PPWR. That act was due by 12 February 2026 and was still a draft on 26 September 2026, so producers register with the existing national registers for now.
The EU PPWR Guide sets out the requirements in full, and the PPWR discovery process looks at a specific business’s packaging and sales routes.