Sending an online order from Luxembourg to a customer in France can involve more than choosing a box, printing a label and paying the courier. The retailer may have to register with France’s packaging-waste system, report what it sends and contribute towards collecting and recycling the material.
A sale to Germany can trigger the same responsibilities under a different national system. Since 12 August 2026, businesses selling packaged goods directly to customers elsewhere in the EU must also appoint a representative in each destination country where they are not established.
For Stikka Atelier, which sends between 400 and 500 orders a month, withdrawal is not an option. “I’m not going to stop delivering,” said its founder and manager, 
Their contrasting responses illustrate a little-discussed obstacle for Luxembourg’s online retailers. The obligation to finance packaging waste in each destination is not new, but a mandatory local representative has added another layer of cost and administration to already fragmented national systems.
One parcel, one national system
Extended producer responsibility, or EPR, follows the principle that businesses placing packaging on a market should contribute towards dealing with the resulting waste. For a Luxembourg retailer selling directly to a customer abroad, the relevant market is generally the customer’s country.
“If a producer sells packaging directly to end users in a member state, it must fulfil EPR obligations in that member state,” the European Commission told Paperjam. “This was also the case prior to the application of the PPWR.”
Luxembourg’s Environment Administration, or AEV, said the retailer is treated as a producer in the destination country. It must therefore “register, join an approved organisation, declare the quantities of packaging placed on the market and pay the corresponding contributions”.
These responsibilities derive from EU rules but are carried out through national registers and waste-management schemes. A retailer serving several countries may consequently have to identify and follow a different procedure in each, even if it sends only a few parcels to some destinations.
The EU’s Packaging and Packaging Waste Regulation, or PPWR, now adds the requirement for an authorised EPR representative in each country where the seller is not established. Some member states had already imposed such a requirement under their national rules, but Luxembourg had not.
Two sellers, two calculations
France and Germany are Stikka’s largest destinations, although the business sends products more widely within Europe and beyond. It will complete the procedures once it establishes precisely what each country requires.
The expense could leave some markets temporarily unprofitable. “At the beginning, perhaps we will take it out of our margin,” Caiano said. “But if we want to remain there and not die, we still have to cover our costs. In the end, it is always the final customer who pays.”
Stikka could vary prices by destination or offset weaker returns in one country against stronger sales elsewhere. “It will take us more time,” Caiano said. “Even if we are not profitable immediately in one country, we will balance it against the others where we are more profitable.”
Alina Beloussova has made the opposite calculation. Oddhaus only began shipping furniture abroad a few months ago, mainly to France and occasionally Belgium. “I’m not doing anything about it,” she said. “I’m still shipping, and I’m not planning to do any of it.”
The cost of another market
Neither business had obtained a quotation from an authorised representative, making the cumulative expense of selling into several countries impossible to establish. Paperjam could not independently substantiate an unofficial figure of €300 per country encountered by Beloussova.
Valorlux’s charges provide a Luxembourg comparison rather than an estimate of foreign costs. The country’s approved household-packaging scheme applies a minimum annual contribution of €50, while a new member pays a one-off joining fee equal to 25% of its first annual contribution, with a minimum of €12.50. The organisation cannot handle a Luxembourg seller’s responsibilities abroad: “The principle is that the producer must declare its packaging in the country in which it has placed it on the market,” it told Paperjam.
Businesses placing less than 10 tonnes of packaging on a member state’s market each year benefit from reduced reporting requirements, but the threshold does not by itself exempt them from registration, contributions or the representative requirement.
“Even when only limited sales volumes are involved, these fixed costs and administrative procedures can become disproportionate,” Carlo Thelen, director general of the Chamber of Commerce, said. “An identical administrative obligation or fixed cost weighs proportionally much more heavily on a very small business than on a large company.”
An extra layer under dispute
The representative can normally handle or coordinate registration, membership of the relevant packaging scheme, declarations and contributions on the seller’s behalf. It does not replace the approved producer-responsibility organisation, which collects contributions and arranges the management of packaging waste.
That additional requirement may yet be suspended. In December 2025, eight months before it became applicable, the Commission proposed suspending it until 1 January 2035 after concluding that it could impose an unnecessary burden on businesses operating across the EU.
The Commission cannot make that change alone. It normally proposes EU legislation, but the directly elected European Parliament and the Council, representing the governments of the 27 member states, must jointly approve it. Until they agree to the suspension, the existing requirement remains law.
“Suspending this obligation would certainly be a significant improvement for many microenterprises,” Thelen said. “However, it would not solve the whole problem by itself.” Sellers would still face national registrations, declarations and contributions even without compulsory representatives.
No guaranteed grace period
The Commission’s published guidance says businesses should first be warned and allowed to correct the forms of non-compliance listed in Article 62. Failure to appoint an EPR representative is not included in that list, meaning sellers cannot rely on a guaranteed warning before enforcement of Article 45(3).
Despite the legal implications, neither retailer learnt of the requirement through prominent official information in Luxembourg. Caiano first encountered it through creators discussing the issue on TikTok, before watching a Belgian webinar and reading material from his packaging supplier.
Beloussova saw small businesses discussing the rules on Instagram. “I haven’t heard about it from any official channels in Luxembourg,” she said. That silence extends to her online sales platform: although the PPWR requires qualifying platforms to obtain sellers’ destination-country registration details and a declaration of compliance, Beloussova said hers had requested neither.
One portal instead of 27 systems
Caiano wants the EU to preserve producer responsibility while replacing repeated national procedures with a central service modelled on its one-stop shop for value-added tax.
“I hope they find an easier way for us to register, as we experienced with European VAT,” he said. “We now have a dedicated platform for all the countries, where we pay everything in Luxembourg and Luxembourg dispatches the VAT collected to the different member states.”
A comparable packaging portal could use businesses’ shipment records to allocate declarations and contributions among destination countries. “That would make life easier for small companies and small organisations which do not have the financial means to register and appoint representatives in every country,” Caiano said.
The PPWR introduces common elements for national registration and reporting, with the first reports under the harmonised rules due by 1 June 2030. The Commission plans further simplification and digitalisation through a forthcoming Circular Economy Act, but businesses cannot yet register, report and pay for all their markets through a single EU portal.
Until the system changes, AEV advises retailers to contact the authorities and packaging organisations in every country where they deliver. Stikka intends to follow that route and either absorb the expense in its margins or pass it on through prices.
Oddhaus could instead retreat from other destinations if enforcement begins. “Then we’d probably have to stop shipping to other countries, or stick to one country—our main market,” Beloussova said. Until an authority intervenes, however, she intends to continue: “I’ll just wait for somebody to come with a stick and say, ‘You can’t do that.’”
