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EPR in Austria, Sweden and the UK: A 2026 Operator's Guide

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Austria, Sweden and UK EPR in 2026: PPWR applies from 12 August 2026, UK large producers exceed 50 tonnes and £2m, and Austria requires a representative.

By Operator One Editorial — 2026-06-14

Key takeaways

  • From 12 August 2026 the EU Packaging and Packaging Waste Regulation (EU) 2025/40 applies, and its Article 45(3) requires a producer selling packaged goods directly to end users in another member state to appoint an authorised representative for extended producer responsibility there, Austria and Sweden included.
  • Austria's Packaging Ordinance 2014 (§ 16b) has required foreign distance sellers supplying packaged goods to Austrian private consumers to appoint an Austrian-established Authorised Representative (Bevollmächtigter) since 1 January 2023, with a certified power of attorney filed through edm.gv.at.
  • Austria has no licence-free de minimis for packaging: under § 9(2) of the Austrian Packaging Ordinance a producer placing no more than 1,500 kg of household packaging a year may use flat-rate licensing, but must still license through an approved system.
  • Sweden's packaging ordinance (2022:1274) obliges producers to engage, or themselves provide, an approved producer responsibility organisation such as NPA, and Sweden's sanction-fee ordinance (2012:259) charges SEK 30,000 for failing to do so and SEK 10,000 for a late report to Naturvårdsverket.
  • UK packaging EPR obligates UK-established organisations with at least £1 million turnover and more than 25 tonnes of packaging; above £2 million and 50 tonnes they are large producers that report every six months, acquire PRNs or PERNs and pay PackUK disposal fees.
  • UK WEEE splits at 5 tonnes of EEE a year (direct registration by 31 January below it, a producer compliance scheme by 15 November above it), and UK portable batteries split at 1 tonne, with battery scheme membership due by 15 October before the compliance year.

Extended Producer Responsibility (EPR) is one of the most under-budgeted lines in cross-border e-commerce plans. It is not one rule but a stack of national rules covering packaging, batteries and waste electrical and electronic equipment (WEEE), each with its own register, its own approved schemes and its own marketplace checks. Austria, Sweden and the United Kingdom stand out in 2026: each runs separate regimes per waste stream with strict registration rules, and in Austria and Sweden the EU Packaging and Packaging Waste Regulation (EU) 2025/40 started to apply on 12 August 2026. This guide sets out what each country requires and where the friction lands for non-EU sellers and for EU sellers shipping cross-border.

Austria: licensed systems, EDM and the Authorised Representative

Austria runs a competitive model for household packaging: producers license their packaging with one of several collection and recovery systems approved under the Austrian Packaging Ordinance 2014 (Verpackungsverordnung, VVO), of which ARA (Altstoff Recycling Austria) is the best known. Austria's federal producer registers sit in EDM (Elektronisches Datenmanagement, edm.gv.at), run for the Federal Ministry BMLUK.

The Austrian rules that catch most foreign sellers:

  • Mandatory Authorised Representative (Bevollmächtigter) for foreign distance sellers. Under § 16b of the Austrian Packaging Ordinance, a distance seller without a seat or branch in Austria that supplies packaged goods to Austrian private consumers must appoint one Austrian-established Authorised Representative for packaging placed on the market from 1 January 2023. The power of attorney must be certified, in German or English, and filed through edm.gv.at; the representative then takes over the seller's Austrian packaging obligations, including registration and volume reporting. This applies to sellers established in other EU countries as well as outside the EU.
  • Cross-border fulfilment into Austria counts. A parcel delivered to an Austrian consumer from a warehouse in Germany or any other country is a distance sale into Austria, so the Austrian packaging obligations apply to it.
  • Small volumes are simplified, not exempt. Under § 9(2) of the Austrian Packaging Ordinance, approved systems may offer flat-rate (pauschale) licensing to participants placing no more than 1,500 kg of household packaging in a calendar year. The licensing obligation itself remains.
  • Representative registration and the licence are separate steps. The Austrian Authorised Representative is registered via EDM in ZAReg (the register of facility and person master data), while the packaging licence sits with the chosen collection and recovery system.
  • WEEE and batteries are separate regimes. Electrical and electronic equipment falls under the Austrian Electrical Equipment Ordinance (Elektroaltgeräteverordnung, EAG-VO), whose § 21b makes an Authorised Representative (Bevollmächtigter für ausländische Fernabsatzhändler) mandatory for foreign distance sellers. Battery EPR has been governed since 18 August 2025 by Chapter VIII of EU Battery Regulation (EU) 2023/1542, whose Article 56(3) requires a distance seller established in another member state or a third country to appoint an authorised representative for EPR in each member state where it sells batteries.

In Operator One's experience, shipping into Austria from German stock is where sellers most often discover an unlicensed back period, which then has to be licensed retrospectively. Austria's Waste Management Act 2002 (Abfallwirtschaftsgesetz, § 79) treats failing to participate in a collection and recovery system as an administrative offence under paragraph 2, punishable by a fine of EUR 450 to EUR 8,400, with a minimum of EUR 2,100 for those operating commercially in waste management.

Sweden: NPA packaging, separate battery and electrical registers

Sweden's packaging regime is set by Förordning (2022:1274) om producentansvar för förpackningar, under which producers must engage, or themselves provide, an approved producer responsibility organisation. Näringslivets Producentansvar i Sverige AB (NPA) is an approved packaging producer responsibility organisation and reports to Naturvårdsverket, the Swedish Environmental Protection Agency, on behalf of its affiliated producers.

Key 2026 points for Sweden:

  • The packaging producer definition changed on 12 August 2026. Naturvårdsverket confirms that Article 3(15) of Regulation (EU) 2025/40 now defines the packaging producer in Sweden: an operator established in an EU country that first makes packaged products available in that same country, or an operator in another member state or a third country that first makes them available directly to end users in Sweden. Naturvårdsverket states that the new EU definition replaces the previous Swedish producer definition from that date.
  • Registration and a scheme contract are both required. The producer registers with Naturvårdsverket and separately engages an approved producer responsibility organisation. Under Sweden's sanction-fee ordinance (2012:259), not engaging an organisation costs SEK 30,000 (§ 20 a) and a late report to Naturvårdsverket costs SEK 10,000 (§ 20 b).
  • A Swedish authorised representative is now a legal requirement for cross-border packaging sellers. Article 45(3) of Regulation (EU) 2025/40 requires a producer selling directly to Swedish end users from another member state or a third country to appoint, by written mandate, an authorised representative for EPR established in Sweden, from 12 August 2026.
  • Batteries are a separate regime. Since 18 August 2025 Swedish battery EPR follows EU Battery Regulation (EU) 2023/1542, supplemented by Förordning (2025:813): producers register with Naturvårdsverket under Article 55, producer responsibility organisations must be approved, and Article 56(3) requires distance sellers from other member states or third countries to appoint an authorised representative.
  • Electrical equipment is a separate regime. Förordning (2022:1276) om producentansvar för elutrustning governs WEEE in Sweden; El-Kretsen and Recipo are the approved producer responsibility organisations for consumer electrical equipment, and registration with Naturvårdsverket is again a separate step.

United Kingdom: packaging EPR and post-Brexit WEEE

UK packaging EPR operates under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, with PackUK as scheme administrator. The first PackUK invoices were issued in October 2025, calculated on 2024 packaging data and payable within 50 days or under a four-instalment plan. From Year 2 (2026 to 2027) UK disposal fees are modulated by recyclability, so 2026 is the first year in which packaging design changes the UK fee.

What sellers need in place for the UK in 2026:

  • Producer thresholds. According to GOV.UK, a UK-established organisation is an obligated packaging producer if its worldwide turnover is £1 million or more and it supplied or imported more than 25 tonnes of packaging in the previous year. Above £2 million turnover and 50 tonnes it is a large producer; otherwise it is a small producer.
  • Reporting and payment. UK large producers report packaging data every six months, must acquire packaging waste recycling notes (PRNs) or export recycling notes (PERNs) to meet recycling obligations, and pay a household packaging waste disposal fee to PackUK. UK small producers report packaging data once a year by 1 April.
  • Fees and modulation. UK Year 1 (2025) base fees are £423 per tonne for plastic, £461 for fibre-based composite, £280 for wood, £266 for aluminium, £259 for steel and other, £196 for paper and card and £192 for glass. PackUK's illustrative Year 2 fees, published on 19 December 2025, apply a red, amber or green rating under the Recyclability Assessment Methodology (RAM), with red at 1.2 times amber (plastic: £415 green, £455 amber, £545 red). PackUK said in December 2025 that confirmed Year 2 fees were expected to be published in June 2026; the Year 2 figures above are illustrative.
  • UK WEEE is a separate regime. Under the Waste Electrical and Electronic Equipment Regulations 2013, a producer placing less than 5 tonnes of EEE on the UK market in a compliance year may register directly by 31 January; above 5 tonnes it must join an approved producer compliance scheme by 15 November. A legal entity not established in the UK that supplies UK end users directly must appoint a UK-based authorised representative or join a UK scheme before placing EEE on the market, so an EU representative does not cover the UK.
  • UK batteries. Under the Waste Batteries and Accumulators Regulations 2009, a producer placing more than 1 tonne of portable batteries on the UK market a year must join a battery compliance scheme by 15 October before the compliance year; at 1 tonne or less it registers directly and reports tonnage and chemistry by 31 January of the following year.

Marketplace verification: where the three regimes diverge

Marketplaces are the enforcement layer sellers feel first, and in the EU that role is now written into law. From 12 August 2026, Article 45(4) of Regulation (EU) 2025/40 requires online platforms that let consumers contract with producers to obtain, before allowing a producer to sell, its packaging registration number in the consumer's member state and a self-certification of EPR compliance. Article 45(7) and (8) set a similar check for fulfilment service providers. For batteries, Article 55(2) of Regulation (EU) 2023/1542 already bars producers from making batteries available in a member state unless they, or their authorised representative, are registered there.

The UK sits outside these EU rules, so UK marketplace checks rest on UK registrations under the UK packaging, WEEE and battery regimes only.

In Operator One's experience, the consistent failure pattern is a seller who registers in one country, assumes that registration or scheme contract covers other markets, and then loses listings where the identifier is national. Every EU register is national: Article 44(2) of Regulation (EU) 2025/40 requires registration in each member state where packaging is first made available. The European Commission's proposal COM(2025) 982, adopted in December 2025, would suspend the authorised-representative requirement for producers established in the EU until 2035, but as of September 2026 it was still in the ordinary legislative procedure and not law, and it would not change the position for producers established outside the EU.

How to register, step by step

  1. Map every stream and country: List, per destination country, whether you place packaging, electrical and electronic equipment or batteries on that market, and identify which legal entity first makes the goods available there, because that entity is the producer under Article 3(15) of Regulation (EU) 2025/40 and the national rules.
  2. Check the thresholds that apply: Apply the UK tests (£1 million and 25 tonnes for packaging, £2 million and 50 tonnes for large producers, 5 tonnes for WEEE, 1 tonne for portable batteries) and Austria's 1,500 kg flat-rate licensing option, which simplifies but does not remove the Austrian licensing duty.
  3. Appoint an authorised representative where required: Appoint an Austrian Bevollmächtigter under § 16b of the Austrian Packaging Ordinance and § 21b EAG-VO if you distance-sell into Austria without an establishment there, a battery representative under Article 56(3) of Regulation (EU) 2023/1542, and from 12 August 2026 a packaging representative under Article 45(3) of Regulation (EU) 2025/40 in each other member state you sell into directly.
  4. Register with each national authority: Register the producer or its representative through edm.gv.at in Austria, with Naturvårdsverket in Sweden, and with the UK environmental regulator through the packaging data service or the UK WEEE and battery registers.
  5. Contract an approved scheme per stream: License household packaging with an approved system such as ARA in Austria, engage an approved producer responsibility organisation in Sweden (NPA for packaging, El-Kretsen or Recipo for consumer electricals), and in the UK join a producer compliance scheme above 5 tonnes of EEE or a battery compliance scheme above 1 tonne of portable batteries.
  6. Report volumes and pay fees on time: File UK packaging data every six months as a large producer or by 1 April as a small producer and pay PackUK invoices, file the Swedish report to Naturvårdsverket on time to avoid the SEK 10,000 late fee, and report Austrian volumes through your system and representative.
  7. Give registration numbers to marketplaces and fulfilment providers: From 12 August 2026 Article 45(4) and 45(7) of Regulation (EU) 2025/40 require producers to give online platforms and fulfilment service providers their registration number in the consumer's member state and a self-certification of EPR compliance.

Frequently asked questions

Do I need an Authorised Representative to sell into Austria?

Yes, if you distance-sell into Austria without an Austrian establishment. Austria's Packaging Ordinance 2014 (§ 16b) has required foreign distance sellers of packaged goods to private consumers to appoint an Austrian-established Bevollmächtigter since 1 January 2023. Austria's Electrical Equipment Ordinance (EAG-VO, § 21b) makes the same appointment mandatory for electrical equipment, and Austria's USP business portal states the same for batteries. From 12 August 2026 Article 45(3) of Regulation (EU) 2025/40 adds an EU-level packaging requirement.

Is there a small-seller exemption for packaging in Austria?

Not a full exemption. Under § 9(2) of the Austrian Packaging Ordinance 2014, approved collection and recovery systems may offer flat-rate (pauschale) licensing to participants placing no more than 1,500 kg of household packaging on the Austrian market in a calendar year. The packaging must still be licensed through an approved system: the flat rate simplifies the tariff but does not remove the obligation, and a foreign distance seller still needs its Austrian Authorised Representative.

What are the UK packaging EPR thresholds for 2026?

UK packaging EPR obligates UK-established organisations with worldwide turnover of £1 million or more that supplied or imported more than 25 tonnes of packaging in the previous year. Organisations above £2 million turnover and 50 tonnes are large producers: they report every six months, acquire PRNs or PERNs and pay PackUK waste disposal fees. Organisations between those lines are small producers and report packaging data once a year by 1 April.

How much does UK packaging EPR cost per tonne?

UK Year 1 (2025) base fees are £423 per tonne for plastic, £461 for fibre-based composite, £280 for wood, £266 for aluminium, £259 for steel and other materials, £196 for paper and card and £192 for glass. PackUK's illustrative Year 2 (2026 to 2027) fees, published on 19 December 2025, are modulated by recyclability: plastic is £415 green, £455 amber and £545 red per tonne, with red set at 1.2 times amber.

Do I have to register separately in Sweden for packaging, batteries and electricals?

Yes. Sweden runs separate producer responsibility ordinances: packaging under Förordning (2022:1274), electrical equipment under Förordning (2022:1276) and batteries under Förordning (2025:813), which supplements EU Battery Regulation (EU) 2023/1542 from 18 August 2025. Each stream needs its own registration with Naturvårdsverket and its own approved producer responsibility organisation, for example NPA for packaging and El-Kretsen or Recipo for consumer electrical equipment.

What is the UK WEEE registration threshold and deadline?

Under the UK Waste Electrical and Electronic Equipment Regulations 2013, a producer placing less than 5 tonnes of EEE on the UK market in a compliance year may register directly with its environmental regulator by 31 January, or within 28 days of first placing EEE on the market. Above 5 tonnes it must join an approved producer compliance scheme by 15 November. A non-UK entity supplying UK end users directly must appoint a UK authorised representative or join a scheme.

What happens if I sell without EPR registration?

Penalties are national. Austria's Waste Management Act 2002 (§ 79) sets a fine of EUR 450 to EUR 8,400 under paragraph 2 for failing to participate in a collection and recovery system, with a minimum of EUR 2,100 for those operating commercially in waste management. Sweden's ordinance 2012:259 charges SEK 30,000 for not engaging a packaging producer responsibility organisation and SEK 10,000 for a late report. From 12 August 2026 Regulation (EU) 2025/40 Article 45(4) also requires online platforms to check producers' registration numbers before letting them sell.

Who carries the EPR obligation when a Merchant of Record is the seller?

Under Article 3(15) of Regulation (EU) 2025/40, the packaging producer is the manufacturer, importer or distributor that first makes packaged products available in a member state, including by distance sale. Where a Merchant of Record sells the goods as the legal seller, it is normally that producer for those sales and holds the national registration, reporting and fees. EPR registrations are per country and per stream and do not transfer from the brand's own registrations.

Does one EPR registration cover the whole EU?

No. Article 44(2) of Regulation (EU) 2025/40 requires producers to register in each member state where they first make packaging available, and Article 55 of Battery Regulation (EU) 2023/1542 does the same for batteries. An Austrian EDM registration does not satisfy Sweden's Naturvårdsverket, and the UK runs separate post-Brexit regimes. The Commission proposal COM(2025) 982 to suspend the authorised-representative duty for EU-established producers had not been adopted by September 2026.

Where a Merchant of Record carries the EPR obligation

EPR follows the legal seller, not the brand name on the product. Under Article 3(15) of Regulation (EU) 2025/40 the packaging producer is the manufacturer, importer or distributor that first makes the packaged product available in a member state, and Article 3(47) of Regulation (EU) 2023/1542 defines the battery producer on the same first-supply basis. When Operator One acts as Merchant of Record, it sells the goods as the legal seller (the listing shows the client as the brand and Operator One as the seller), so it is normally the producer for those sales and carries the national registrations, reports and fees. Those registrations are per country and per stream and do not transfer to or from the brand's own registrations, so a brand that also sells its own stock keeps its own EPR obligations for those sales. Where a market requires a locally established authorised representative, Operator One commonly arranges one as part of onboarding, but not in every market. Product conformity obligations such as CE marking, the technical file and the EU Declaration of Conformity stay with the manufacturer. Definitions of the terms used here are in the compliance glossary.

Sources: Regulation (EU) 2025/40 (PPWR); Regulation (EU) 2023/1542 (Batteries); Procedure 2025/0395/COD, COM(2025) 982; Austrian Packaging Ordinance § 16b; Austrian Packaging Ordinance § 9; Austrian Waste Management Act 2002 § 79; USP Austria: authorised representatives for EEE; Swedish ordinance 2012:259 on environmental sanction fees; Swedish ordinance 2025:813 on batteries; GOV.UK: EPR for packaging, who is affected; GOV.UK: Year 2 illustrative waste disposal fees; GOV.UK: EEE producer responsibilities.

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