Cross-border sellers may need an Authorized Representative in each member state.
Photo credit: Alexey Larionov on Unsplash
New European Union packaging rules could create substantial additional costs for independent labels, record stores, and other small businesses selling directly across EU borders.
The Packaging and Packaging Waste Regulation was made law on February 11th, 2025 and enforced on August 12th, 2026. Under the rules, an EU company selling directly to consumers in another member state must appoint an Authorised Representative in each country where it operates.
The requirement also applies to non-EU businesses selling directly to consumers within the union, though business-to-business commerce is excluded.
Depending on providers and scale, representation may cost hundreds or thousands per country annually, creating concerns among smaller sellers.
Entertainment attorney and AFEM member Olivia Griffin cautioned against viewing the regulation as an immediate threat to independent distribution, noting that enforcement may initially focus on larger companies.
A petition calling for a moratorium has attracted more than 70,000 signatures, while a European Commission proposal would suspend the Authorised Representative rules until 2035.
View the petition here.
