The EU Packaging and Packaging Waste Regulation — PPWR, formally Regulation (EU) 2025/40 — is the single biggest change to packaging law in a generation. If you sell packaged goods into Belgium from outside the EU, one article in particular matters to you.
The timeline
The PPWR entered into force on 11 February 2025, starting an 18-month transition. Its general application date is 12 August 2026 — and there is no grace period. As of that date, market surveillance began across the EU, and Amazon set the same date as its own internal enforcement deadline.
Article 45: the authorised representative
Article 45 is the clause that changes things for non-EU sellers. It requires a producer that is not established in the Member State where it places packaging on the market to appoint an authorised representative — established in that Member State — to carry out the producer's obligations.
For third-country producers (China included), this is not optional, and it is not waivable. The proposed suspension of the AR obligation until 2035 explicitly applies only to EU-based producers; non-EU companies are excluded from that exemption.
What Belgium adds on top
Belgium already went further than the EU, earlier. Since the 3 September 2020 amendment to the Belgian Interregional Packaging Agreement, a foreign company selling directly to Belgian consumers (distance selling) must appoint an authorised representative established in Belgium. The text uses « désigne » — "must appoint" — not "may appoint".
In practice this means: Fost Plus registration (household packaging), the authorisation filed with EPRiBEL, and an annual declaration — with your AR carrying the same obligations as the producer.
What this means for you
If you sell direct to Belgian consumers from outside the EU, you are the producer and you need a Belgian AR — from the first package, with no minimum volume. The good news is that Belgian registration is fast: around 4–6 weeks, versus 12–14 weeks in Germany.
The obligation is already in force. The question is not whether to get compliant, but how quickly you can.
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