The application of the EU Regulation on packaging and packaging waste (PPWR), starting on August 12, 2026, changes the obligations of Romanian producers delivering packaged products to other Member States. Responsibility is no longer assessed solely based on where the packaging takes place, but also on the country where the product reaches the final user and on the operator considered the producer.
Companies that sell directly to customers in other EU countries, including through online commerce, may become responsible for the packaging placed on the market in each respective country. However, the rules differ depending on the commercial flow: selling to a distributor is not treated in the same way as delivering directly to consumers.
Producers must separately analyze sales packaging, grouped packaging, and transport packaging. For certain operations, it may be necessary to appoint an authorized representative to manage registration, reporting, and the financing of waste collection.
In addition, companies must track, for each country, the type and weight of packaging, the materials used, the destination of the products, and where they are made available to the final user. Deloitte Romania recommends a comprehensive analysis of cross-border flows and coordination among sales, logistics, tax, environmental, and legal teams to avoid incomplete reporting.
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