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🇮🇪 EPR Compliance for Packaging in Ireland |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Packaging – 7 Steps to Compliance + Step-by-Step Checklist

Ireland provided clarity in 2026: The government granted Repak a new 10-year license – valid through 2036 – thereby confirming Repak as the country’s sole state-recognized packaging compliance organization. For companies placing packaging on the Irish market, this means that joining Repak’s system is mandatory.

In addition, the PPWR harmonizes packaging legislation across the entire European Union and requires all market participants to maintain complete registration under the extended producer responsibility framework. A key component of this EU-wide regulation is the requirement for cross-border online retailers to appoint a local authorized representative in every EU destination country where they do not have their own branch office. Specifically for the Irish market, this means that foreign companies – whether from the EU or a third country – must appoint such a local representative as of the effective date to ensure legally compliant registration and volume reporting within the Repak system, which is now established on a long-term basis.

Here are the 7 most important steps for packaging EPR compliance in Ireland.

Who is considered a “producer” under Irish packaging regulations?

Anyone who first places packaged goods on the market in Ireland on a commercial basis is legally considered a producer.
  • Producers/bottlers based in Ireland: Companies that bottle or package goods in Ireland and distribute them under their own brand name.
  • Private-label owners: Retailers who have products packaged by third parties but sell them under their own name in Ireland.
  • Importers: Anyone who imports packaged goods into Ireland on a commercial basis from abroad (EU or third country).
  • Companies from other EU countries: Anyone who sells packaged products directly to Irish end consumers via distance selling (e-commerce) – including shipping boxes and packing materials.
  • Companies outside the EU: For direct B2C deliveries, the obligation lies with the foreign company. In traditional B2B supply chains, the first Irish importer assumes the role of producer.
  • Marketplace operators: Platforms are increasingly bearing subsidiary liability for the packaging compliance of their third-party sellers.

Practical example: A German company ships cosmetic products in cardboard shipping boxes directly to Irish end consumers → is considered a producer → an authorized representative is required → Repak membership → semi-annual reporting by August 21 (H1) and February 21 (H2) → direct PPWR obligations effective August 12, 2026.

The 7 Most Important Steps for Packaging EPR Compliance in Ireland

Step 1: Appoint an Authorized Representative (for foreign companies)

Foreign companies without a place of business in Ireland that sell packaged goods directly to Irish consumers are required to appoint an Authorized Representative based in Ireland.

The Authorized Representative assumes financial and administrative liability for all legal packaging obligations in Ireland (registration, reporting, fee payment).

Requirements:

  • A natural person or legal entity based in Ireland
  • Written power of attorney
  • No Hague Apostille required
  • The EPA verifies the existence of the foreign company digitally

Step 2: Check for Major Producers (Threshold: 10 metric tons + €1 million in revenue)

Ireland’s packaging EPR distinguishes between Major Producers (mandatory members of Repak) and smaller companies:

A company is considered a Major Producer and must join Repak if it places more than 10 metric tons of packaging material on the Irish market AND has annual revenue exceeding €1 million.

StatusConditionObligation
Major Producer>10 metric tons of packaging/year AND >€1 million revenue Full mandatory membership in Repak with detailed material reporting.
Small ProducerBelow one or both thresholdsUntil August 2026: Record-keeping requirement + local administration.
Effective August 12, 2026 (PPWR): Registration and reporting requirement with Repak (via simplified small business rates with no minimum threshold).

Step 3: Repak Membership: Regular vs. Scheduled

Repak offers two types of membership: Regular Membership for large companies such as manufacturers, importers, brand owners, and large retailers, who pay an annual fee based on the volume of packaging placed on the market; and Scheduled Membership (simplified membership) for small and medium-sized businesses such as retailers, hotels, pharmacies, and restaurants, who pay a fixed annual fee.

Regular Membership (Major Producers): Volume-based fee for large companies (manufacturers, importers, large online retailers). Semi-annual reporting requirement (deadlines: August 21 and February 21).

Scheduled Membership (Major Producers): Fixed annual fee for domestic service providers/retailers that exceed the major producer threshold but are not importers or manufacturers.

This category is strictly intended for purely domestic businesses that sell goods directly to end consumers (e.g., local hotels, pubs, pharmacies, or retailers). As soon as a company manufactures goods itself, imports them, or is a brand owner, it is automatically subject to Regular Membership with the requirement to submit detailed statistics.

Note: As of August 12, 2026, the PPWR will eliminate the legal exemption threshold (0-kg threshold) for registration.

How to Sign Up for Repak Membership:

  1. Open an online account at repak.ie; submit the previous year’s tonnage by material
  2. Sign the Repak contract; pay the one-time membership fee
  3. Repak issues a membership number – proof of EPR registration
  4. Retain data for 7 years for EPA/local government audits

Step 4: Classify packaging by material stream

Repak requires a detailed breakdown by material stream – which is essential for accurate fee calculation and reporting.

Eco-modulation (under development): As part of the PPWR implementation, Repak is preparing a more robust eco-modulation system. Recycling-friendly designs (mono-materials, unpigmented plastics) will be rewarded with lower rates in the future; composite materials that are difficult to recycle will be subject to penalty surcharges.

Under the Irish EPR system and the PPWR, these categories must be recorded separately, as they are subject to different fee rates, recovery obligations, and recycling targets.

Separate Collection:

  • Primary packaging (product packaging)
  • Secondary packaging (outer packaging)
  • Transport packaging (pallets, stretch film)
  • E-commerce shipping packaging (to end customers)

Step 5: Financial Obligations & Repak Fees

The Repak Eco-Contribution is calculated per metric ton/kilogram of packaging materials placed on the market in Ireland, broken down by material stream.

Fee Structure (Principle):

Net weight (metric tons) × rate per material stream

The current rates are available to members on repak.ie and are adjusted annually. As a general rule:

  • Plastic (rigid & flexible): Highest rates (heavily eco-modulated)
  • Metals (steel & aluminum): High rates.
  • Paper/cardboard: Medium rates.
  • Glass & wood: Lowest rates per metric ton.

SUP (Single-Use Plastics) Surcharges: Since the beginning of 2023, producers of certain SUP items have been required to cover the costs of litter cleanup, in addition to their existing EPR obligations. This applies to certain food containers, packaging made of flexible materials, beverage containers, cups, lightweight plastic carrier bags, and tobacco products.

Step 6: Reporting Requirements: Semi-Annual

Semi-Annual Repak Report:

For the first half of the year (January–June), data must be submitted to Repak by August 21 of the same year; for the second half of the year (July–December), by February 21 of the following year.

PeriodDeadline
H1 (January–June)August 21 of the same year
H2 (July–December)February 21 of the following year

Report Contents:

  • Exact weight figures (in metric tons) for all packaging placed on the market in Ireland during the reporting period
  • Breakdown by material stream and type of use (household vs. commercial)
  • Includes shipping packaging and service packaging for e-commerce shipments

Channel: Digitally via the Repak member portal.

Step 7: Deposit-and-Return Scheme (DRS)

Deposit-and-Return Scheme (DRS) in Ireland: Ireland’s deposit-and-return system for single-use beverage containers (Return) became mandatory on February 1, 2024. It covers all containers made of PET plastic, aluminum, and steel ranging in size from 150 ml to 3 liters, with the exception of milk and juices. Depending on the size, a deposit of 15 or 25 cents applies. Affected producers must register their products with Re-turn, affix the logo, and pay producer fees. In return, these packaging items are exempt from the regular Repak bin fees.

PPWR Labeling (starting in 2028): As of August 12, 2026, the PPWR will initially take effect with material bans on PFAS in food packaging and the requirement to provide comprehensive declarations of conformity. The mandatory introduction of EU-wide harmonized labeling requirements for material composition and waste separation, however, will not take effect until after a transition period beginning in 2028. Until that date, the existing Irish national requirements and labeling rules will continue to apply in parallel to give companies sufficient time to adapt their packaging designs.

Step-by-Step Checklist

(a) Companies based in Ireland

1. Check the major producer threshold: >10 metric tons of packaging per year and >€1 million in revenue?

2. Record all packaging components by material (including shipping packaging)

3. Sign up for Repak membership: Regular (Major Producer) or Scheduled (Small Producer)

4. Obtain a Repak membership number

5. Semi-annual reporting: H1 data by August 21; H2 data by February 21

6. Pay the Eco-Contribution by the deadline

7. Check SUP obligations: Littering fee for affected single-use items

8. Retain data for 7 years for EPA audits

9. Keep an eye on the PPWR, effective August 12, 2026

(b) Companies from other EU countries

1. Appoint an authorized representative in Ireland

2. Check the “major producer” threshold (Irish packaging volumes, including shipping cartons)

3. The authorized representative opens a Repak account and completes the membership process

4. Communicate the Repak membership number to Irish trading partners and marketplaces

5. Submit all packaging volumes (weight by material) in a structured format to the authorized representative for semi-annual reporting

6. Note the deadlines: H1 data by August 21; H2 data by February 21

7. PPWR: Starting August 12, 2026, foreign shippers will be subject to strict registration and reporting requirements for even the first gram of packaging under the PPWR

(c) Companies from third countries (outside the EU)

1. Option A – Shipping to an Irish B2B partner: The partner assumes the importer’s obligations; submit all material weights in a timely manner

2. Option B – Direct B2C shipping: Appoint an authorized representative in Ireland (mandatory); complete all steps listed in (b)

Are you planning to sell your products in Ireland?

We’ll help you ensure compliance with Ireland’s EPR regulations for packaging so you can get started with legal certainty.

Contact

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