Ireland Packaging EPR · PPWR 2026
Ireland packaging EPR — Producer, representation, Repak, Re-turn and evidence
Ireland combines a live national packaging EPR system with the directly applicable PPWR. Determine the Producer first, keep the Irish Major Producer threshold separate from PPWR duties, treat Article 44 as a register transition, then operate Repak, Re-turn and Revenue as distinct compliance layers.
Regulatory review · 5 September 2026
Ireland in 30 seconds
01 · Producer
Who is the Ireland packaging Producer?
Start with the transaction that first makes packaging or packaged products available in Ireland. Do not substitute marketplace account ownership, VAT registration, brand ownership or fulfilment location for the PPWR Producer test.
EU seller → Irish end user
An EU-established seller can be the PPWR Producer in Ireland when it supplies packaged products directly to Irish end users.
Irish Major Producer: more than 10 tonnes AND more than €1 million Irish turnover.
PPWR Article 44: less than 10 tonnes uses the simplified Annex IX reporting dataset; it is not an EPR exemption.
02 · EPR Authorised Representative
Ireland EPR Authorised Representative
The current PPWR text creates a clear mandatory route for certain EU cross-border Producers and gives Ireland discretion for third-country Producers. The proposed EU suspension remains a proposal.
Article 45(3): a Producer under Article 3(15)(c) or (d) appoints, by written mandate, an EPR Authorised Representative in each other Member State where it first makes packaging available.
The representative for the Irish route must be established in Ireland.
Article 45 says Member States may require a third-country Producer to appoint an EPR AR. Ireland-specific packaging implementation must therefore be confirmed before onboarding.
COM(2025) 982 / procedure 2025/0395/COD is ongoing. Do not operate as though the proposed suspension were already binding law.
03 · Registration / Article 44
Article 44 is binding architecture — Ireland is still in register transition
PPWR Article 44 requires each Member State to establish a national producer register within 18 months after the first Article 44(14) implementing act enters into force. The Commission published a draft harmonised registration/reporting format on 6 August 2026; it is a draft consultation document, not a final Irish producer portal.
Do not relabel Repak membership as the final Article 44 producer-register number. Track the binding Article 44 architecture, the Commission draft format and Ireland's national implementation separately.
Producer registration, public register, registration number, reporting and marketplace-verification data are set by the Regulation.
Commission draft for the harmonised registration/reporting format. Draft / consultation status at this review.
Ares(2026)7688068Use the current Irish national obligations and Repak participation while monitoring the final Article 44 authority/portal implementation.
Resolve the Ireland first-making-available transaction before opening scheme or register workflows.
Producer, EPR AR or entrusted PRO may be the operational filer depending on national implementation.
Repak membership proves scheme participation; it is not automatically the final Article 44 registration record.
Beverage DRS Producer/product registration is a distinct evidence class.
When the Article 44 route is operational, retain the registration number, public record and change history separately.
Article 44 annual reporting is due by 1 June once the register/reporting implementation is operational; <10 t uses simplified data.
04 · PRO / system
Repak is the packaging EPR system; Re-turn is a separate DRS layer
Ireland is not a multi-PRO bidding market. Repak is approved to operate the packaging EPR scheme through 2035. Re-turn applies separately to in-scope beverage containers.
Government-approved packaging EPR scheme. Regular Member fees are supply-chain-stage and material-specific. Major Producers have been required to join an approved body since 1 January 2023.
Open source ↗MEMBERSHIP CLASSRegular MemberFor many importers and brandholders, the Brandholder / Importer tariff stage is the relevant published 2026 basis. Confirm the actual membership class before applying rates.
Open source ↗SEPARATE DRSRe-turnRepublic of Ireland DRS for in-scope PET bottles and aluminium/steel cans from 150 ml to 3 L. Producer registration, product registration, monthly reporting, producer fee and deposits are separate from Repak.
Open source ↗05 · Charges / levies
Keep every Ireland cash layer separate
Repak contributions, Re-turn producer fees, refundable deposits, Revenue levies, EPR-AR services, third-party costs and Beyoğlu fees have different payees and legal natures.
2026 Regular Member contribution
Brandholder / Importer €/tonne rates by material. Use only where this is the correct membership stage.
Current Re-turn producer fee
Per-container producer fee varies by in-scope material. Enter the current verified agreement/portal rate instead of freezing the old public 2023 guide.
Re-turn deposit cash
€0.15 up to and including 500 ml; €0.25 above 500 ml to 3 L. Show as refundable circulating cash, not operating expense.
Plastic Bag Environmental Levy
€0.22 per covered shopping bag, itemised and remitted to Revenue. The levy is not subject to VAT.
Ireland EPR AR service
Commercial fee paid to the appointed Ireland-established representative where the valid legal route requires one.
Operating coordination
€25 country activation + €1 per qualifying declared parcel. Never mix this revenue with regulatory/system money.
06 · Ireland calculator
Ireland first-year cash calculator
Calculate the published Repak 2026 Brandholder / Importer tariff and statutory bag levy. Enter current quote/agreement values where the amount is not safely hard-coded. Refundable DRS deposit cash stays separate.
01 · Repak / Major Producer
02 · Re-turn / DRS
03 · Other cash layers
07 · Reporting / payment
Ireland has several reporting clocks
Repak statistics, PPWR Article 44 reporting, Re-turn monthly data and Plastic Bag Levy returns have different recipients and mechanics. Keep one reconciled Ireland operating calendar.
Jan–Jun statistics
Repak's published training uses 21 August for first-half packaging statistics.
Jul–Dec statistics
Second-half statistics are due 21 February of the following year under the published Repak training material.
Previous calendar year
Article 44 sets 1 June reporting for each full preceding calendar year; <10 t uses the simplified Annex IX dataset. Apply through the final operational register route.
Placed-on-market volumes
Registered Producers report in-scope products placed on the ROI market each month. CSV and Manual Input Reporting are available.
08 · Beyoğlu duties
What Beyoğlu operates
09 · Seller duties
What the seller must own
10 · Evidence / marketplace
Build an Ireland evidence chain that an authority, marketplace or auditor can read
Do not collapse every document into one generic EPR certificate. Preserve each proof class and link it to the same Producer, period and packaging dataset.
Compare Ireland's register, AR and system route against the other EU Member States.
Open EU Country Matrix →Operate Ireland from one compliance account
Test the first-making-available transaction before selecting a scheme.
Check Producer status →RepresentEPR AR CheckerSeparate the current EU cross-border rule from the third-country national check.
Check EPR representation →PreparePackaging Weight CalculatorConvert Ireland SKU/component data into reportable material weights.
Calculate packaging weight →CalculateEPR Cost EstimatorKeep regulatory/system cash separate from service revenue.
Estimate EPR cost →OperateCompliance Deadline CalculatorTrack Repak, Re-turn, Article 44 and levy clocks.
Check deadlines →VerifyOfficial SourcesOpen authorities, legislation, registers and recognised systems.
Open official sources →Primary sources
Claim-level primary sources
Use EU law, Irish legislation, EPA / government material, Repak, Re-turn and Revenue. Secondary summaries do not control the operating position.
FAQ
Ireland packaging EPR FAQ
Producer → representation → Article 44 transition → Repak → conditional Re-turn / Revenue → regulatory cash → reporting → evidence.
Is Ireland packaging EPR already operating under PPWR?
Yes, PPWR applies generally from 12 August 2026, while Ireland's existing national packaging framework and Repak continue operating. The Article 44 producer-register implementation must be tracked as a separate transition layer.
Is Repak membership the same as Article 44 registration?
No. Repak membership is scheme-participation evidence. Article 44 creates a national producer-register architecture with its own registration number and public-list requirements.
Does less than 10 tonnes mean no Ireland EPR?
No. PPWR Article 44 uses less than 10 tonnes for a simplified reporting dataset. Ireland's legacy Major Producer concept uses more than 10 tonnes together with turnover above €1 million for that national status.
Must an EU seller appoint an Ireland EPR Authorised Representative?
Under the current Article 45(3) text, a Producer within Article 3(15)(c) or (d) appoints an EPR Authorised Representative in each other Member State where it first makes packaging available. The proposal to suspend this rule remains ongoing, not adopted.
Must every third-country seller appoint an Ireland packaging EPR AR?
The PPWR lets Member States require this. This page does not assert a blanket Irish packaging requirement without a current national implementation source; confirm the Ireland route at onboarding.
What does Repak charge in 2026?
Repak publishes 2026 Regular Member rates by material and supply-chain stage. The official table has four supply-chain stages. This page calculates the Brandholder / Importer stage only for the common foreign-seller route; the published "Total per tonne" is a cross-stage sum, not a single member charge, and these rates are not a government tax.
What is separate about Re-turn?
Re-turn is the Republic of Ireland DRS for in-scope PET bottles and aluminium/steel cans from 150 ml to 3 L. It has separate Producer/product registration, monthly reporting, producer fees and refundable deposits.
What are the current Re-turn deposits?
€0.15 for in-scope containers up to and including 500 ml, and €0.25 for in-scope containers over 500 ml up to 3 L.
How much is the Plastic Bag Environmental Levy?
Revenue states 22 cent per covered shopping bag. The levy is itemised at point of sale, remitted to Revenue and is not subject to VAT.
What should a marketplace evidence pack contain?
Keep Article 44 register proof, Repak scheme proof, EPR-AR mandate where applicable, Re-turn evidence where applicable, payment proof and marketplace verification as separate but linked evidence classes.
Operate Ireland from one compliance account
Producer → representation → Article 44 transition → Repak → conditional Re-turn / Revenue → regulatory cash → reporting → evidence.