# Ireland EPR Authorized Representative & Packaging EPR | PPWR 2026

> 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.

Canonical: https://beyogluprofessional.com/countries/ireland
Reviewed: 2026-09-05

## Ireland in 30 seconds

- **PPWR status:** APPLIES · 12 Aug 2026
- **Irish Major Producer:** >10 t + >€1m
- **Article 44:** REGISTER TRANSITION
- **Packaging system:** REPAK · approved to 2035
- **EU cross-border EPR AR:** CURRENT ART. 45(3)
- **Third-country packaging AR:** NATIONAL RULE TO CONFIRM
- **Beverage DRS:** RE-TURN · 150 ml–3 L
- **Plastic Bag Levy:** €0.22 / covered bag

## 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.

- **Two different 10-tonne rules:** Irish Major Producer: more than 10 tonnes AND more than €1 million Irish turnover.
- **PPWR Article 44(8):** PPWR Article 44: less than 10 tonnes uses the simplified Annex IX reporting dataset; it is not an EPR exemption.

### 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.

- Test Article 3(15)(c)/(d)
- Current Article 45(3) EPR-AR route
- Ireland is the destination Member State
- Legacy Irish threshold is a second, separate test

### Third-country seller → Irish end user

A Turkish, UK, US, Chinese or other third-country seller can itself be the PPWR Producer. Article 45 lets Ireland require an EPR AR, but a blanket Ireland packaging rule is not asserted without national confirmation.

- Producer can be non-EU
- Third-country AR rule must be verified
- Do not copy WEEE/battery rules into packaging
- Repak / DRS duties remain route-specific

### Foreign supplier → Irish importer

Where an Irish importer is the operator first making the packaged product available in Ireland, the Producer position can sit with that Irish entity.

- Transaction chain controls
- Importer may become Producer
- Foreign supplier is not automatically Producer
- Contract and Incoterms are evidence, not the legal test by themselves

### Own brand / private label

Who commissions, brands, imports and first supplies the product matters. A contract manufacturer is not automatically the packaging EPR Producer.

- Principal must be tested
- Manufacturer ≠ EPR Producer automatically
- Importer route may control
- Keep product conformity roles separate

## 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.

- **EU cross-border Producer:** 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.
- **Established where?:** The representative for the Irish route must be established in Ireland.
- **Third-country Producer:** 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.
- **Proposal status:** COM(2025) 982 / procedure 2025/0395/COD is ongoing. Do not operate as though the proposed suspension were already binding law.

EPR Authorised Representative ≠ manufacturer authorised representative. This page operates packaging EPR representation under PPWR Chapter VIII; technical manufacturer/conformity representation remains a separate role.

## 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.

- **Article 44 national-register timing:** Within 18 months of entry into force of the first Article 44(14) implementing act
- **Commission draft:** Ares(2026)7688068 · 2026-08-06 · DRAFT / CONSULTATION
- **PPWR annual reporting date:** 1 June
- **Simplified PPWR reporting threshold:** <10 tonnes
- **Registration grant maximum after complete information:** 12 weeks

- **Binding PPWR · Article 44 national register architecture:** Producer registration, public register, registration number, reporting and marketplace-verification data are set by the Regulation.
- **EU implementation · Draft Ares(2026)7688068 · 6 Aug 2026:** Commission draft for the harmonised registration/reporting format. Draft / consultation status at this review.
- **Ireland operating route · National packaging framework + Repak continue:** Use the current Irish national obligations and Repak participation while monitoring the final Article 44 authority/portal implementation.

1. **Determine the Producer** — Resolve the Ireland first-making-available transaction before opening scheme or register workflows.
2. **Map the Article 44 filer** — Producer, EPR AR or entrusted PRO may be the operational filer depending on national implementation.
3. **Keep Repak evidence separate** — Repak membership proves scheme participation; it is not automatically the final Article 44 registration record.
4. **Add Re-turn separately** — Beverage DRS Producer/product registration is a distinct evidence class.
5. **Preserve the number / public record** — When the Article 44 route is operational, retain the registration number, public record and change history separately.
6. **Report by the controlling route** — Article 44 annual reporting is due by 1 June once the register/reporting implementation is operational; <10 t uses simplified data.

## 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.

- **Repak approval:** through 2035; approval dated 2026-01-16
- **Irish Major Producer:** >10 t + >€1,000,000
- **Approved-body membership:** required for Major Producers since 2023-01-01

- **Repak · PACKAGING EPR:** 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. — https://repak.ie/
- **Regular Member · MEMBERSHIP CLASS:** For many importers and brandholders, the Brandholder / Importer tariff stage is the relevant published 2026 basis. Confirm the actual membership class before applying rates. — https://repak.ie/images/uploads/downloads/Repak_Regular_Member_2026_Fees_Sheet.pdf
- **Re-turn · SEPARATE DRS:** Republic 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. — https://re-turn.ie/producer/

Scheduled Membership is not a generic low-volume importer shortcut. Classify membership from Repak's current eligibility rules rather than seller size alone.

## 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.

- **REPAK · 2026 Regular Member contribution:** Brandholder / Importer €/tonne rates by material. Use only where this is the correct membership stage.
- **DRS FEE · 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.
- **REFUNDABLE · 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.
- **REVENUE · Plastic Bag Environmental Levy:** €0.22 per covered shopping bag, itemised and remitted to Revenue. The levy is not subject to VAT.
- **REPRESENTATIVE · Ireland EPR AR service:** Commercial fee paid to the appointed Ireland-established representative where the valid legal route requires one.
- **BEYOĞLU · Operating coordination:** €25 country activation + €1 per qualifying declared parcel. Never mix this revenue with regulatory/system money.

- **Recycled paper / cardboard:** €41.60 / tonne
- **Recycled glass:** €19.14 / tonne
- **Recycled aluminium · non-DRS:** €5.14 / tonne
- **Recycled steel · non-DRS:** €64.76 / tonne
- **Recycled rigid plastic:** €165.70 / tonne
- **Recycled flexible plastic:** €165.70 / tonne
- **Non-recycled plastic:** €616.22 / tonne
- **PET beverage bottles · non-DRS:** €165.70 / tonne
- **Other plastic beverage bottles:** €165.70 / tonne
- **Plastic non-beverage bottles:** €165.70 / tonne
- **Recycled wood:** €14.18 / tonne
- **Recycled composite:** €165.70 / tonne
- **Non-recycled composite:** €616.22 / tonne
- **Non-recycled other:** €324.06 / tonne

- **Re-turn scope:** PET plastic bottles and aluminium/steel cans from 150 ml to 3 L
- **Re-turn deposit ≤500 ml:** €0.15 / unit
- **Re-turn deposit >500 ml–3 L:** €0.25 / unit
- **Re-turn reporting:** monthly; Manual Input Reporting available
- **Re-turn 2023 historical producer-fee baseline:** PET €0.02/container; aluminium/steel €0.0125/container. Historical structure only — the source committed to annual review from Q1 2025, so current 2026 fees must come from the current agreement/portal.
- **Re-turn producer fee:** Current verified Producer Membership Agreement / portal rate
- **Plastic Bag Environmental Levy:** €0.22 / covered bag; VAT 0%
- **Beyoğlu:** €25 country activation + €1 / qualifying parcel

Planning values only. Repak rates are the published 2026 Regular Member Brandholder / Importer stage. Re-turn producer-fee inputs must come from the current agreement/portal. Regulatory money, deposits and third-party invoices are not Beyoğlu revenue.

## 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.

- **REPAK · H1 · 21 AUG · Jan–Jun statistics:** Repak's published training uses 21 August for first-half packaging statistics.
- **REPAK · H2 · 21 FEB · Jul–Dec statistics:** Second-half statistics are due 21 February of the following year under the published Repak training material.
- **PPWR · ART. 44 · 1 JUN · 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.
- **RE-TURN · MONTHLY · Placed-on-market volumes:** Registered Producers report in-scope products placed on the ROI market each month. CSV and Manual Input Reporting are available.

- **Plastic Bag Levy Q1:** 19 Apr
- **Plastic Bag Levy Q2:** 19 Jul
- **Plastic Bag Levy Q3:** 19 Oct
- **Plastic Bag Levy Q4:** 19 Jan following year

- **Plastic Bag Levy annual filing:** only where Revenue places a fully compliant retailer with <€1000 total levy over four consecutive quarters onto annual filing.

## What Beyoğlu operates

- Producer and Major Producer status mapping
- Ireland EPR-AR route analysis and onboarding coordination
- Article 44 register-transition monitoring
- Repak membership-class / tariff workflow coordination
- Re-turn route, product-registration and monthly-reporting coordination where applicable
- Regulatory cash separation and prefunding workflow
- Reporting calendar and evidence reconciliation
- Primary-source revalidation

## What the seller must own

- Truthful legal entity and transaction-chain information
- SKU/component/material packaging weights
- Irish turnover and tonnage evidence for the Major Producer test
- Approval of mandates and scheme contracts
- Current Re-turn product/barcode data where applicable
- Regulatory funding before due dates
- Signatures / attestations where legally required
- Prompt notification of material changes

## 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.

1. Producer assessment and transaction route
2. Irish Major Producer tonnage + turnover test
3. EPR AR legal decision and written mandate where applicable
4. Article 44 registration number / public record once operational
5. Repak membership class, member number and participation evidence
6. Packaging ledger by SKU / component / material / weight
7. Repak returns, invoices and payment evidence
8. Re-turn Producer / product registration and monthly reports where applicable
9. Re-turn deposit and producer-fee settlement records
10. Revenue Plastic Bag Levy registration / returns / payment where applicable
11. Marketplace submission, self-certification and verification correspondence
12. Technical PPWR conformity file kept separately

PPWR Article 45(4) requires in-scope online platforms to obtain the Producer's Article 44 registration information / number for the consumer's Member State plus a self-certification of EPR compliance before allowing the Producer to use the service. This verification layer does not decide who the Producer is.

Ireland's national Packaging Regulations contain offences and enforcement powers. Maximum statutory penalties are not automatic fines for every data error. Tie enforcement claims to the breached duty and current legal route; scheme-contract consequences remain separate from government penalties.

## 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.

- **Regulation (EU) 2025/40 · PPWR:** https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng — verified 2026-09-05
- **Procedure 2025/0395/COD:** https://eur-lex.europa.eu/procedure/EN/2025_395 — verified 2026-09-05
- **Commission Article 44 draft · Ares(2026)7688068:** https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/15352-Implementing-rules-on-registering-in-and-reporting-to-the-register-of-producers/F33544238_en — verified 2026-09-05
- **S.I. No. 282/2014 · Packaging Regulations:** https://www.irishstatutebook.ie/eli/2014/si/282/made/en/print — verified 2026-09-05
- **S.I. No. 659/2022 · 2022 amendment:** https://www.irishstatutebook.ie/eli/2022/si/659/made/en/pdf — verified 2026-09-05
- **EPA · Ireland packaging / PPWR future focus:** https://www.epa.ie/our-services/monitoring--assessment/waste/national-waste-statistics/packaging/ — verified 2026-09-05
- **Government · Repak approval through 2035:** https://www.gov.ie/en/department-of-climate-energy-and-the-environment/press-releases/minister-dillon-approves-10-year-licence-for-repak/ — verified 2026-09-05
- **Repak Regular Member Fees 2026:** https://repak.ie/images/uploads/downloads/Repak_Regular_Member_2026_Fees_Sheet.pdf — verified 2026-09-05
- **Repak Regular Member Guide 2026:** https://repak.ie/images/uploads/downloads/Repak_Regular_Member_2026_Fees_Sheet.pdf — verified 2026-09-05
- **Repak Statistical Returns Training:** https://repak.ie/images/uploads/downloads/QF%20509%20-%20Repak%20Statistical%20Returns%20Training.pdf — verified 2026-09-05
- **Re-turn · Producers:** https://re-turn.ie/producer/ — verified 2026-09-05
- **Re-turn Registration and Management Guide · July 2026:** https://media.re-turn.ie/wp-content/uploads/Re-turn-Registration-and-Management-Guide-v4.pdf — verified 2026-09-05
- **Re-turn Producer Fees Update · September 2023 · historical baseline only:** https://media.re-turn.ie/wp-content/uploads/2023/10/Producer-Fees-Updated-September-2023-2.pdf — verified 2026-09-05
- **S.I. No. 33/2024 · DRS Regulations:** https://www.irishstatutebook.ie/eli/2024/si/33/made/en/print — verified 2026-09-05
- **Revenue · Plastic Bag Environmental Levy:** https://www.revenue.ie/en/companies-and-charities/plastic-bag-environmental-levy/index.aspx — verified 2026-09-05
- **Revenue · Levy returns and deadlines:** https://www.revenue.ie/en/companies-and-charities/plastic-bag-environmental-levy/returns-payment-deadlines.aspx — verified 2026-09-05

## Ireland packaging EPR FAQ

### 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.

## Operational actions

- **Producer Status Checker:** Test the first-making-available transaction before selecting a scheme. — https://beyogluprofessional.com/tools/producer-status-checker
- **EU Country Obligation Checker:** Confirm whether Ireland is one of the Member States where you must act. — https://beyogluprofessional.com/tools/eu-country-obligation-checker
- **EPR AR Checker:** Separate the current EU cross-border rule from the third-country national check. — https://beyogluprofessional.com/tools/epr-ar-checker
- **Packaging Weight Calculator:** Convert Ireland SKU/component data into reportable material weights. — https://beyogluprofessional.com/tools/packaging-weight-calculator
- **EPR Cost Estimator:** Keep regulatory/system cash separate from service revenue. — https://beyogluprofessional.com/tools/epr-cost-estimator
- **Compliance Deadline Calculator:** Track Repak, Re-turn, Article 44 and levy clocks. — https://beyogluprofessional.com/tools/compliance-deadline-calculator
- **Official Sources:** Open authorities, legislation, registers and recognised systems. — https://beyogluprofessional.com/official-links
- **EU Country Matrix:** Compare Ireland's register, AR and system route against the other EU Member States. — https://beyogluprofessional.com/knowledge-hub/eu-country-matrix

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