{"schema_version":1,"publisher":{"name":"TRADE MERIDIAN","url":"https://trademeridian.app"},"scope":"Packaging guidance reference summaries, not personalised market-access clearance","hash_definition":"SHA-256 of sorted JSON summary/provenance fields, excluding content_hash; not source webpage bytes","review_freshness_days":90,"references":[{"id":"ppwr-eu","jurisdiction":"EU","title":"When does PPWR apply, and does it replace national EPR checks?","summary":"Regulation (EU) 2025/40 is generally applicable from 12 August 2026, after entering into force on 11 February 2025. Some requirements have later deadlines or transitional provisions. It covers packaging across materials and origins. A Commission proposal to suspend certain cross-border authorised-representative obligations is still described as under examination; it is not treated here as an adopted exemption.","source_title":"European Commission — Packaging waste","source_url":"https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en","source_kind":"competent_authority_guidance","source_section":"Status, application date and Environmental Omnibus proposal","checked_at":"2026-10-02","general_application_date":"2026-08-12","date_note":"General application; individual requirements may differ.","uncertainty":"Packaging producer status depends on the seller’s establishment, supply-chain role, packaging and end user. Goods origin and HS code alone do not establish that status. Confirm current duties with the competent authority; fees and permission to sell remain unknown.","designated_reviewer":"Aleksey Kalinichenko","content_hash":"e2eb8abad5cae215466289eb98ef7f476ae265171c43190c322c18189747e44c","review_status":"approved","reviewer":"Aleksey Kalinichenko","reviewed_at":"2026-10-02T10:37:33.755844+00:00","url":"https://trademeridian.app/guides/ppwr-eu","applicability_status":"case_review_required","fee":null},{"id":"packaging-epr-germany","jurisdiction":"DE","title":"What packaging checks matter for sales to Germany?","summary":"Producers under PPWR must register in LUCID; registration itself is free. The current ZSVR registration guidance requires an authorised representative for a foreign business selling empty packaging or packaged goods directly to German end users without a German branch. Packaging subject to system participation also requires a system agreement and volume reporting. Registration is distinct from those paid arrangements.","source_title":"ZSVR — Registering with LUCID","source_url":"https://www.verpackungsregister.org/en/registration/find-out-about-registrations","source_kind":"competent_authority_guidance","source_section":"Producer role; master data; system participation and data reporting","checked_at":"2026-10-02","general_application_date":null,"date_note":"Current administrative guidance checked on 2 October 2026; no statutory commencement date inferred.","uncertainty":"Packaging producer status depends on the seller’s establishment, supply-chain role, packaging and end user. Goods origin and HS code alone do not establish that status. Confirm current duties with the competent authority; fees and permission to sell remain unknown.","designated_reviewer":"Aleksey Kalinichenko","content_hash":"a7bd7c38c6d06350fa93c231d87886d06012756db7bee6f34a17c513dc658dc8","review_status":"approved","reviewer":"Aleksey Kalinichenko","reviewed_at":"2026-10-02T10:37:33.755844+00:00","url":"https://trademeridian.app/guides/packaging-epr-germany","applicability_status":"case_review_required","fee":null},{"id":"packaging-epr-france","jurisdiction":"FR","title":"What does packaging REP in France require checking?","summary":"Businesses subject to a French REP stream must use an approved eco-organisation or approved individual system, obtain an IDU and submit annual declarations. Household packaging is one stream; products may trigger separate streams. Identify the relevant producer and packaging stream before applying this framework. This source describes the general REP framework rather than resolving every 2026 PPWR transition.","source_title":"Service Public Entreprendre — Filières REP","source_url":"https://entreprendre.service-public.gouv.fr/vosdroits/F37937","source_kind":"competent_authority_guidance","source_section":"Relevant enterprises; obligations; IDU and annual declaration","checked_at":"2026-10-02","general_application_date":null,"date_note":"Source marked verified 4 August 2025; checked 2 October 2026. National PPWR transition and professional-packaging rollout require separate confirmation.","uncertainty":"Packaging producer status depends on the seller’s establishment, supply-chain role, packaging and end user. Goods origin and HS code alone do not establish that status. Confirm current duties with the competent authority; fees and permission to sell remain unknown.","designated_reviewer":"Aleksey Kalinichenko","content_hash":"a472aca8c588ff66dee8f1e2eabcd4e2e5b40419c16662e19b8f9bd9e5101216","review_status":"approved","reviewer":"Aleksey Kalinichenko","reviewed_at":"2026-10-02T10:37:33.755844+00:00","url":"https://trademeridian.app/guides/packaging-epr-france","applicability_status":"case_review_required","fee":null},{"id":"packaging-epr-spain","jurisdiction":"ES","title":"What packaging registration checks matter in Spain?","summary":"MITECO provides the packaging section of the Product Producer Register and registration/reporting guidance. Foreign producers supplying packaged goods directly to Spanish end users must check authorised-representative arrangements and the exception for a Spanish subsidiary. The ministry describes different 2026 reporting periods according to whether the business remains, ceases to be, or becomes a producer under PPWR. Determine that role before selecting a reporting period.","source_title":"MITECO — Registro de productores, envases","source_url":"https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/prevencion-y-gestion-residuos/registro-productores-producto/registro-productores-producto-seccion-envases.html","source_kind":"competent_authority_guidance","source_section":"Registration; foreign producers; 2026 reporting transition","checked_at":"2026-10-02","general_application_date":null,"date_note":"Checked 2 October 2026. Reporting ranges around 12/13 August are not a replacement for the EU general application date.","uncertainty":"Packaging producer status depends on the seller’s establishment, supply-chain role, packaging and end user. Goods origin and HS code alone do not establish that status. Confirm current duties with the competent authority; fees and permission to sell remain unknown.","designated_reviewer":"Aleksey Kalinichenko","content_hash":"549caaff796945052df66d00678983882e96a0a1846a309e4033dd6efd0e3346","review_status":"approved","reviewer":"Aleksey Kalinichenko","reviewed_at":"2026-10-02T10:37:33.755844+00:00","url":"https://trademeridian.app/guides/packaging-epr-spain","applicability_status":"case_review_required","fee":null},{"id":"packaging-epr-italy","jurisdiction":"IT","title":"What should an importer check about Italian packaging contributions?","summary":"CONAI describes declaration and payment obligations for parties liable for the packaging environmental contribution. Procedures depend on packaging materials, empty or filled packaging, imports and destination; filing frequency and exemptions vary. A seller should establish its liable role and the applicable procedure before estimating a contribution. This reference does not conclude that every foreign online seller owes an identical CONAI fee.","source_title":"CONAI — Declaration and payment","source_url":"https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/declaration-and-payment/","source_kind":"producer_responsibility_organisation_guidance","source_section":"Liable parties; imported packaging; declaration frequency","checked_at":"2026-10-02","general_application_date":null,"date_note":"Current consortium procedure checked 2 October 2026; foreign-seller PPWR/representative procedure requires case-specific confirmation.","uncertainty":"Packaging producer status depends on the seller’s establishment, supply-chain role, packaging and end user. Goods origin and HS code alone do not establish that status. Confirm current duties with the competent authority; fees and permission to sell remain unknown.","designated_reviewer":"Aleksey Kalinichenko","content_hash":"00fe74573fee52547af752122abd81d44a30ad6b0bb0d17f26e5c6e7c35e38f6","review_status":"approved","reviewer":"Aleksey Kalinichenko","reviewed_at":"2026-10-02T10:37:33.755844+00:00","url":"https://trademeridian.app/guides/packaging-epr-italy","applicability_status":"case_review_required","fee":null},{"id":"packaging-epr-netherlands","jurisdiction":"NL","title":"Does the Dutch 50,000 kg threshold remove all packaging duties?","summary":"RVO describes packaging EPR duties for manufacturers and importers and requires businesses to determine their role in the packaging chain. Its guidance says bringing at least 50,000 kg of packaging onto the Dutch market in a calendar year triggers Verpact contribution and reporting duties. That threshold is not treated as a blanket exemption from every packaging duty below it.","source_title":"Netherlands Enterprise Agency (RVO) — Requirements for packaging","source_url":"https://business.gov.nl/regulations/packaging/","source_kind":"competent_authority_guidance","source_section":"Packaging-chain role; waste management contribution and reporting","checked_at":"2026-10-02","general_application_date":null,"date_note":"Page marked checked 25 March 2026 and includes PPWR amendment dated 12 August 2026; checked 2 October 2026. Special streams and foreign-distance-seller procedures need confirmation.","uncertainty":"Packaging producer status depends on the seller’s establishment, supply-chain role, packaging and end user. Goods origin and HS code alone do not establish that status. Confirm current duties with the competent authority; fees and permission to sell remain unknown.","designated_reviewer":"Aleksey Kalinichenko","content_hash":"7d2165e0ed0c79e8b22a3622af3d50ad51190ab565adeeed4d2e5425a6a3d849","review_status":"approved","reviewer":"Aleksey Kalinichenko","reviewed_at":"2026-10-02T10:37:33.755844+00:00","url":"https://trademeridian.app/guides/packaging-epr-netherlands","applicability_status":"case_review_required","fee":null}]}