You may already be unable to sell your own sauce to your own customers in France.

The 60-second version

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, applies from 12 August 2026. Article 45 says that if you sell into another EU country, you need a written mandate appointing someone legally on the hook for you there. The law calls this an authorised representative^[1]. Article 44 says that until you are registered, in that country specifically, you are not allowed to sell into it at all^[1].

There is no small-producer exemption. A 10-tonne packaging threshold exists, but it only lightens the paperwork once you are registered, it does not remove the registration or the representative^[2]. And registering is not instant: the competent authority has up to twelve weeks to grant it^[2], so a producer who starts today is not legally selling into that market again until roughly mid-November.

What it costs to fix this alone

A bundled multi-country compliance platform runs roughly €650 to €1,250 per country per year. Unbundled, a local agency per market runs €2,100 to €4,500 or more. Either way, multiply by every country you sell into. Plus €1,300 to €7,800 in one-off registration and notarisation costs in the first year.

The shape of the cost matters more than the total. It is fixed retainers and minimum-fee floors, not tonnage. A producer shipping 40kg a year pays close to what one shipping 4,000kg pays. Scale does not dilute this cost. It concentrates it on the smallest sellers.

The clock

10 Dec 2025

The Commission itself proposes suspending Article 45 until 2035 for EU-established producers.

Jun 2026

Council discontinues negotiations on that proposal. A large majority of Member States raised reservations.

12 Aug 2026

Article 44 and 45 apply. No suspension in force. This is where things stand today.

~1 Oct 2026

Parliament's ENVI committee is expected to vote on a narrower version, limited to micro and small enterprises. Indicative, not confirmed.

The Commission proposed its own fix and could not get it through Council in time^[3][4]. The obligation is not stuck behind a technicality. It is stuck behind a live disagreement between Member States.

Separately: the Commission’s own PPWR guidance, published nine days before the deadline, says enforcement will be warning-first rather than sanction-first in the immediate term^[5]. That is not the same as the law changing. Banks, distributors and marketplaces read the Regulation, not the guidance, and Article 45’s marketplace gate requires a registration number before a platform may let you sell at all. A platform will not carry that risk on your behalf.

What the Council is building instead

The alternative to twenty-seven separate registrations is one pooled one. Members hold stock, on consignment, at a single Council depot. Republic of Heat, the Council’s founding member, is the registered producer of record for that pooled stock and carries the compliance work in each market members actually sell into, rather than every maker separately finding, paying and managing their own representative in every country.

The same depot is doing double duty. Because stock is pooled, outbound shipping runs on pooled courier and groupage rates instead of one parcel at a time, and inbound stock from members ships in at the same pooled rate. Storage is quoted per bottle per year, at €0.70. On an average €8.84 bottle that is under 8% of what the bottle is worth.

Coverage is priced by how much of the EU a member actually needs, not a flat all-or-nothing fee. Founding-member terms, including the exact figures, are being finalised now with compliance providers directly, so the number quoted is a real one rather than a guess. Register interest below and the Council will follow up with founding-member pricing as it is confirmed.

Find out more about the depot, storage and compliance model