BEYOĞLU PROFESSIONAL PPWR-EPR COMPLIANCE SERVICES
Free Workspace Check My EU Scope
Repak approved to 2035Re-turn livePPWR appliesRegulatory review · 28 Aug 2026

Ireland Packaging EPR · PPWR 2026

Ireland EPR Authorized Representative & Packaging Compliance Producer first. Register transition. Repak. Re-turn. Marketplace proof.

Ireland combines an established national packaging regime with the directly applicable PPWR. The operating task is to distinguish the legacy Irish “Major Producer” threshold from PPWR registration and reporting, determine whether an Ireland-established EPR representative is required, connect Repak and Re-turn where relevant, and fund the correct regulatory cash before reporting or payment dates.

Start Free AssessmentOpen Free Workspace

The Ireland route

What must a foreign SME solve before the first Irish sale?

Operating thesisProducer → AR decision → register route → Repak → conditional DRS / levy → regulatory cash → report → proof.

The same legal entity, Irish sales route, packaging dataset and reporting scope should reconcile across PPWR registration, Repak, Re-turn, Revenue and marketplace evidence.

01

Define the Irish transaction

Direct end-user sale, Irish importer, marketplace, private label, local fulfilment or professional supply.

Input · commercial route
02

Determine the Producer

Apply the PPWR producer definition first; then map the remaining Irish national packaging obligations.

Output · Producer position
03

Decide AR + registration

Test Article 45(3), third-country status and the current Irish Article 44 register implementation route.

Output · representation + register plan
04

Connect Repak / Re-turn

Use the correct Repak membership route and add Re-turn only for in-scope beverage containers.

Output · financed EPR route
05

Operate data → cash → proof

Maintain material weights, returns, invoices, deposits, levy records and marketplace-ready evidence.

Output · recurring Ireland file
Threshold trap

10 tonnes means two different things.

The Irish legacy test uses more than 10 tonnes together with turnover above €1 million to define a Major Producer. PPWR Article 44 uses less than 10 tonnes for simplified reporting. Neither rule should be converted into a generic “no EPR below 10 t” statement.

Register transition

Repak membership is not automatically the Article 44 register.

Repak proves scheme participation. The final PPWR producer-register route must be identified from the Irish competent authority implementation rather than inferred from the legacy scheme.

AR status

The proposed Article 45 suspension is not law.

COM(2025) 982 remains in an ongoing legislative procedure. The page therefore operates the current PPWR text and flags any Ireland-specific implementation point that still requires confirmation.

Next · Understand the Irish terms →

First understand the Irish names

Eight terms. Eight different compliance functions.

The national scheme, Major Producer threshold, PPWR register, deposit system and Revenue levy are separate legal or operating layers.

Producer

PPWR packaging Producer

Article 3(15)

The entity that first makes relevant packaging or packaged products available in Ireland under the PPWR transaction tests.

Major Producer

Irish legacy threshold status

Packaging Regulations

A national category based on packaging tonnage and Irish turnover. It is not identical to the PPWR Producer concept.

EPR AR

EPR Authorised Representative

PPWR Chapter VIII

An Ireland-established natural or legal person appointed by written mandate where the applicable Article 45 route requires it.

Article 44

PPWR Producer Register

National register infrastructure

The PPWR register that monitors producer compliance. Ireland’s final operational route is treated here as a transition item until officially confirmed.

Repak

Packaging EPR approved body

Approved through 2035

Ireland’s packaging EPR scheme operator. For current Major Producers, approved-body membership is mandatory under the national rules.

Regular Member

Repak supply-chain membership

Brandholder / Importer tariff

The relevant Repak route for many importers and brandholders, with published material fees by supply-chain stage.

Re-turn

Deposit Return Scheme

Republic of Ireland DRS

A separate producer, product-registration, reporting and deposit route for in-scope PET bottles and aluminium/steel cans.

E-Levy

Plastic Bag Environmental Levy

Revenue

A conditional €0.22 shopping-bag levy charged at point of sale and remitted to Revenue; it is not a Repak contribution.

Do not merge the layers

EPR AR ≠ Manufacturer AR.

This page operates the packaging-EPR route: Producer, representation, registration, EPR scheme, regulatory charges, reporting and evidence. Technical PPWR conformity, manufacturer documentation, recyclability, material restrictions and product-safety representation remain separate compliance layers.

Next · Determine the Irish Producer →

01 · Who is the Irish Producer?

Start with who first makes the packaging available in Ireland — not where the seller is incorporated.

PPWR Article 3(15) reaches cross-border sales directly to end users. Ireland’s legacy Packaging Regulations use their own “producer” and “Major Producer” concepts, so the operating file should record both analyses without merging them.

Route A

EU seller → Irish end user

An EU-established seller supplies packaged products directly into Ireland. It can be the PPWR Producer in Ireland and the current Article 45(3) EPR-AR rule must be tested.

Producer + AR route
Route B

Third-country seller → Irish end user

A UK, Turkish, US, Chinese or other third-country seller can itself be the PPWR Producer. Ireland may impose an EPR-AR requirement, but a blanket Irish packaging rule is not asserted here without national confirmation.

Producer + national AR check
Route C

Foreign supplier → Irish importer

If an Irish importer is the operator first making the packaged product available in Ireland, the producer position may sit with that Irish entity instead of the foreign supplier.

Supply-chain dependent
Route D

Private label / own brand

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

Principal must be tested
Producer first. Marketplace account ownership, VAT registration, fulfilment location and brand ownership are relevant facts but none replaces the PPWR Producer test.
Irish national Major Producer test>10 tonnes + >€1m turnover

Under the legacy Irish Packaging Regulations, both packaging supplied in the State and Irish turnover criteria are relevant. Since 1 January 2023, a Major Producer must be a member of an approved body.

PPWR Article 44 reporting test<10 tonnes = simplified reporting

PPWR Article 44(8) changes the reporting data set for producers below 10 tonnes. It does not say that those producers cease to be Producers or become exempt from EPR.

PPWR · EUR-Lex ↗Irish Packaging Regulations ↗2022 amendment ↗
Next · Ireland EPR Authorised Representative →

02 · Ireland EPR Authorised Representative

Current EU law creates one clear route and one Ireland-specific question.

Article 45(3) is directly applicable while the proposed suspension remains unadopted. The current text distinguishes producers established in another Member State from producers established in third countries.

Current PPWR rule

EU-established cross-border Producer

A Producer falling within Article 3(15)(c) or (d) must appoint, by written mandate, an EPR Authorised Representative in each other Member State where it first makes packaging or packaged products available. The EPR AR must be established in the Member State concerned — Ireland for the Irish route.

Status: operate as mandatory under the current PPWR text unless and until EU law changes.

National implementation check

Third-country Producer

PPWR allows Member States to require a third-country Producer to appoint an EPR AR. In the official packaging sources reviewed for Ireland, a blanket third-country packaging-AR requirement under the PPWR implementation route was not located.

Operating status: national authority / implementation confirmation before onboarding. Do not copy WEEE, battery or tobacco-filter AR rules into packaging.

Established where?Ireland

The EPR AR definition requires establishment in the Member State for which the representative is appointed.

Natural or legal person?Either can qualify

Subject to the PPWR definition and the Irish operational implementation route.

MandateWritten mandate

Article 45(3) expressly requires the appointment by written mandate.

Seller duties remainData · funding · truthfulness

The Producer must still supply accurate packaging data, fund obligations and maintain evidence.

Legislative proposal ≠ binding law. COM(2025) 982 proposes to suspend application of the packaging EPR-AR appointment rule, but procedure 2025/0395/COD remains ongoing at this review date. This page therefore does not behave as if the suspension were already adopted.
Article 45 · EUR-Lex ↗2025/0395/COD status ↗
Next · Registration / Register →

03 · Registration / Registry

Treat Ireland as a PPWR register transition — not as a blank country and not as a finished Article 44 portal.

Article 44 requires registration before first making packaging available. At the same time, Ireland already has Repak membership infrastructure and legacy national packaging rules. These evidence classes must remain distinct.

01

Article 44 duty

The Producer may not first make packaging available in Ireland if the Producer — or applicable EPR AR — is not registered in the national Article 44 register.

02

Who can file?

PPWR allows national law to place registration filing with the Producer, EPR AR or entrusted PRO. The Irish implementation route must decide the operational filer.

03

Repak evidence

Repak membership number/certificate and public member evidence demonstrate scheme participation, but are not relabelled here as the final Article 44 producer-register record.

04

DRS evidence

If beverage containers are in scope, Re-turn Producer and product registration are separate from packaging EPR registration and Repak participation.

Register proof

Article 44 registration number

Keep the Irish national registration record and registration number once the final operating route is available.

Scheme proof

Repak membership evidence

Membership certificate / number, current membership category, tariff version, declarations and invoices.

Representation proof

AR mandate + acceptance

Where applicable, preserve the written mandate, representative details and any register evidence linking the representative to the Producer.

Public evidence chain: Article 44 registration proof ≠ Repak participation proof ≠ Re-turn product registration ≠ payment proof ≠ marketplace approval. Keep them linked but separately identifiable.
Next · Repak / Systems →

04 · PRO / System architecture

Ireland is not a Germany-style operator marketplace. Start with Repak — then add Re-turn only where the packaging stream requires it.

Repak received a new approval in January 2026 to continue operating Ireland’s packaging EPR scheme through 2035. The operating decision is therefore membership eligibility and tariff stage, not invented multi-PRO bidding.

Packaging EPR

Repak

The approved packaging EPR body. Since 1 January 2023, an Irish “Major Producer” must be a member of an approved body. Repak Regular Membership uses supply-chain-stage material fees; the Brandholder / Importer stage is the relevant published basis for many foreign sellers that first place packaged goods on the Irish market.

  • Approval period: through 2035
  • Current public fee sheet: H1/H2 2026
  • Material-by-material declarations
  • Regular vs Scheduled membership must be classified correctly
  • Scheme participation remains separate from PPWR Article 44 registration
Separate beverage DRS

Re-turn

Re-turn is the Republic of Ireland Deposit Return Scheme for in-scope PET plastic bottles and aluminium/steel cans from 150 ml to 3 litres. If you import an in-scope product and are first to place it on the ROI market, Re-turn treats you as the Producer for that DRS route.

  • Producer registration
  • Product / barcode registration
  • Monthly placed-on-market reporting
  • Producer fee under current agreement / guide
  • Refundable €0.15 / €0.25 consumer deposit
01Legal eligibility

Producer and Major Producer status.

02Membership type

Regular vs Scheduled route.

03Supply-chain stage

Brandholder / Importer or other stage.

04DRS overlay

Add Re-turn only for in-scope containers.

05Seller approval

Contract, current tariff, data and cash plan.

Scheduled Membership is not a generic low-volume route. Repak describes it for specified direct-to-consumer retailers and excludes importers, brandholders and manufacturers. A foreign importer/brandholder should not be pushed into Scheduled Membership merely because it is small.

05 · Regulatory Charges, Contributions & Taxes

Separate Repak contributions, Re-turn deposits, Revenue levies, representative costs and Beyoğlu service revenue.

Ireland has calculable public and scheme charges, but they do not share one legal nature. The calculator below preserves that separation.

PRO / system

Repak 2026 contribution

Published Regular Member material contribution. Calculator scope: Brandholder / Importer stage.

PayeeRepak
Basis€/tonne by material
FrequencyH1 / H2 reporting model
VATFees exclusive; apply invoice treatment
Refundable deposit

Re-turn DRS deposit

€0.15 for containers up to 500 ml and €0.25 for containers over 500 ml to 3 L. This is circulating refundable cash, not an EPR expense.

Payee/flowRe-turn scheme cash flow
BasisPer in-scope container
Expense?No — show separately
DRS producer fee

Re-turn producer fee

A per-container producer fee applies under the scheme. Because the current producer-fee guide/agreement controls, the calculator uses your verified current PET and metal rates instead of freezing an older rate.

PayeeRe-turn
BasisUnit × current verified rate
TariffCurrent agreement / guide
Statutory levy

Plastic Bag Environmental Levy

Retailers supplying covered plastic shopping bags charge €0.22 per bag and remit it to Revenue. The levy is not subject to VAT.

PayeeRevenue
Rate€0.22 / covered bag
FilingQuarterly; 19th following period
Representative

Ireland EPR AR service

Where an Ireland-established statutory EPR AR is required, the representative fee is a commercial service charge — not a Repak or government tariff.

PayeeAppointed Irish AR provider
BasisVerified commercial quote
Beyoğlu roleOnboarding coordination
Beyoğlu Professional

Operating coordination

Country onboarding €25 plus €1 per qualifying parcel. These are professional-service fees and never presented as the total Irish compliance cost.

RevenueBeyoğlu Professional
Onboarding€25
Parcel operation€1 / qualifying parcel
Repak 2026 materialBrandholder / Importer €/tonne
Recycled paper / cardboard€41.60
Recycled glass€19.14
Recycled aluminium — non-DRS€5.14
Recycled steel — non-DRS€64.76
Recycled rigid plastic€165.70
Recycled flexible plastic€165.70
Non-recycled plastic€616.22
PET beverage bottles — non-DRS€165.70
Other plastic beverage bottles€165.70
Plastic non-beverage bottles€165.70
Recycled wood€14.18
Recycled composite€165.70
Non-recycled composite€616.22
Non-recycled other€324.06
Tariff scope: these are Repak’s published 2026 Regular Member rates for the Brandholder / Importer supply-chain stage. They are not a government “Ireland €/kg tax”, and they should not be applied to a different Repak membership class without checking that class.

06 · Ireland first-year cash calculator

Calculate what is published. Enter what is quote-only. Keep refundable deposits outside operating expense.

This calculator estimates Repak contribution using the published 2026 Brandholder / Importer tariff, tests the legacy Major Producer threshold, and separately models DRS, plastic-bag levy, AR, third-party and Beyoğlu cash.

Operating inputs

Enter annual Republic of Ireland quantities. Use zero for materials or conditional schemes outside your route.

Legacy threshold test

Repak 2026 · Brandholder / Importer kilograms

Cash-planning assumption only. Follow the actual invoice/tax treatment.

Re-turn DRS · conditional

Other cash layers

Calculator applies €0.22/bag; VAT 0%.
Next · Reporting & Payment →

07 · Reporting & Payment

Ireland has several clocks. Build one operating calendar instead of treating “annual EPR reporting” as the whole job.

Repak statistics, PPWR Article 44 reporting, Re-turn monthly data and the Plastic Bag Levy have different recipients, periods and payment mechanics.

Repak · H1Jan–Jun → 21 Aug

Published Repak training instructs members to submit first-half packaging statistics by 21 August. Repak issues two membership invoices per year, in January and July.

Repak · H2Jul–Dec → 21 Feb

Second-half packaging statistics are submitted by 21 February of the following year. Published scheme material uses 30-day payment terms unless otherwise advised.

PPWR Article 44Previous year → 1 Jun

PPWR reporting is due by 1 June for each full preceding calendar year. Producers under 10 tonnes use the simplified Annex IX data set; Ireland’s operational portal route must still be confirmed.

Re-turnMonthly

Producers report in-scope products placed on the ROI market monthly. Use the current Producer Membership Agreement / portal for the controlling monthly cut-off and invoice terms.

Plastic Bag Levy · Q119 April

Jan–Mar return + payment.

Q219 July

Apr–Jun return + payment.

Q319 October

Jul–Sep return + payment.

Q419 January

Oct–Dec return + payment. Revenue may place qualifying low-liability compliant retailers on annual filing.

Invoice date controls cash. Repak’s published training and Scheme Rules refer to 30-day payment timing, while Re-turn producer fees/deposits operate under the current producer agreement. Keep the actual contract and invoice terms in the evidence file rather than relying only on a web summary.

08 · Who does what?

Coordination can be outsourced. Producer truth, approvals and regulatory funding cannot be invented for the seller.

The operating model separates the seller, statutory EPR representative where applicable, Irish schemes / authorities and Beyoğlu Professional.

SE

Seller / Producer

The economic operator whose transaction creates the Irish Producer position.

  • Provides truthful legal and sales-route data
  • Maintains packaging/SKU weights
  • Approves mandate and scheme contracts
  • Funds regulatory amounts before due date
  • Signs / attests where legally required
  • Notifies material changes
AR

Ireland EPR AR

An Ireland-established representative only where the valid legal route requires or permits one.

  • Acts under written mandate
  • Performs delegated Chapter VIII duties
  • May support register/reporting route where Irish law allows
  • Maintains representative evidence
  • Does not become manufacturer AR by default
IE

Repak · Re-turn · Revenue

Separate Irish scheme and public-payment counterparties.

  • Repak: packaging EPR participation
  • Re-turn: beverage DRS
  • Revenue: plastic-bag levy
  • Competent authority: Article 44 register
  • Local authorities / EPA: enforcement roles
BP

Beyoğlu Professional

The operating coordination layer — not the regulatory payee.

  • Producer determination
  • AR route mapping + onboarding coordination
  • Register-transition monitoring
  • Repak / Re-turn workflow coordination
  • Calculator + prefunding plan
  • Reporting calendar + evidence management
  • Recurring source revalidation
Regulatory Prefunding: seller → safeguarded regulatory funding balance / legally appropriate payment infrastructure → Repak, Re-turn, Revenue or other statutory payee. Regulatory money is not Beyoğlu Professional revenue and should not be financed from our operating working capital.
Marketplace evidence

Build marketplace proof after the Producer decision.

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

1 · Register proofArticle 44 Irish registration number / record once the operational route is live.
2 · Scheme proofRepak membership certificate / member number, declarations and current participation evidence.
3 · Representation proofEPR AR mandate, acceptance and linked registration evidence where applicable.
4 · DRS proofRe-turn Producer and product registration, current product approvals and reporting records where applicable.
5 · Payment proofRepak / Re-turn / Revenue invoices, returns, deposits and settlement evidence.
6 · Marketplace proofPlatform submission, verification result and material correspondence.
Register proof ≠ scheme proof ≠ payment proof ≠ marketplace approval. Store all four evidence classes without collapsing them into one “EPR certificate”.

What should remain in the Ireland evidence file?

Producer assessmentLegal entity, transaction route, end-user destination and PPWR Producer conclusion.
Major Producer testIrish packaging tonnage, Irish turnover and calculation period.
AR decisionEU/third-country analysis, legal basis and national implementation note.
Mandate + acceptanceSigned mandate and Ireland-established representative evidence where applicable.
Article 44 registerApplication, registration number, public record and update history once operational.
Repak fileMembership class, member number, tariff version, returns, invoices and payments.
Packaging ledgerSKU, component, material, mass, units, Irish classification and period.
Re-turn fileProducer / product registration, barcodes, monthly reports, deposits and invoices where applicable.
Revenue levy filePlastic-bag registration, returns and payment proof where applicable.
Regulatory fundingPrefunding instructions, safeguarded payment record and reconciliation.
Marketplace recordRegistration information supplied, self-certification, approval/review and correspondence.
Technical PPWR fileKept separately: conformity, restrictions, recyclability, minimisation and technical documentation.

Enforcement exposure

Irish Packaging Regulations contain criminal offences. Maximum penalties are not automatic fines for every compliance mistake.

Enforcement should be tied to the breached duty and the applicable legal route. Local authorities and the EPA have enforcement roles under the national packaging framework.

National Packaging RegulationsContravention / failure

Contravening or failing to comply with the Regulations can constitute an offence, as can materially false/misleading information or obstruction of authorised functions.

Maximum indictment routeUp to €500,000 / 3 years

For offences to which the indictment route applies, the Regulations provide a maximum fine of €500,000 and/or imprisonment up to three years. This is a statutory maximum, not the default outcome.

Commercial verificationPlatform EPR checks

PPWR requires certain online platforms to collect registration and self-certification information. Platform-specific restriction or delisting outcomes must be verified from each marketplace’s own current policy.

Repak contract consequences are separate. Late/incorrect statistical returns, late fees, back fees or scheme-level sanctions should be read from the current Repak Scheme Rules and member contract, rather than described as government fines.

Primary sources

Verify Ireland from EU law, Irish legislation, government approval, the scheme operator, DRS operator and Revenue.

The links below are claim-level operating sources. They are not a substitute for applying the source to the seller’s exact transaction and establishment.

Binding EU law

Regulation (EU) 2025/40 · PPWR

Producer, Article 44 register/reporting, EPR AR, PRO and marketplace verification.

EUR-Lex ↗Legislative status

Procedure 2025/0395/COD

Current status of the proposal to suspend EPR-AR appointment rules.

EUR-Lex ↗National law

S.I. No. 282/2014

Irish Packaging Regulations: producer, Major Producer and enforcement architecture.

Irish Statute Book ↗National amendment

S.I. No. 659/2022

From 1 January 2023 a Major Producer must be a member of an approved body.

Irish Statute Book ↗Government approval

Repak approval to 2035

16 January 2026 approval to continue Ireland’s packaging EPR scheme.

gov.ie ↗Published 2026 tariff

Repak Regular Member Fees 2026

Supply-chain-stage material fees used by the page calculator.

Repak ↗DRS operator

Re-turn · Producers

Producer/importer status, registration, in-scope containers and deposit obligations.

Re-turn ↗Tax authority

Plastic Bag Environmental Levy

Current €0.22 rate, VAT treatment and retailer obligation.

Revenue ↗Tax authority

Levy returns & deadlines

Quarterly 19th-day filing/payment and conditional annual-filing route.

Revenue ↗

Operate Ireland from one compliance account.

Map the Producer, representation route, Article 44 transition, Repak class, conditional Re-turn / Revenue layers, regulatory cash, reporting and evidence before the first shipment creates an avoidable compliance gap.

Start Free AssessmentOpen Free Workspace