With the implementation of the PPWR, the requirements for foreign companies are also changing in Ireland and Italy. Packaging registrations are now possible and, where applicable, required for foreign companies without a local VAT number through an Authorised Representative for packaging.
The new requirements may be particularly relevant for foreign companies engaged in cross-border e-commerce that sell goods directly to end customers in Ireland or Italy. Based on the information currently available to us, the requirements in Italy appear to apply to e-commerce shops selling their products through online platforms. Foreign companies may join the EPR take back system “voluntarily” through an authorized representative, regardless of the distribution channel.
In Ireland all foreign distance sellers that sell their products online directly to end customers are obliged to appoint an Authorized representative and join a take back system..
Companies concerned must register for packaging in Italy and Ireland, participate in an appropriate take-back or EPR scheme, and regularly report the quantities of packaging placed on the market.