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Entitlement · EPR-04

A producer whose fulfilment service is suspended for an EPR information failure may challenge that decision before a court in the Member State where the fulfilment service provider is established.

Producers whose fulfilment service has been suspended are given a right, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 45(9), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 12 August 2026 (Art. 71). as of 2026-08-18
  • It names 7 industries by name: Plastics converting, Paper and board, Glass, Aluminium, Wood, Food and drink and Retail. as of 2026-08-18
  • Compliance is checked by national court, per suspension. as of 2026-08-18
Addressee Producers whose fulfilment service has been suspendedAct Regulation (EU) 2025/40, base actArticle Art. 45(9)Class Businesses

What changes

Producers dependent on third-party fulfilment. Linked to EPR-03 by provision_id: the same provision creates a private enforcement power and the remedy against it, and neither reading contains the other.

The rule

New — no predecessor
Trigger

suspension of a fulfilment service under Art. 45(8)

Entitlement

A producer whose fulfilment service is suspended for an EPR information failure may challenge that decision before a court in the Member State where the fulfilment service provider is established.

Who is affected

Addressee
Producers whose fulfilment service has been suspended
Class
Businesses
Sectors
Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products, Food, drink and tobacco, Retail and distribution
Applies
From 12 August 2026 (Art. 71)

Burden drivers

No burden drivers recorded on this provision.

No size threshold.

Source text

Verbatim

the producer concerned shall have the right to challenge the decision of the fulfilment service provider before a court in a Member State in which the fulfilment service provider is established.

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