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EU EPR Obligations explained.
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Extended Producer Responsibility is law across all EU member states. If you sell products into any EU market — via Amazon, eBay, or your own store — you typically need EPR registration in every country you sell to: WEEE, packaging, battery. We handle the full process across 30+ countries. Powered by Certify GmbH.
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📌 EU Packaging Regulation (PPWR) — in force since 12 August 2026: what applies now
Regulation (EU) 2025/40 (PPWR) entered into force on 11 February 2025 and applies since 12 August 2026. It generally repeals the Packaging Directive 94/62/EC (some provisions continue) and applies directly in all 27 EU member states, supplemented by national laws such as Germany's VerpackDG. What has not changed: you still register in each country's producer register (LUCID in Germany, national equivalents elsewhere), join a compliance scheme and report your volumes.
- New EU-wide (Art. 45): producers — EU or non-EU — who sell packaged products directly to end users in another member state must appoint an authorized representative there; for other non-EU producers, member states may require one. In Germany this applies only to producers without a German branch who sell directly to end users; the representative confirms the mandate in LUCID, and the registration stays with the producer.
- Marketplaces: Amazon and eBay check packaging EPR numbers per destination country; eBay may hide listings without one. Amazon's "Pay on Behalf" is a fallback that does not replace your own registration or legal responsibility.
- Next dates: 12 November 2026 — update German LUCID registration data · 31 December 2026 — German dual-system contracts concluded before 12 August 2026 end at the latest · 12 February 2027 — member-state penalty rules due; PPWR-related fines apply in Germany · 17 May 2027 — German completeness declaration 2026 (one declaration under § 10 VerpackDG, with 2026 data broken down per the old VerpackG rules; 15 May falls on a Saturday). Fee modulation by recyclability already applies nationally (Germany, France, UK); EU-harmonised modulation is expected around 2028–2030.
- Proposal – not yet law Representative exemption: the Environmental Omnibus (COM(2025) 982) would exempt EU-established producers from the representative duty. The Council's position of 21 October 2026 covers producers placing under 1 tonne of packaging a year in another member state, until 2032; the European Parliament voted on 20 October 2026 for an exemption for EU micro and small enterprises until 2035. Trilogue is next. It is not law, and it does not cover non-EU sellers. Meanwhile the Commission asks member states to enforce the representative duty in a "constructive and pragmatic" way.
What this guide covers
This page provides a structured overview of your legal EPR duties as a producer selling into EU markets. We cover the full breakdown of obligations by category, the EU rules that apply, how each country enforces them, penalty frameworks including fines, bans and marketplace delisting, and country guides for 14 markets — from Germany, France and Italy to Sweden, Ireland and the UK.
Legally compliant with CERTIFY — reduce risks & save resources
Non-compliance with EPR obligations can lead to severe penalties: in Germany fines of up to €200,000 depending on the offence, deactivated or hidden marketplace listings, and sales bans. Working with Certify helps you avoid these risks.
We reduce complexity, eliminate language barriers, and handle all regulatory processes centrally — so you can focus on growing your business while staying fully compliant.
What our clients say
"I'm really glad I found Certify. They handled my LUCID and EAR registration competently and very friendly. I can focus on my business now."
— Alexander S., Amazon Seller
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"What a competent and friendly contact! They helped us navigate the recycling and registration chaos perfectly. Highly recommended!"
— Andre R., E-Commerce Brand Owner
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"Perfect! Top advice and service. Certify takes care of everything so we can trade legally across European markets. All thumbs up!"
— Richard W., International Distributor
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— Sebastian S., Online Retailer
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Who carries EPR obligations?
- Manufacturers selling regulated products domestically in EU countries
- Importers bringing products into an EU member state
- E-commerce and marketplace sellers shipping cross-border into the EU
- Brand owners — even if manufacturing is outsourced (white label / OEM)
- Any company placing packaged products on EU markets
Compliance roadmap — 3 steps to fulfilling your obligations
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1
Obligation mapping
Define your product categories, target countries and role in the supply chain. Identify which legal obligations apply, in which jurisdictions, and by what deadlines.
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2
Registration & scheme selection
Complete mandatory registrations, appoint authorized representatives where required, and establish a reporting calendar aligned with statutory deadlines. You receive your registration numbers — ready to submit to Amazon and other marketplaces.
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3
Ongoing reporting & legal monitoring
Submit quantity declarations on time, maintain accurate documentation, and track legislative changes across all relevant jurisdictions. You provide the volume data — the compliance obligations are managed on your behalf.
The three main EPR obligation categories
Most sellers in the EU face obligations across multiple categories simultaneously. Missing even one registration can result in listing suspension or fines.
WEEE Obligations (Electronics)
Selling electronics, chargers, lighting or battery-powered devices in the EU? You must register with national WEEE authorities and contribute to certified take-back systems. Germany: Stiftung EAR / ear-Register. Mandatory before your first sale — checked by Amazon.de.
Check my WEEE obligations →Packaging Obligations (LUCID)
Any seller shipping packaged goods into EU markets must register with national packaging schemes and pay eco-fees. In Germany: LUCID registration (ZSVR) and dual-system participation — mandatory before your first shipment, checked by Amazon.de.
Check my packaging obligations →Battery Obligations (EU 2023/1542)
Products containing batteries require separate EPR registration under the EU Battery Regulation, whose EPR regime has applied since 18 August 2025. National registers (in Germany: stiftung ear) record producers, and marketplaces may ask for your battery registration number.
Check my battery obligations →⚠️ Marketplaces check EPR numbers — non-compliant offers may be removed
In a notice of 25 March 2026, Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 — naming Germany, France, Italy, Spain, the Netherlands, Sweden, Poland, Ireland and Belgium, plus Austria and Denmark for cross-border sales — and said it may need to stop selling non-compliant products. eBay requires packaging EPR numbers per country since 12 August 2026; listings without one may be hidden to buyers there.
What you need: LUCID number for packaging · EAR number for electronics · Battery registration per country. We handle all three for you — see the Amazon EPR number guide →
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EPR obligations – the legal duties in detail
EPR makes the entity placing goods on the market legally and financially responsible for their end-of-life phase. Obligations are triggered per country and per product category — and must typically be fulfilled before you are permitted to sell.
What exactly is a producer's EPR obligation?
Under EPR legislation, the "producer" — the entity that places regulated products on a market — is legally obligated to take financial and organisational responsibility for those products once they reach end-of-life. This includes registration, contributing to certified collection and recycling systems, regular quantity reporting, and in certain markets, specific labeling and information requirements.
These obligations exist across categories such as packaging, electrical and electronic equipment (WEEE), batteries, textiles, tyres and — depending on national law — other product types.
What is the legal basis for EPR in the EU?
EPR obligations derive from a combination of EU directives and their national implementations:
- Packaging & Packaging Waste Regulation (PPWR) (EU 2025/40, in force since 11 February 2025 and applicable since 12 August 2026 — generally repealing Directive 94/62/EC)
- WEEE Directive (2012/19/EU) for electrical and electronic equipment
- Batteries Regulation (EU 2023/1542, superseding 2006/66/EC)
- Single-Use Plastics Directive (2019/904/EU)
Most of these set requirements that member states implement nationally — but the Packaging Regulation (PPWR) has applied directly in all 27 states since 12 August 2026. Even so, the practical obligations — registration procedures (e.g. LUCID in Germany), fee structures and reporting formats — are still operated nationally and vary significantly from country to country.
What are the four core EPR obligation types?
- Registration obligation: Producers must register with the national authority and/or compliance scheme before placing products on the market.
- Financial obligation: Eco-contributions (fees) are due based on quantities and materials placed on the market — and these fees are increasingly eco-modulated (lower for easily recyclable packaging): national modulation already applies in Germany, France and the UK, and EU-harmonised modulation under the PPWR is expected around 2028–2030.
- Reporting obligation: Regular quantity declarations must be submitted — typically quarterly or annually, with strict deadlines.
- Labeling & information obligation: Certain countries and categories require specific product or packaging markings and consumer information.
When do EPR obligations apply to my business?
EPR obligations apply to you if you are considered a "producer" under the applicable national law. This typically includes anyone who:
- Manufactures regulated products and sells them domestically
- Imports regulated products into an EU country
- Sells products into an EU country via distance selling (e-commerce, online marketplaces)
- Is the brand owner, even if manufacturing is outsourced (white label / OEM)
Do EPR obligations apply to e-commerce and marketplace sellers?
Yes. Cross-border online sales are explicitly covered in most EU member states. If you sell into a country without a local legal entity, you are typically still obligated to register and report in that country. Several jurisdictions additionally assign obligations to the marketplace platform itself if the seller fails to comply — in France, for example, a marketplace counts as the producer for third-party goods unless it holds proof of the seller's UIN.
Are there thresholds or de minimis exemptions?
Some countries operate volume-based thresholds below which certain obligations are reduced or waived — particularly for small producers. However, these exemptions are category- and country-specific, often narrow in scope, and should never be assumed without verification. Examples: the Netherlands requires Verpact registration only above 50,000 kg of packaging a year; Ireland's Repak duty applies to major producers (at least 10 tonnes and turnover above €1 million); Spain has no registration de-minimis; and the Czech small-producer exemption ended on 12 August 2026. In most cases, the obligation to register exists regardless of volume.
Who is responsible in a white label or OEM supply chain?
In the majority of EU EPR frameworks, legal responsibility lies with the entity whose brand or identity appears on the product as presented to the end user. If the actual manufacturer is not identifiable from the product itself, the brand owner who places it on the market is treated as the producer and carries the full scope of EPR obligations.
What are the reporting obligations in detail?
Reporting obligations require producers to submit verified data on volumes placed on the market. Key aspects:
- Frequency: typically quarterly or annual depending on country and scheme
- Format: prescribed by the scheme or authority; often digital via scheme portals
- Verification: some jurisdictions require third-party audits for larger volumes
- Consequences of missing deadlines: late fees, surcharges, or enforcement action
How do I stay compliant across changing laws in multiple countries?
EU EPR legislation is actively evolving — new regulations, updated fee structures and tightened enforcement are introduced regularly. Monitoring several national legal frameworks simultaneously, in different languages, across multiple schemes, is operationally demanding. Most companies handling multi-country obligations rely on a specialised compliance partner for ongoing legal monitoring, deadline management and reporting.
Penalties for non-compliance with EPR obligations
Enforcement of EPR obligations is increasing across the EU. Authorities and marketplace platforms are actively verifying compliance — and the consequences of violations are significant.
What penalties apply if I fail to meet EPR obligations?
Sanctions are defined by national law and vary by country and violation type. Common consequences include:
- Administrative fines — in Germany up to €200,000 depending on the offence (PPWR-related fines from 12 February 2027); in Spain €100,001–3,500,000 for very serious offences; in Poland PLN 1,000–1,000,000 for operating without BDO registration
- Sales or market bans — authorities can prohibit the marketing of non-compliant products
- Mandatory removal from market — products may need to be recalled or withdrawn
- Marketplace delisting — Amazon may deactivate offers or stop selling them, and eBay may hide listings without a valid EPR number
- Retroactive fee obligations — back-payments for all periods where obligations existed but were not fulfilled
Are authorities actively enforcing EPR obligations?
Yes — and the legal tools are growing. Member states must lay down PPWR penalty rules by 12 February 2027, and Germany's PPWR-related fines apply from that date. Spain checks import declarations for electrical equipment and batteries against its producer registers (RD 993/2022). Registers are often publicly searchable, so competitors can report unregistered sellers.
Can online marketplaces be held liable for my non-compliance?
In several EU countries, marketplace operators can face secondary liability or be required to take enforcement action against non-compliant sellers on their platform. As a result, major e-commerce platforms have introduced their own EPR compliance verification requirements — independent of and in addition to what authorities require.
Authorized representative – a legal obligation in many EU countries
Several EU member states legally require non-resident producers to appoint a local authorized representative as a condition of registration. This is not optional — it is a statutory requirement in those jurisdictions. Since 12 August 2026 the PPWR (Art. 45) makes this an EU-wide rule for packaging sold directly to end users: producers — EU or non-EU — who sell packaged products directly to end users in another member state must appoint a representative there; for other non-EU producers, member states may require one. An exemption for small EU-established producers is under negotiation Proposal – not yet law.
When is an authorized representative legally required?
The requirement applies primarily to companies established outside a given country that sell products into that market. In these cases, national law designates the authorized representative as the entity that is legally accountable for the producer's EPR obligations — including registration, reporting and communication with authorities.
Examples: France requires a France-established mandataire for all EPR streams since 10 July 2026 for every producer not established in France; Belgium requires a Belgium-established representative registered with EPRiBEL since 12 August 2026; Sweden requires one for EU-established producers; Austria and Portugal require one for foreign distance sellers; in Germany it applies to packaging only for producers without a German branch who sell directly to end users, and to WEEE and batteries for producers without a German establishment. Authorized representative guide → By country: who needs an authorized representative in Italy, France, Germany, Spain and Poland →
What obligations does an authorized representative hold?
- Act as the legal point of contact for national authorities and compliance schemes
- Ensure registration is obtained and maintained
- Submit or coordinate periodic quantity reports and declarations
- Manage deadlines and ensure documentation is audit-ready
- Handle all EPR-related correspondence in the national language
Is the authorized representative liable for my EPR violations?
In many jurisdictions, the authorized representative assumes shared legal responsibility for the producer's compliance. This is why reputable representatives require proper documentation from their clients — and why the selection of a qualified, experienced representative with genuine legal grounding is important.
One representative for all EU countries
Instead of managing separate representatives per country, we act as your central authorized representative for all EU member states — packaging, WEEE and battery, all markets, one contract.
Request authorized representationCountry-specific EPR obligations across the EU
EU rules increasingly harmonise the framework — the Packaging Regulation (PPWR) has applied directly in all 27 states since 12 August 2026 — but the concrete obligations (authorities, registers, schemes, fees and reporting) are still operated and enforced nationally. No two countries are fully identical.
🇩🇪 Germany – VerpackDG (PPWR), ElektroG and BattDG
Germany operates three category-specific frameworks: packaging in the LUCID register (ZSVR, free of charge) plus a licensed dual system; electrical and electronic equipment with stiftung ear (ElektroG); and batteries, also with stiftung ear under the BattDG, where joining a producer responsibility organisation is mandatory since 1 January 2026.
Since 12 August 2026 the VerpackDG has replaced the VerpackG. Only producers without a German branch who sell directly to end users must appoint an authorized representative, who confirms the mandate in LUCID — the registration stays with the producer. Fines reach up to €200,000 depending on the offence; PPWR-related fines apply from 12 February 2027.
🇫🇷 France – around 20 EPR streams, UIN and mandataire
France has one of the broadest EPR scopes in the EU, with around 20 EPR streams (filières REP) — including packaging, electrical equipment, batteries, textiles, furniture and tyres. ADEME issues a unique identifier (UIN) per stream, which must appear in your terms and conditions and on your website.
Since 10 July 2026 (Loi n° 2026-602) every producer not established in France — EU or non-EU — must appoint a France-established mandataire by written mandate, unless a France-established marketplace handles compliance. The Triman logo and sorting information remain mandatory.
🇮🇹 Italy – CONAI, Registro AEE and the Contributo Ambientale
Placing packaging on the Italian market triggers CONAI membership and the environmental contribution (CAC), charged by weight and material on packaging placed on the Italian market. Foreign sellers without an Italian establishment need an Italy-based representative (Italian VAT number and PEC address), not an establishment of their own.
Electrical equipment is registered in the Registro AEE via the Chambers of Commerce before placing on the market (fines €30,000–100,000 for selling unregistered); batteries are registered in the Registro Pile.
🇪🇸 Spain – MITECO register, representante autorizado and customs checks
Packaging producers register in the packaging section of MITECO's Registro de Productores de Producto. Producers established in another EU state or a third country must appoint a representante autorizado in Spain; there is no registration de-minimis (simplified reporting applies below 15 tonnes).
WEEE and batteries are registered with the industry ministry, and import declarations must match the register data (RD 993/2022). Very serious offences under Ley 7/2022 can be fined €100,001–3,500,000.
🇵🇱 Poland – BDO register
Poland's BDO register covers packaging, WEEE and batteries; entries are made by the voivodeship marshal's office, and foreign entities may need to register even without a Polish branch. Carrying on registrable activity without a BDO registration can be fined PLN 1,000–1,000,000.
A packaging EPR reform bill (UC100, with NFOŚiGW as central body and a per-kg fee) is still a draft Proposal – not yet law.
🇳🇱 Netherlands – Verpact and Stichting OPEN
Packaging producers register with Verpact (formerly Afvalfonds Verpakkingen) only if they place more than 50,000 kg of packaging per year on the Dutch market.
Electrical and electronic equipment is registered with Stichting OPEN in the national (W)EEE register; foreign sellers selling directly to Dutch end users count as producers.
🇧🇪 Belgium – Fost Plus, Valipac and EPRiBEL
Packaging is handled by Fost Plus (household) and Valipac (industrial); the authority formerly known as IVCIE is now EPRiBEL. Since 12 August 2026 foreign producers need an authorized representative established in Belgium and registered with EPRiBEL; annual registration fees start in 2027.
WEEE is covered by Recupel and batteries by Bebat. Flemish environmental administrative fines reach up to €400,000 (exclusive fine) or €2,000,000 (alternative fine).
🇦🇹 Austria – Bevollmächtigter and EDM registration
Foreign distance sellers to private consumers in Austria must appoint a Bevollmächtigter (authorized representative) for packaging (§§ 16a–16e Verpackungsverordnung) and for WEEE and batteries. Registration runs via the ministry's EDM portal.
Missing system participation can be fined €450–8,400 under § 79 AWG, plus up to twice the participation fee.
🇸🇪 Sweden – one Naturvårdsverket register
Sweden keeps one producer-responsibility register at Naturvårdsverket, used via e-service or a producer responsibility organisation (approved packaging PROs: NPA and TMR). EU-established producers must appoint an authorized representative in Sweden since 12 August 2026.
New producers file their first report by 31 March 2027, covering 12 August–31 December 2026. For WEEE and batteries, EU distance sellers need a Sweden-established representative, while non-EU sellers may register directly.
🇨🇿 Czech Republic – EKO-KOM and the end of the small-producer exemption
The national small-producer exemption (up to 300 kg and CZK 25 million turnover) no longer applies since 12 August 2026, and authorized representatives report to EKO-KOM. After 12 February 2027 the Green Dot may only be shown via QR code or digital marking.
A national packaging-law amendment is in preparation Proposal – not yet law.
🇩🇰 Denmark – Dansk Producentansvar
Dansk Producentansvar (DPA) keeps the producer register, to which packaging and batteries were added in 2025. EU companies need a Danish authorized representative; non-EU companies may register directly, except for batteries.
Supplementary PPWR rules (BEK 851 of 28 September 2026) apply since 15 October 2026.
🇵🇹 Portugal – APA SILiAmb register
Producers register in APA's SILiAmb register, and the registration number (format PTFF000000) must appear on invoices; schemes include SPV, Novo Verde and Electrão. Foreign distance sellers to end users need an authorized representative — for EEE since 2018, for packaging and batteries since 1 January 2022.
Serious offences can be fined €12,000–72,000 (negligence) or €36,000–216,000 (intent) for companies.
🇮🇪 Ireland – Repak and Producer Register Ltd
Major packaging producers (at least 10 tonnes and turnover above €1 million) must join Repak; self-compliance ended on 1 January 2023.
Distance sellers of EEE and batteries based outside Ireland must appoint an Irish authorized representative and register with Producer Register Ltd, renewed by 31 January each year.
🇬🇧 United Kingdom – packaging EPR & WEEE (post-Brexit)
Post-Brexit, the UK runs its own EPR framework. Packaging EPR registration is made with the environmental regulator; the 2027 deadline was 1 October 2026 (1 April 2027 for sellers whose only activity is selling filled packaging to end users). 2027 fees are £2,842 for large producers registering directly or £1,803 via a compliance scheme, and PackUK plans its first 2026–27 notices of liability for the end of November 2026.
WEEE is a separate regime. UK sellers selling into EU countries need full EU registrations in addition to their UK obligations.
Where can I find the legally binding rules for each country?
No single EU-wide database consolidates all national EPR legislation in one place. Each country guide above links to the official registers and legal texts, and our EPR deadline calendar lists the next dates for all countries. Given language barriers and the volume of updates, most multi-country compliance programmes use professional monitoring services rather than attempting to track changes directly.
Get expert guidance on your EPR obligations
Submit a short request and receive structured guidance on your legal EPR duties. Your message is delivered directly to Certify — specialists in EU-wide producer responsibility compliance. Free first consultation, no obligation.
Legal note: This site is an informational resource operated in partnership with Certify GmbH. EPR obligations are country- and category-specific. Nothing on this page constitutes legal advice. Consult a qualified compliance specialist for your specific situation.
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WEEE · Packaging · Battery registration for EU markets. For international sellers.
Get registered →Germany guide
LUCID, EAR & BattDG — the strictest EPR market in the EU, explained. Includes the checklist for sellers already registered before August 2026.
Read the Germany guide →Your advantages with CERTIFY
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3 steps to compliance with CERTIFY
Map your obligations
We analyse your product portfolio, target markets and sales channels to identify all EPR requirements.
Registration, handled
We register you with all relevant authorities and schemes and keep you updated until every number is issued.
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Reporting, monitoring, legal updates — we handle it all. You focus on growing your business.