Do You Need EPR in Every EU Country, and What Is PPWR?

On August 12, 2026, a new EU packaging law takes full effect. It changes how every seller — big or small, inside or outside Europe — must pack and ship goods into the EU. This guide explains, in plain language, what the law requires, what it does not, and exactly what you need to do.

What is this law?

The law is called the PPWR (Packaging and Packaging Waste Regulation), or Regulation (EU) 2025/40. It replaces an older directive and applies directly in all 27 EU countries from August 12, 2026. If you send any packaged product to an EU customer, it applies to you.

First, the big question: what is EPR?

EPR stands for 'Extended Producer Responsibility.' Put simply: the company that first puts packaged goods on the market must pay to collect and recycle that packaging after the customer throws it away.

It works in a loop:

• You register as a 'producer' in each country where you sell.
• You report how much packaging (by weight and material) you put on the market.
• You pay a recycling fee (called an 'eco-fee') to a national recycling organisation.
• You keep the registration active with regular reports and renewals.

There is no single EU registration. Each country runs its own system. If you sell in Germany, France, and Spain, you register three times — once in each country.

Who is the 'producer' — and why it is probably you, not your box factory

A common mix-up: the 'producer' under EPR is not the company that makes the empty box. It is the party that first makes the packaged goods available on the EU market — that is you, the moment you fill the box and ship it to an EU customer. A company that only sells you empty cartons is usually not the producer for your sales packaging. Its only job is to give you the conformity evidence you need (material data, substance-compliance, test reports) so you can prove your packaging is compliant. You pay the eco-fee to the national scheme — not them. Whether you later ask a supplier to share that cost is a private business choice, not their legal duty.

The five hard packaging rules

1. Substance limits — packaging must not contain more than 100 mg/kg of lead, cadmium, mercury, or hexavalent chromium combined.
2. PFAS ban — food-contact packaging must not contain PFAS ('forever chemicals') above set limits.
3. Recyclable — all packaging must be recyclable. From 2030, most must reach at least grade C (70% recyclable); from 2038, grade B (80%).
4. Empty space — from August 12, 2026, you must keep packaging no larger than necessary. No fake bottoms, no double walls, no shipping a tiny item in a huge box full of air pillows. A strict 50% empty-space cap comes later, in 2030. (Some posts say a 40% limit starts in August 2026. That figure is wrong.)
5. EPR + a contact in the EU — you must be registered for EPR in every country you sell, and if you are outside the EU, you must name an 'authorised representative' in each of those countries.

Do you need an EU company, tax number, or business license?

No. This is where most sellers get stuck, so here is the clear answer:

• You do not need to open a company in the EU.
• You do not need an EU business license.
• You register using your own home-country business documents (your business registration certificate).
• You do not need an EU VAT number to register for packaging EPR. VAT is a separate tax rule that applies once your sales pass certain thresholds; it is not part of packaging EPR. Some national recycling bodies may ask for a VAT number, but it is usually not required to get registered.

What you do need as a non-EU seller is an authorised representative (explained just below).

What is an authorised representative?

If you are outside the EU, you usually cannot register for EPR in a country by yourself — the system wants a local contact inside that country. That local contact is the 'authorised representative' (AR).

In short, the AR is a person or company that is based in the specific EU country where you sell. You appoint them under a written mandate (a signed instruction). After that, they act as your local stand-in for packaging EPR. They:

• register your business in that country's packaging system;
• file your packaging weights and pay the recycling fee;
• answer the national authority if it asks questions.

Three things matter most:

• One per country. You need a separate AR in each country where you sell. There is no single 'EU-wide' representative. A seller shipping to Germany, France, and Spain needs three.
• You stay responsible. The AR handles the paperwork, but the law still holds you — the producer — accountable. If something is wrong, the fine lands on you, not the AR.
• It is not your importer or warehouse. A marketplace store, a 3PL, or a VAT number does not count as an AR. You must appoint one separately.

Most outside-EU sellers use a compliance service that provides the AR for a yearly fee. This is standard practice.

One more note: the packaging EPR representative (required by Article 45) is different from the representative some sellers use to sign the Declaration of Conformity (Article 17, optional). They are two separate roles — do not assume one covers the other.

If you sell from outside the EU

If your company is based outside the EU (for example, in the UK or the US) and you ship directly to EU customers, the PPWR treats you as the 'producer.' From August 12, 2026, you must:

• Register for EPR in every EU country where you sell.
• Appoint an authorised representative (AR) in each of those countries (see the explanation just above).
• Note: a marketplace store, a 3PL warehouse, or having a VAT number does not count as 'being established' in that country. You still need the AR.

Most outside-EU sellers use a compliance agent — a service that provides the AR and handles the registration for a yearly fee. An EU proposal may lift the AR requirement for EU-based companies, but it does not cover non-EU sellers. You are fully bound.

If you are a solo or small seller

The rules apply to all sellers, with no sales-volume exemption. Even one parcel to a French customer can technically trigger the requirement. In practice, sellers focus on the countries where they have real volume (Germany, France, Italy, Spain, and the Netherlands account for most EU cross-border e-commerce).

• Small and micro sellers are not excused from EPR registration, but many countries offer lower fees for small volumes. France, for example, has a micro tier around €30–50 per year for under 100 kg of packaging.
• One exception: very small producers may be exempt from the packaging Declaration of Conformity paperwork. In Germany's system, producers with under €2 million turnover or fewer than 10 employees are exempt from that document. That is a separate obligation from EPR — you still register for EPR.
• Individual sellers without a company number can still register through a compliance service provider using an ID and a shop link.

Where do you register for EPR?

EPR is not one form. You register separately in each country where you sell. The steps are similar everywhere:

1. List the countries where you place packaged goods on the market.
2. Open an account in that country's national packaging register (see the list below).
3. Enter your company details and your packaging data — type (paper, plastic, glass, metal, composite) and estimated weight per year.
4. Sign a contract with the country's recycling scheme and pay the eco-fee.
5. You receive a registration number. Upload it to your marketplace (for example, Amazon Seller Central's EPR section) for each country.
6. Each year, report your actual weights and pay the fee again to keep the number active.

The main country systems

You do not need to act on this list today. The point is simple: there is no single EU sign-up. Every country runs its own public register and its own recycling scheme — a producer-responsibility organisation (PRO), the scheme you pay the eco-fee to. So you register separately in each market where you sell. When you are ready, here are the official doors for the main markets:

Country	Official register	Scheme you contract with (PRO)
Germany	LUCID (central register)	Dual system such as Der Grüne Punkt or Landbell
France	SYDEREP (national register)	Citeo or Adelphe
Spain	MITECO (Ministry for Ecological Transition)	Ecoembes
Italy	CONAI (national consortium)	CONAI
Netherlands	Verpact	Verpact
Poland	BDO (national register)	BDO (national register)
Belgium	Fost Plus (household) / Valipac (business)	Fost Plus / Valipac
Ireland	Repak	Repak

Links above point to the official registers and schemes. Always start from the official site for the country where you sell.

If you are outside the EU, you usually hand the whole process to a compliance service provider. The provider runs the registration for each country and supplies the authorised representative for that country, for an annual fee.

Does EPR registration let you sell in the EU?

No. This is a common mistake. A registration number is necessary, but it is not the same as permission to sell.

Under the PPWR, packaging 'may only be placed on the market if it complies with this Regulation' (Article 4). Put simply: no compliance, no market. So even with a valid EPR number, you must still meet the packaging rules themselves — the substance limits (heavy metals, PFAS), recyclability, and the ban on excessive empty space. You also need the Declaration of Conformity for your packaging (unless you are a micro-producer) and, if you are outside the EU, an authorised representative per country.

On top of packaging law, normal market-access rules still apply: customs and import rules, VAT once your sales pass the threshold, and product-safety rules for the goods inside the packaging. EPR registration covers the packaging waste only. It does not grant you market access by itself.

How to get compliant: the full checklist

EPR registration is only one part of PPWR compliance. The complete list, in order:

1. List your markets. Every EU country where you sell or plan to sell.
2. Register for EPR in each market — the six steps above. Open the national register, sign a recycling contract, get your number, and upload it to your marketplace. There is no EU-wide form.
3. Appoint an authorised representative for each country (if you are outside the EU). Sign a written mandate; a compliance agent can do it for you. You stay legally responsible.
4. Collect supplier evidence. Get material test reports (heavy metals, PFAS) from your packaging supplier so you can prove your packaging is compliant.
5. Meet the packaging design rules. Cut empty space, remove fake structures, and check recyclability.
6. Keep it alive. File your weights and pay the eco-fee every year, and renew on time so your number stays valid.

The exact places sellers fail

• Using your old box supplier without asking for a material test report → heavy-metal or PFAS breach.
• Shipping small items in oversized boxes stuffed with air pillows → empty-space breach.
• Never registering EPR in a country where you sell → no registration, marketplace blocks the listing.
• Being outside the EU with no authorised representative → cannot even register; listing blocked.
• Registering but letting the contract or reports lapse → number invalidated, listings removed.

Does it cover every type of product?

A quick but important point: the PPWR rules the packaging, not the product inside it. Every parcel you send to the EU — whether it holds electronics, baby goods, clothes, toys, food, or cosmetics — must follow the packaging rules. There is no 'my product is exempt' escape.

But some product types need extra attention, for two reasons: their packaging carries stricter limits, or they trigger a second law on top of the packaging law.

Products whose packaging faces the strictest limits

• Food-contact packaging (food, drinks, baby bottles, tableware) — the PFAS ban and the heavy-metal limit (100 mg/kg) hit here first, from August 12, 2026. This is the area to watch most.
• Plastic packaging of any product — from 2030, recycled-content minimums apply (30% for single-use bottles, 30% for PET food-contact, 35% for other plastic).
• Single-use plastic formats — some are banned from 2030 (for example, pre-packed fresh fruit and vegetables under 1.5 kg).
• Multi-material (composite) packaging — often hard to recycle, so check its grade.

Products that trigger a second law on top of the packaging law

• Electronics and electrical equipment — the box follows the PPWR, but the device itself falls under WEEE (Waste Electrical and Electronic Equipment, Directive 2012/19/EU), a separate product-level EPR. If you are the producer who first places such goods on the EU market, you register for both: packaging (PPWR) and product take-back (WEEE). Meeting one does not meet the other.
• Batteries — built-in or loose, they follow the Batteries Regulation (EU) 2023/1542, another separate EPR.
• Baby and infant goods — if they are food-contact (bottles, teats, tableware), the strict PFAS and heavy-metal rules apply. One exception: packaging for infant formula and special medical foods is exempt from the recyclability grade until the 2035 review.

Exempt only from the recyclability grade (not from everything)

Medicines, medical-device packaging, infant-formula packaging, and sales packaging made of light wood, cork, textiles, rubber, ceramics, or wax are exempt from the recyclability minimums until 2035 — but they still need EPR registration and must still meet the substance limits.

A note on cosmetics and textiles: their packaging follows the PPWR too. The products themselves follow other EU rules, but those rules fall outside this law's scope.

Key dates

• August 12, 2026 — PPWR fully applies. EPR per country plus authorised representative for non-EU sellers. Substance, PFAS, recyclable, and minimisation rules start.
• 2030 — 50% empty-space cap; recyclability grade C.
• 2038 — recyclability grade B.

Common questions

Who must follow this law? Any business that first places packaged goods on the EU market. This includes manufacturers, importers, distributors, retailers, and online sellers — inside or outside the EU. If you ship one parcel to an EU customer, the law applies to you.

Do I need to register on every Amazon or TikTok country site? There is no single 'EU packaging law' run by Amazon or TikTok. These are marketplaces that enforce each country's own rules. If you sell on Amazon.de, you need a German LUCID number. On Amazon.fr, a French number. The same applies to TikTok Shop and Temu — each asks for the registration number of the country where you sell, uploaded separately.

Does the PPWR cover every type of product? Yes for the packaging, no for the product inside it. The law rules the packaging, not what is in it — and there is no 'my product is exempt' escape. For the product types that need extra care (food-contact, electronics under WEEE, batteries, baby goods, plastics), see the section 'Does it cover every type of product?' above. The short version: all their packaging still follows the PPWR, even when the product itself follows a different EU rule.

I use Pan-European FBA. What then? Pan-Eu spreads your stock across several countries. Storing goods for sale in a country counts as 'placing them on the market' there. So you need EPR registration in every country where Amazon keeps your inventory — usually Germany, France, Italy, Spain, and the Netherlands. Restricting storage to fewer countries lowers the count but also lowers the shipping benefit.

What about the UK? It left the EU. The UK runs its own system, called pEPR, managed by PackUK. It is separate from the EU PPWR. An EU registration does not work in the UK, and a UK one does not work in the EU. If you sell in both, you register in both. For non-UK sellers using a platform like Amazon, the platform may handle UK packaging fees for you — but confirm per category, since WEEE and textiles may still need self-registration.

If I only ship to one EU country, is one registration enough? Yes — if your sales and your stock stay in that one country, one registration covers it. But if you use Pan-Eu, EFN, or store stock in more than one country, each of those countries counts. A parcel shipped into a country still 'places' your packaging on that market.

Does the registration number go on the package? No. You print recycling labels — France requires the Triman logo, Germany uses the Green Dot or resin codes — but the registration number itself goes to the marketplace and the authorities, not on the box. Keep it for inspection.

If the platform pays the fee for me, do I still register? Yes. This is the most common mistake. A marketplace 'pay-on-behalf' service only pays the recycling fee. It does not replace your registration. Amazon states clearly that even with pay-on-behalf, you must still register in each country and hold a valid number. In some countries — Germany, Poland, Belgium, the Netherlands, Ireland — Amazon does not offer pay-on-behalf for packaging at all, so you register yourself.

What does PPWR mean for cross-border sellers? From August 12, 2026, packaging EPR registration is a baseline market-access rule, not a nice-to-have. Non-EU sellers must name a representative per country. Marketplaces will block listings without a valid number. The old shortcut — register in one country and ship everywhere — no longer works.

Sources

1. European Commission. Packaging and Packaging Waste Regulation (PPWR) — guidance document. environment.ec.europa.eu.
2. EUR-Lex. Regulation (EU) 2025/40 of 16 December 2024 on packaging and packaging waste. eur-lex.europa.eu.
3. European Commission. PPWR Frequently Asked Questions. environment.ec.europa.eu.
4. UK Department for Business and Trade. Guidance for UK businesses on the EU PPWR. gov.uk.
5. PPWR Article 45 decoded — authorised representative obligation. eprrepresentative.com.
6. Eldris. PPWR for marketplace sellers: EPR registration and authorised representative. epr.eldris.ai.