EPR registration: which countries require it and how to register

Extended Producer Responsibility is where EU compliance stops being a document exercise and starts being an invoice. If you place packaging, electrical equipment, batteries or textiles on the market in an EU country, you generally have to register nationally, report what you placed on that market, and pay fees that fund collection and recycling.

The PPWR harmonised much of the packaging rulebook from 12 August 2026, but it did not centralise registration. There is no single EU EPR account. You register country by country, scheme by scheme.

The pattern that repeats in every country

Before the country detail, the shape is almost always the same:

1. Register as a producer, either directly with a public register or through a compliance scheme.
2. Obtain a registration number, which marketplaces and customers may demand.
3. Report volumes, usually by material category and weight, monthly, quarterly or annually.
4. Pay fees based on those volumes and materials.
5. Where you are not established in that country, appoint an authorised representative to act for you.

The variations are in who holds the register, whether representation is mandatory, and how aggressively marketplaces check.

Germany

Packaging is governed by the Verpackungsgesetz. You register in the LUCID packaging register operated by the Zentrale Stelle Verpackungsregister, then contract with a dual system for the packaging you place on the market, and report the same volumes to both. Marketplaces are legally required to check LUCID registration, so an unregistered seller is usually blocked at listing level rather than fined.

Germany also runs registers for electrical equipment (WEEE, via the stiftung ear) and batteries. Registration for electricals is required before you sell, and the registration number must appear in your commercial documentation.

France

France has the broadest EPR scope in the EU, covering packaging, paper, electricals, batteries, furniture, textiles, toys, DIY and garden equipment, sports and leisure goods, and more. You obtain a unique identifier (identifiant unique) from ADEME for each stream, and join a producer responsibility organisation such as Citeo for household packaging and paper.

France layers on the Triman sorting information requirement, which affects your on-pack artwork, and applies distance-selling rules that make marketplaces responsible for verifying seller registration.

Spain

Royal Decree 1055/2022 restructured packaging obligations and brought in registration in the producer register for packaging, plus reporting and joining a collective system for household packaging. Spain also applies a plastic packaging tax on non-reusable plastic packaging, which is a separate filing from your EPR scheme reporting and catches importers in particular.

Italy

Packaging producers typically join CONAI, which administers the environmental contribution, with reporting based on material and weight. Italy additionally requires environmental labelling on packaging identifying materials and giving sorting instructions — a requirement that predates the PPWR harmonised labelling scheme and still needs to be met.

Netherlands

Packaging is administered through the packaging waste fund, with registration and annual reporting of tonnage placed on the market, and a threshold below which reporting duties are lighter. Electrical equipment and batteries have their own registration routes.

Other markets worth knowing

Austria, Belgium, Poland, Portugal, Sweden, Denmark, Ireland, Czechia, Romania and the rest each have their own registers and schemes; Belgium's Fost Plus and Austria's dual systems are the ones most often encountered by mid-sized sellers. Where you are not established locally, most require an authorised representative — that requirement, not the fee, is usually what takes time to arrange.

How to work out what you owe

Step 1 — list your markets. Every country where a customer receives your goods. Marketplace sales count. Sales through an EU distributor may shift the obligation to them, but only if they are genuinely placing the product on the market.

Step 2 — list your streams. Packaging almost always. Then: electrical or electronic equipment, batteries including those inside products, textiles in the countries that regulate them, furniture, toys and other France-specific categories.

Step 3 — get the weights. Per SKU, per packaging component, by material, in kilograms. This is the work. Every scheme reports on material and weight, so one clean dataset serves all of them.

Step 4 — decide direct or representative. If you are established in the country, register directly. If not, use an authorised representative or a service that provides one.

Step 5 — register before you sell. Several registrations are pre-market conditions, and marketplaces check numbers at listing time.

Step 6 — set the reporting calendar. Different countries, different frequencies. Late reports and estimated volumes generate corrections and penalties.

Textiles, the next wave

Several Member States are extending EPR to textiles, with France already operating a textiles scheme and others following as the revised Waste Framework Directive rules bed in. If you sell clothing, footwear or home textiles, expect a textiles registration and reporting obligation in more markets over the next two years, on the same pattern: register, report weight by category, pay, and appoint a representative where you are not established.

The data you need is again weight and material composition per SKU — the same dataset a Digital Product Passport for textiles will require. Collecting it once, at product introduction, serves both.

Getting the first registration done

If you are starting from nothing, do one country end to end rather than opening five applications at once. Pick your largest market, assemble the SKU weight data, register, join the scheme, file the first report, and record every document and reference number as you go. The second country then takes a fraction of the time, because the hard part — the data and the internal process — is already built, and the differences between schemes are mostly forms and calendars.

Expect the first registration to take several weeks where representation is required, since the representative needs your company documentation before they can act. Start before you need the listing live, not after a marketplace has asked.

The mistakes that cost the most

Registering only in your biggest market. Almost universal. Germany first, then five more countries added without touching EPR again.

Forgetting shipping packaging. Cartons, mailers, tape and void-fill are packaging you placed on the market.

Ignoring batteries inside products. A device with an embedded cell brings battery obligations as well as electricals.

Assuming the marketplace handles it. Marketplaces verify registration; they do not usually become the producer.

Reporting estimates. When actual tonnage is reconciled, the difference is billed, sometimes with penalties.

Missing local labelling. Triman in France and environmental labelling in Italy are separate from registration and separate from the PPWR harmonised scheme still to come.

Thresholds, marketplaces and who actually pays

Two structural questions decide most of the workload. The first is whether you are placing the product on the market in that country at all: if an EU-established distributor buys from you and resells, the obligation usually travels with them, but if the consumer is the buyer, it is yours. The second is whether the country applies a small-producer threshold; several do for reporting frequency or for scheme membership, but almost none exempt registration entirely, and thresholds are measured in tonnage placed rather than revenue.

Marketplaces have become the practical enforcement layer. Because platforms are obliged to verify registration, an unregistered producer typically finds out through a listing block in a single country, which is also the fastest diagnostic you will get. Keep registration numbers per country in one place so that filling in a platform verification form takes minutes.

What this looks like when it is under control

A single table: SKU, packaging component, material, grams, country, scheme, registration number, reporting frequency, last report date. Boring, and it answers every question a scheme, a marketplace or an auditor will ask. Most companies do not have it, and that is why EPR feels chaotic rather than merely administrative.

Educational information only, not legal advice. Registration thresholds, representation requirements and fees change frequently — verify current requirements with each scheme or a qualified advisor.