EPR in the EU: extended producer responsibility for online sellers

EPR is not one EU register. The EU texts decide who the producer is, where you register, when you need a representative and what marketplaces check. The forms and the money are national.

The four streams side by side

All four hang on one frame: the general minimum requirements for EPR schemes in Article 8aDirective 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8aClick opens the article on EUR-Lex. of Directive 2008/98/ECDirective 2008/98/EC, Waste Framework DirectiveThe whole regulationClick opens the law on the EU Publications Office., which the packaging, battery and textile rules each name as their basis (Art. 45(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 1Click opens the article on EUR-Lex., Art. 56(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 1Click opens the article on EUR-Lex., Art. 22a(1)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 1Click opens the article on EUR-Lex.).

Batteries built into a product count: the battery register takes “batteries, including those incorporated in appliances, light means of transport or other vehicles” (Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex.). The textile scheme covers what Annex IVc lists: knitted and woven clothing and clothing accessories, blankets, bed, table, toilet and kitchen linen, curtains and blinds, other furnishing articles, worn clothing, hats, leather clothing and accessories, and footwear. It leaves out used products assessed fit for re-use and self-employed tailors making customised products (Art. 3(4b)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4bClick opens the article on EUR-Lex.). A separate EU rule, not part of EPR, bars large businesses from destroying unsold clothing and footwear since 19 July 2026 (Art. 25(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex.); it is on the ESPR ecodesign guide. The textile stream has its own guide: textile EPR. Single-use plastic products, such as plastic cutlery, cups and wet wipes, come under producer-responsibility schemes through a fifth act, Directive (EU) 2019/904Directive (EU) 2019/904, Single-Use Plastics DirectiveThe whole regulationClick opens the law on the EU Publications Office.; that is on the single-use plastics directive.

EPR by country: the register, the scheme and whether a small-volume limit exists

Each country runs its own register, as the section “The four streams side by side” shows. This table names them for five countries and says whether the text we read has a limit below which you need not register. A “simplified” regime means less to report, not no duty.

France runs a textiles scheme too, and it has a page: textile EPR in France. Its furniture and other streams are on France furniture EPR and AGEC law and the other EPR streams.

EU law, as we read it, adds no limit of its own to registration. Article 44 names no tonnage or turnover exemption, and none for micro-enterprises: the duty applies to every producer that makes packaging available for the first time in a country, and the 10 tonne line only lightens the yearly report (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex., Art. 44(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 8Click opens the article on EUR-Lex.). The battery register article names no minimum quantity (Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex.), and neither does the WEEE registration rule (Art. 16(1)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 16, paragraph 1Click opens the article on EUR-Lex.). Textiles get a later start under EU law, not an exemption: businesses with fewer than 10 persons and a turnover and balance sheet not above EUR 2 million come under the scheme from 17 April 2029 (Art. 41Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 41Click opens the article on EUR-Lex.). A country may already cover them: recital 33 of the amending Directive says a country can keep a textile scheme for microenterprises that was in force when the Directive entered into force. As for “do I need to register for a few parcels”: the texts we read name no parcel count in Germany, France or Spain, and the PPWR duty starts with the first making available.

Marketplaces state limits of their own. These are marketplace practice. For Italy the paragraph of the national code behind it is in the table; for Finland we have not found the national text:

• Italy, packaging. Amazon says a micro-enterprise is exempt: fewer than 10 employees and a turnover or balance sheet of EUR 2 million or less. It asks for a chamber of commerce certificate once a year (Amazon, Italy). The text behind it appears to be paragraph 11 of Article 178-quater, which Amazon states without the condition about packaging that cannot be avoided. That paragraph switches off the platform route only, and PPWR Article 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex. has no micro-enterprise exemption.
• Finland, packaging. Amazon says sellers with an annual turnover below the Finnish VAT threshold of EUR 20,000 are not professional sellers and are out of scope, and asks for a chamber of commerce certificate to show it. A seller outside Finland is out of scope only if it is under “the taxable turnover threshold in your home country” (Amazon, other countries). The PPWR registration duty has no turnover line, and we found no official statement on how the two sit together.
• Czech Republic, packaging. Amazon says Czech packaging law has no minimum sales thresholds (Amazon, other countries).

Not read for any threshold: Austria, Belgium, the Netherlands, Ireland, Poland and Sweden.

Who the producer is

Each act defines the producer by where it is established and how it sells, “irrespective of the selling technique used, including by means of distance contracts”. For a seller shipping from one country into another, the case that decides it is the same in all four: you make the goods available for the first time in an EU country, directly to end users there, and you are established in another EU country or outside the EU (Art. 3(15)(c)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (c)Click opens the article on EUR-Lex., Art. 3(15)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (d)Click opens the article on EUR-Lex., Art. 3(1)(f)(iv)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 3, paragraph 1, point (f), point (iv)Click opens the article on EUR-Lex., Art. 3(47)(d)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47, point (d)Click opens the article on EUR-Lex., Art. 3(4b)(d)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (d)Click opens the article on EUR-Lex.). Then you are the producer in the buyer’s country.

Sell instead to a business established in that country that brings the goods in and resells them, and that business is the producer there (Art. 3(1)(f)(iii)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 3, paragraph 1, point (f), point (iii)Click opens the article on EUR-Lex., Art. 3(47)(c)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47, point (c)Click opens the article on EUR-Lex., Art. 3(4b)(c)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (c)Click opens the article on EUR-Lex.). For packaging, a business established in that country that makes packaged products available there for the first time is the producer (Art. 3(15)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (b)Click opens the article on EUR-Lex.). The five packaging cases, and the micro-enterprise carve-out that moves the word “manufacturer”, are on PPWR.

You pay EPR as the producer in each country, and what you hold is a registration number, not a certificate

No EU act issues an “EPR certificate”. Each country’s producer register gives you a registration number, and a marketplace asks for that number (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex., Art. 44(11)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 11, point (b)Click opens the article on EUR-Lex., Art. 16(1)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 16, paragraph 1Click opens the article on EUR-Lex., Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex., Art. 22b(2)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22b, paragraph 2Click opens the article on EUR-Lex.). The number is per country and per stream, so a seller in four countries and two streams can hold up to eight. Which register issues which number, country by country, is in EPR number.

A country can still ask for a certificate of a different kind: proof that you belong to a scheme. Spain asks for a certificate of membership of an individual or collective scheme when you register packaging (Art. 15(2) RD 1055/2022), and Amazon’s page for Germany says it may ask for a system participation certificate (Amazon, Germany). Neither is a certificate issued by the register.

The producer carries the cost (Art. 45(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 1Click opens the article on EUR-Lex., Art. 56(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 1Click opens the article on EUR-Lex., Art. 22a(1)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 1Click opens the article on EUR-Lex.). You are the producer in the buyer’s country when you sell to buyers there directly, as the section “Who the producer is” shows. A seller that is not the producer in a country pays no scheme there. A marketplace may still ask it for its supplier’s number, as the Amazon section below shows. The amounts are set by each scheme, not by an EU act: see “Fees and reports”.

Registering

You apply to the competent authority of each country (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex., Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex.). The application names your business, its brands and addresses, your trade register number and tax number, and how you meet the producer duties (Art. 55(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 3Click opens the article on EUR-Lex.; for packaging, Annex IX Part A through Art. 44(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 5Click opens the article on EUR-Lex.). The authority may charge a cost-based and proportionate registration fee (Art. 44(11)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 11, point (d)Click opens the article on EUR-Lex., Art. 55(10)(b)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 10, point (b)Click opens the article on EUR-Lex.). Each country publishes its list of registered packaging producers free of charge (Art. 44(13)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 13Click opens the article on EUR-Lex.), and the registers link to one another to make registering in several countries easier (Art. 44(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 1Click opens the article on EUR-Lex., Art. 16(2)(d)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 16, paragraph 2, point (d)Click opens the article on EUR-Lex.).

Tell the authority without undue delay when your details change or when you stop selling there (Art. 44(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 12Click opens the article on EUR-Lex., Art. 55(12)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 12Click opens the article on EUR-Lex.). A battery registration can be refused or withdrawn where the information or evidence is missing or insufficient (Art. 55(11)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 11Click opens the article on EUR-Lex.).

For packaging, the new national register, how a country takes registrations until it runs, and how a producer responsibility organisation or a representative can register for you are in packaging EPR. Which register issues your number in each country, and where it must be shown, is in the EPR registration number guide.

The authorised representative for EPR

It is a separate role from the GPSR responsible person, appointed by its own written mandate (Art. 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex., Art. 56(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 3Click opens the article on EUR-Lex., Art. 17(3)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 17, paragraph 3Click opens the article on EUR-Lex., Art. 22a(3)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 3Click opens the article on EUR-Lex.), and it sits in the country you sell into. Every EU country must let a producer established in another EU country appoint one on its territory to meet its EPR duties there, and may set registration, information and reporting rules for the representative (Art. 8a(5)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 5Click opens the article on EUR-Lex.). One business can hold both roles for you, but an EU responsible person under GPSR does not cover EPR by holding that title. Who can act, what it costs and how to appoint one is in EPR authorised representative. What the GPSR role is: the EU Responsible Person.

For textiles, a producer selling at a distance may have its producer responsibility organisation act as the representative, on a written mandate (Art. 22a(4)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 4Click opens the article on EUR-Lex.). France requires one, under loi n° 2026-602 du 8 juillet 2026, from every producer not established there, unless a marketplace established in France meets the producer duties for the product; the rule is under packaging EPR.

Fees and reports

Each country’s schemes set the amounts. The EU frame sets the rules the amounts follow: producers are treated equally “regardless of their origin or size”, without a disproportionate burden on small and medium-sized producers of small quantities (Art. 8a(1)(d)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 1, point (d)Click opens the article on EUR-Lex.); a collective scheme publishes the contributions producers pay “per unit sold or per tonne of product placed on the market” (Art. 8a(3)(e)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 3, point (e)Click opens the article on EUR-Lex.); fees are modulated, where possible, by durability, reparability, re-usability, recyclability and hazardous substances, and may not exceed the cost of providing the waste management services in a cost-efficient way (Art. 8a(4)(b)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 4, point (b)Click opens the article on EUR-Lex., Art. 8a(4)(c)Directive 2008/98/EC on waste, as amended by Directive (EU) 2018/851Article 8a, paragraph 4, point (c)Click opens the article on EUR-Lex.).

For packaging you report the quantities you made available in each country by 1 June for the previous calendar year (Art. 44(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 7Click opens the article on EUR-Lex.). What goes in the report, the shorter form under 10 tonnes and the country rules are in packaging EPR. What each scheme charges, what a producer pays in 2026 where a scheme publishes a tariff, and how the price is set, is in EPR fees; the textile fees are in textile EPR.

On top of the costs the general frame lists, the packaging contributions also pay for labelling waste bins and for surveys of what mixed municipal waste contains (Art. 45(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 2Click opens the article on EUR-Lex.). Battery contributions cover separate collection, transport and treatment, those surveys, information to the public, and data gathering and reporting (Art. 56(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 4Click opens the article on EUR-Lex.).

A producer responsibility organisation can take over your EPR duties, and for textiles it is compulsory

A producer responsibility organisation is a legal entity that organises the financing, or the financing and the operations, of EPR duties for several producers (Art. 3(66)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 66Click opens the article on EUR-Lex., Art. 3(49)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 49Click opens the article on EUR-Lex.). Countries use other names for it. Amazon’s EPR page lists “compliance schemes”, “compliance systems” and “eco-organisations”, and Germany’s packaging law calls the packaging scheme a “system” (Amazon, EPR education and § 7 VerpackDG).

Whether you must use one depends on the stream:

• Packaging. You may entrust the duties to one, and a country may make that compulsory. Where you have entrusted one, it meets the registration duty for you unless the country says otherwise (Art. 46(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 46, paragraph 1Click opens the article on EUR-Lex., Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex.).
• Batteries. The same: you may appoint one, and a country may make it compulsory (Art. 57(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 57, paragraph 1Click opens the article on EUR-Lex.).
• Textiles. Each country must make you entrust one (Art. 22c(1)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22c, paragraph 1Click opens the article on EUR-Lex.).
• Electrical equipment. The Directive leaves the choice to you: you may meet the financing duty individually or by joining a collective scheme (Art. 12(3)Directive 2012/19/EU, Waste Electrical and Electronic Equipment DirectiveArticle 12, paragraph 3Click opens the article on EUR-Lex.).

A collective organisation must treat producers equally “regardless of their origin or size”, without a disproportionate burden on producers of small quantities (Art. 46(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 46, paragraph 5Click opens the article on EUR-Lex., Art. 57(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 57, paragraph 2Click opens the article on EUR-Lex.).

Two countries show how far the choice is yours. In Germany you register yourself, and packaging that reaches private buyers needs a system (§ 6(1), § 7(1) VerpackDG). In France you get your unique identification number only through an accredited organisation or an individual scheme approved by the Ministry, and as a member of a collective scheme you cannot register as an individual (ADEME). For batteries, France has required producers to join an accredited organisation, or to apply for accreditation of an individual scheme of their own, since 18 August 2025 (ADEME, batteries). Which organisations exist, and what they charge, are in packaging EPR.

What marketplaces and fulfilment providers check

A marketplace that lets consumers buy from you must obtain, before you sell packaged goods, your registration in the buyer’s country with its number and your self-certification that you meet the packaging EPR duties there, and must make best efforts to assess whether they are complete and reliable (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex., Art. 45(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 6Click opens the article on EUR-Lex.). It must obtain the same for batteries (Art. 62(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 6Click opens the article on EUR-Lex.), and for textiles once each country’s scheme runs (Art. 22a(13)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 13Click opens the article on EUR-Lex.). The packaging and battery checks bind only marketplaces within Section 4 of Chapter III of the Digital Services Act, and that Section leaves out a marketplace run by a micro or small enterprise unless it has been designated a very large online platform (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex., Art. 62(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 6Click opens the article on EUR-Lex., Art. 29Regulation (EU) 2022/2065, Digital Services ActArticle 29Click opens the article on EUR-Lex.). The electrical-equipment Directive puts no such duty on marketplaces; each EU country sets whether they check.

A fulfilment service provider gets the packaging registration and self-certification from you when you sign its contract, and must suspend its service for your packaged goods offered to EU consumers if you do not correct information that looks inaccurate, incomplete or out of date (Art. 45(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 7Click opens the article on EUR-Lex., Art. 45(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 8Click opens the article on EUR-Lex.). How the checks run in Germany, France and Spain, including your right to challenge a suspension, is in packaging EPR. How Amazon and Etsy collect the numbers is in the sections on Amazon and Etsy.

Amazon asks for your EPR registration number in Account Health, country by country and stream by stream

This section is marketplace practice, not law. It is what Amazon’s own help pages say. Amazon calls the number an EPR registration number (ERN). What the EU law requires of a marketplace is in the section “What marketplaces and fulfilment providers check” above. Amazon’s pages say Amazon is legally obliged to check in some countries. We have not matched those statements to the national texts line by line, except where this guide says so.

Amazon says you must have complied with the EPR rules of every country and stream you sell into before you list, and that Amazon collects the numbers in some countries because it must confirm compliance there. Self-ship sellers are included, not only sellers using Fulfilment by Amazon (Amazon, EPR education). Where Amazon’s pages say it collects numbers:

For packaging, Amazon’s new-regulation page also names the register or scheme for the Netherlands (Verpact), Ireland (Repak), Poland (BDO), Sweden and Portugal. It says the registries in Belgium, the Netherlands, Ireland, Poland and Italy are delayed (Amazon, EPR requirements: new EU Packaging Waste Regulation). Amazon’s page for Germany still links the old Verpackungsgesetz. The VerpackDG replaced it on 12 August 2026, as packaging EPR shows.

A LUCID number, or any other number, goes into Account Health once it shows in the public register

Amazon’s steps for packaging are the same in each store: choose the country, open Account Health, open Regulatory Compliance, search “EPR”, click Submit next to “EPR: [country] Packaging”, choose “Do you already have an ERN?”, enter the number and click Save. Repeat in each store where you sell packaging. Amazon then validates the number against the public register, which it says takes up to five working days where the register is public.

• Wait until the number shows in the public register. Amazon says that can take up to 72 hours after you receive it, and a number submitted too early is marked invalid.
• A LUCID number is “DE” and 13 digits. Amazon says a number in the wrong format is marked invalid.
• The packaging page gives three reasons for a rejection: number not found, number expired, producer name mismatch.
• A number Amazon has marked valid is not submitted again: for Germany Amazon says a resubmission resets the validation and can make listings inactive.
• As of March 2026, Amazon says you need not resubmit existing valid packaging numbers (LUCID, and the numbers for Spain and France) because of the PPWR.
• In Spain, France, the Netherlands, Belgium, Sweden, Poland, Italy and Ireland you can be a non-producer, but only where, in Amazon’s words, your “supplier has already fulfil[led] the EPR obligations upstream”. You then enter your supplier’s number and tick the box that you are not the producer. A seller that ships to buyers in a country directly is the producer there (Art. 3(15)(c)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (c)Click opens the article on EUR-Lex., Art. 3(15)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (d)Click opens the article on EUR-Lex.), so for that country it does not tick the box.

Pay on Behalf reports your Amazon sales and pays the contributions, but it does not replace the number

Amazon’s Pay on Behalf service reports your EPR-relevant Amazon sales and pays the eco-contributions to the organisations, then debits those amounts and a service fee from your selling account. It runs in Belgium, France, Italy, Spain and the UK. It does not cover labelling, take-back, recycling or eco-design, which stay with you. No minimum eco-contribution applies under the service, and charges arise only on actual sales (Amazon, EPR Pay on Behalf).

For packaging, Amazon says that even if you are enrolled you must register in each country where you sell packaged goods and submit the number. Amazon’s pages for France, Spain, Italy and Belgium say it enrols you automatically in the categories each page lists if you do not submit a valid number by that category’s cut-off date; packaging is among them in France, and in Italy for sellers not established there (Amazon, France, Spain, Italy, Belgium). To opt out for other categories you submit a valid number for each category before the last day of the reporting cycle. In France and Spain, for packaging, you choose “Manage EPR reporting and eco-contributions yourself” and submit the number.

A missing number takes the listing down, and the stock with it

Amazon says it deactivates the listings concerned. The listings stay non-sellable, purchase orders for them are paused, and Fulfilment by Amazon will not receive new stock for them. If you do not provide the information within 30 days, outstanding purchase orders are cancelled and your stock is returned or disposed of. A removal order costs you the return charge (Amazon, reinstating deactivated listings). For electrical equipment in Germany Amazon says the account is not deactivated automatically: only the non-compliant listings are (Amazon, WEEE in Germany).

Fulfilment by Amazon packaging is described in two ways. The page for Germany says you are the producer for the FBA packaging used to ship your products, “if applicable”. The new-regulation page says you stay responsible for the packaging that comes with the product before it reaches Amazon, and that Amazon handles the shipping packaging it adds. The Austria page says Amazon is the producer for FBA secondary packaging. We found no official text that settles this.

Etsy asks for EPR registration numbers in Germany, France and Spain

This section is marketplace practice, not law. Etsy’s English help centre has an EPR page for each of three countries. Each says sellers that qualify as producers have duties for the categories listed and must give Etsy the registration number for each country. You add it in Shop Manager under Finances, Legal and tax information, then Extended Producer Responsibility (EPR) Registrations, and “Add info” under the country (Etsy, Germany and Etsy, France, and Etsy, Spain).

Etsy adds two duties that are not about the number. Producers give buyers return and recycling information, in a visible place such as shop policies. And for some categories in France, such as electrical equipment, sellers must offer a way to return used products for recycling. Etsy says furniture, toys, sports goods and DIY goods carry that duty only above an annual turnover threshold and gives no figure. In France the figure for furniture is EUR 100,000 of delivered sales a year (France furniture EPR).

Etsy’s pages for Germany and Spain match the law: both require a representative from a seller established outside the country. France does too, by written mandate (L. 541-10-9-1, loi n° 2026-602 du 8 juillet 2026), and Etsy’s France page has not caught up. Packaging EPR shows where. Etsy’s German, French and Spanish pages describe the PPWR as applying from 12 August 2026 “alongside” the national packaging rules, and the German page still names the old Packaging Act (VerpackG). Etsy has no EPR page for another country that we could find. If the registrations are more than you want to take on, Etsy offers a way to opt out of selling to the countries GPSR covers. That is on GPSR on Etsy.

Amazon Pan-EU and EFN: Amazon ties EPR registration to where the buyer is, not to where the stock sits

Under Pan-European FBA you list offers in several Amazon stores, send stock to an EU fulfilment centre, and Amazon stores and moves it between the countries you enabled. Under cross-border fulfilment (EFN) your stock stays in one country and Amazon ships from there to buyers in other countries (Amazon, Pan-European FBA). For VAT the registrations follow the stock: see Amazon Pan-EU and EFN: you register where your stock is stored.

For packaging EPR the law reads the other way. You are the producer in a country where you make packaged products available for the first time on its territory directly to end users, and you register in each such country (Art. 3(15)(c)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (c)Click opens the article on EUR-Lex., Art. 3(15)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (d)Click opens the article on EUR-Lex., Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex.). “Making available on the territory of the Member State” is any supply for distribution, consumption or use there (Art. 3(11)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 11Click opens the article on EUR-Lex.). The test in points (c) and (d) is a supply “directly to end users” in that other country, so the law looks to where the buyer is, not to where the stock sits.

Amazon’s pages put it in terms of the buyer’s location, in these words:

• “Registration obligations are linked to where consumers are located, not only where you actively sell. If your products are available to Dutch customers through PAN-EU, you are required to register in the Netherlands.”
• A distinct country-specific number is needed for each EU country where you sell packaged products to customers. Amazon says this applies “also when selling cross-borders from EU store countries to EU non-store countries”, and that it is working to open the compliance portal for those countries (Amazon, new EU Packaging Waste Regulation).
• For Austria, where Amazon has no store: shipments go there from other stores, and “the EPR regulation requires producer compliance in all EU countries where products are shipped, not just where listings are created” (Amazon, Austria).

So a Netherlands or Belgium offer puts buyers there in front of you without any stock there. Amazon’s new-regulation page lists both countries among those whose registries are delayed, while its Pan-EU page makes an offer in each a condition of the programme (Amazon, Pan-European FBA and Amazon, storage options). The packaging you must register is not all of the parcel. Amazon says Fulfilment by Amazon sellers stay responsible for product packaging that arrives at the warehouse, and Amazon handles the shipping packaging it adds. Its Germany page says otherwise; see the end of the Amazon section above.

Who checks EPR, and what has happened to sellers

The EU texts leave penalties to each country, due by 12 February 2027 for packaging (Art. 68(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 68, paragraph 1Click opens the article on EUR-Lex.). Checks come from three places: the national authority, the marketplace and the fulfilment provider, and the public registers. The marketplace and fulfilment checks are in the section above; here is what the national sources show.

Germany, packaging. The ZSVR investigates irregularities and can ask a company for documents. Where it has specific grounds to suspect an administrative offence, it reports to the state authorities through the LUCID Authorities Portal, and the case is punished in the state where the company is located. A breach leads to a distribution ban on the packaging or the packaged goods. Fines go up to EUR 100,000 for not registering, EUR 200,000 for not taking part in a system and EUR 10,000 for a late data report, and profit from the saved costs can be confiscated. The register is public, so a competitor can look you up and complain to the authority or bring a civil case (ZSVR, monitoring).

The ZSVR publishes case reports. Nine are on its page, from 2020 to September 2026, and the page names no company. The closest to a cross-border seller is Case report 02/2025, headed “Online pharmacy has to make up for five years of non-compliance with the system participation requirement, paying millions”: an online pharmacy based abroad shipped to Germany for years without taking part in a system for its shipment packaging. The 2024 report concerns an online shop that sold deposit-bearing drinks without charging the deposit. All nine fall under the old Verpackungsgesetz, which the VerpackDG replaced on 12 August 2026; the page says new reports under the VerpackDG will be published there (ZSVR, case reports).

Germany, electrical equipment. An unregistered producer may not place equipment on the market, and distributors may not offer it, marketplace operators may not make the offer possible, and fulfilment services may not store or ship it (§ 6(2) ElektroG). Not registering, not naming an authorised representative and supplying unregistered equipment are administrative offences, with fines up to EUR 100,000, and the Federal Environment Agency is the authority for the registration-related ones (§ 45 ElektroG).

France. A producer that does not meet its EPR duties faces a fine of up to EUR 7,500 per unit or tonne and a daily penalty of up to EUR 20,000. A further fine of up to EUR 30,000 applies for not being registered, wrong data or no unique identification number on the required documents. The Ministry takes these decisions and publishes them, after the producer has had its say. Its page lists the published files: 7 for 2026 and 15 for 2025, with some marked as withdrawals or annulments. Six of the seven 2026 files are named after producer responsibility organisations (Alcome, Soren, Ecomaison, Valdelia, Valobat and Refashion), the bodies the sanction rule for organisations covers (L. 541-9-6). The 2025 list names companies as well as organisations. We did not open the decision files, so we cannot say how many concern sellers (Ministry for the Ecological Transition).

Spain. Not registering, and not giving the registered number where it must appear, is a serious infringement of Law 7/2022, with a fine of EUR 2,001 to 100,000. For the battery and electrical-equipment registers this rests on Ley 7/2022 additional provision 12, whose transitional wording ran to 10 April 2025. Selling products without meeting the EPR financial duties is also serious. It is very serious, with a fine of EUR 100,001 to 3,500,000, where it gravely disturbs public health, the environment or consumer safety. A fine can be raised to twice the benefit gained, and goods sold without meeting those financial duties can be seized (Art. 108-109 Law 7/2022).

Marketplaces. Amazon says it deactivates listings that lack a valid number, and Etsy asks for the number on its own pages. What follows from a missing number on each platform is in the Amazon section above.

What we cannot give is a count of sellers fined for missing EPR on a marketplace. The German case reports show that authorities act and publish. The French list mostly names organisations in 2026, and we did not open the files. Neither shows how often a small cross-border seller is the target. We read no enforcement source for Italy, Austria or the other countries.

• In the French administration’s words: “Tout produit soumis à REP mis sur le marché à destination des ménages fait l’objet d’une signalétique informant le consommateur que ce produit fait l’objet de règles de tri.” Unofficial translation: every product subject to EPR placed on the market for households carries a sign telling the consumer that the product is subject to sorting rules.
• Another common sign set by EU law or another EU country’s law may replace Triman, where that sign is mandatory and tells the consumer the same thing; the page gives the crossed-out bin for electrical and electronic equipment as the example.
• Household glass drink packaging is left out.
• Small products get a way out: under 10 cm² on the largest side (20 cm² for a cylinder or sphere), with no other document supplied, the logo and instructions may go on a digital medium instead.
• The page names its legal basis as the French Environment Code, articles L541-9 to L541-9-10 and L541-10 onward. It was last checked by the French administration on 4 August 2025.

Selling through a marketplace, you may give it a written mandate to meet the packaging cost duties of Art. 45(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 2Click opens the article on EUR-Lex. for you (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex., last subparagraph). Where a country’s battery register is not public, marketplaces get free access to it (Art. 55(13)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 13Click opens the article on EUR-Lex.).

What you can skip