EPR packaging in the EU: who is the producer when you ship from outside the EU, and where to register

If you ship packaged goods from outside the EU to a buyer in an EU country, you are the packaging producer in that country under the Packaging and Packaging Waste Regulation (PPWR). The duty covers the shipping box and the packaging the product comes in (Art. 3(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 8Click opens the article on EUR-Lex., 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.). The producer registers in that country, pays the country’s scheme to take the packaging back, and reports the weights. Germany, Spain and France also want a representative on their soil. The EPR guide covers the other three streams: electrical goods, batteries and textiles.

What you do:

1. List each EU country where you make packaging or packaged products available for the first time directly to a buyer. A buyer can be a consumer or a business, and the sale can be a web order, a phone order or a postal order (Art. 3(14)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 14Click opens the article on EUR-Lex., 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(23)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 23Click opens the article on EUR-Lex.). In each of them you are the producer.
2. Total the packaging you send into each country in a year, by material: the box or mailer, tape, filler, inner packs and the product’s own packaging. The section on weights below shows what each country asks for.
3. Before your first sale in Germany, Spain or France, appoint a representative there. Germany asks for a written mandate in German and only one representative (§ 5(2), § 5(4) VerpackDG). Spain asks you to designate one on Spanish territory (Art. 17.2 RD 1055/2022). France asks for a written mandate too, unless a marketplace established in France meets your duties for the product (L. 541-10-9-1, loi n° 2026-602 du 8 juillet 2026).
4. Register in each country before the first sale. Germany: LUCID, free. Spain: the register at the Ministry for the Ecological Transition. France: you get your number when you join a scheme (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex., Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex.).
5. Join the country’s scheme and pay it: a “system” in Germany, one of three organisations for household packaging in France, a collective system such as Ecoembes in Spain. If you sell to business buyers in France, a separate scheme for professional packaging starts on 1 January 2027, and ADEME asks you to join an organisation before 31 December 2026 (ADEME).
6. Report every year. The EU date is 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.); each country sets its own channel and date.
7. Give each marketplace and fulfilment provider the registration number for the buyer’s country and your self-certification (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex., Art. 45(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 7Click opens the article on EUR-Lex.).
8. In France, put the Triman logo and the sorting instructions on the packaging (Triman logo in France).

Do nothing, and you may not make the packaging available in that country (Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex.). A marketplace that falls under the Digital Services Act rules must hold your number first (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex., Art. 29(1)Regulation (EU) 2022/2065, Digital Services ActArticle 29, paragraph 1Click opens the article on EUR-Lex.). Each country sets penalties; Germany’s go up to EUR 200,000 for selling without a system (§ 66(1) no. 3, § 66(3) VerpackDG).

A seller outside the EU is the packaging producer in the buyer’s country

The PPWR defines a producer as “any manufacturer, importer or distributor” to whom one of five cases applies, “irrespective of the selling technique used, including by means of distance contracts” (Art. 3(15)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15Click opens the article on EUR-Lex.). A distance contract is the one in the Consumer Rights Directive, a contract concluded with no physical presence of both sides (Art. 3(14)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 14Click opens the article on EUR-Lex.). Two of the five cases are written for you: the manufacturer, importer or distributor is “established in a Member State or in a third country” and makes available for the first time on the territory of another EU country, directly to end users, either transport, service or primary production packaging (case c) or products packaged in other packaging (case d) (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.). A shipping box for an online sale is transport packaging (Art. 3(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 7Click opens the article on EUR-Lex., Art. 3(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 8Click opens the article on EUR-Lex.), so it falls under case c. The product’s own sales packaging falls under case d.

An end user is a person that resides or is established in the EU and does not make the product further available in the form supplied, so a business that buys for its own use counts (Art. 3(23)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 23Click opens the article on EUR-Lex.). An importer is a person established in the EU, so you are not the importer when you ship from outside it (Art. 3(17)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 17Click opens the article on EUR-Lex.); you are the manufacturer or the distributor of the packaging and the producer through case c or d. The German register reads it the same way: a company abroad that ships packaged products directly to end users in Germany is at least the manufacturer and the producer of the packaging it ships with, whether it sits in another EU country or in a third country (ZSVR).

Registering means one register per country, and no EU-wide number

You apply to the competent authority of each country where you make packaging or packaged products available for the first time, and you may not make them available there before you are registered (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex., Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex.). The application names your business and brands, the single contact point, your trade register number and tax number, your representative if you have one, and a declaration of how you meet your producer duties (Annex IX, Part A). The authority grants the registration and a number within twelve weeks of a complete application, and may charge a cost-based fee (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. 44(11)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 11, point (d)Click opens the article on EUR-Lex.). Each country publishes its list of registered 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.). If you have joined a producer responsibility organisation, it meets the registration duty for you unless the country says otherwise; a country may also let an authorised representative do it (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex., Art. 44(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 3Click opens the article on EUR-Lex., Art. 46(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 46, paragraph 1Click opens the article on EUR-Lex.).

A representative is required in Germany, Spain and France

The authorised representative for extended producer responsibility is a person established in the country where you make the packaging available, other than the country where you are established, appointed by you (Art. 3(20)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 20Click opens the article on EUR-Lex.). The PPWR splits the duty in two. A producer established in another EU country must appoint one in each country it sells into. A country may require the same of a producer established in a third country (Art. 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex.). Who can act, and for which goods and countries, is on EPR authorised representative. It is not the GPSR role: that one is the EU responsible person.

Germany uses the option for sellers outside the EU: the producers of Article 45(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex., second sentence, “haben einen Bevollmächtigten … zu benennen” (must name a representative), before the first making available (§ 5(2) VerpackDG). The representative acts in its own name and counts as a producer for the duties it takes over (§ 5(3) VerpackDG). Registration is not one of them: “This is a personal duty that you have to fulfil yourself”, and LUCID will not let you finish registering without the representative’s details (ZSVR). The representative can be any person with a registered office or branch in Germany that is not affiliated with you, and needs its own LUCID login. The ZSVR publishes no list of representatives and says representatives charge fees, with no figure (ZSVR).

In Spain, producers established in another EU country or in a third country that sell in Spain must designate a person on Spanish territory as authorised representative (Art. 17.2 RD 1055/2022). The Ministry adds two points: you need none if you already have a Spanish subsidiary, and the representative registers you and reports for you, while a collective system cannot do either without a mandate from you (MITECO).

In France, Article 5 of Law no. 2026-602 of 8 July 2026 inserted L. 541-10-9-1 into the Environment Code. A producer subject to extended producer responsibility that is not established in France “désigne, par mandat écrit, une personne physique ou morale établie en France en tant que mandataire” (designates, by written mandate, a natural or legal person established in France as its representative). The rule covers sellers in other EU countries and sellers outside the EU alike. The duty counts as met for products for which a marketplace established in France meets the producer obligations (L. 541-10-9-1, the text as Ineris reproduces it; the Sénat table of the loi n° 2026-602 du 8 juillet 2026). Citeo, one of the three organisations you can join, had already written in September 2025 that producers established in an EU country must name a representative in France (Citeo). ADEME’s page on the unique identification number still says a producer “may” assign an authorised representative and shows no date, so it predates the law (ADEME). The Légifrance text itself returned an access block to our fetch. The registration number and the roles are set out in the EPR registration number guide. What France adds for packaging, with the three organisations, their fees and the declaration dates, is on France packaging EPR. What Italy adds, with CONAI, its voluntary membership for foreign companies and the national register, is on Italy packaging EPR.

How Germany, France and Spain differ at a glance

What each country charges: LUCID is free, France starts at EUR 110, Spain prices by the kilogram

The PPWR leaves the amounts to each country. It lets the register authority charge cost-based fees for processing the registration, and it says the producer’s contributions must cover the cost of labelling waste bins and of waste surveys (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. 45(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 2Click opens the article on EUR-Lex.). What a scheme may charge, and how fees move with recyclability, is on the EPR guide and in EPR fees.

Germany. Registration in LUCID is free. The cost of a system depends on the volume and material of your packaging, and you pick the system operator; the ZSVR lists the operators and says it may not share information about prices (ZSVR, ZSVR, ZSVR). Neither § 6 nor § 7 VerpackDG names a minimum quantity for registering or for joining a system. Shipping packaging always needs a system (ZSVR). We found no official price list.

France. Three organisations are accredited for household packaging for 2025 to 2029: Adelphe, Citeo and Leko (ADEME). Citeo’s 2026 guide sets a minimum billing of EUR 110 excluding VAT. Below 10,000 units of sale a year, you pay that flat amount. From 10,000 to 500,000 units you may declare by product family at a tariff per unit, with no technical data to give. A family exists for products shipped in a parcel, described as suited to marketplaces and their sellers (Citeo). We read only Citeo’s guide, not the price lists of Adelphe or Leko.

Spain. We found no registration fee on the Ministry’s page. Ecoembes publishes prices per kilogram for 2027. For household packaging: paper and cardboard EUR 0.117, steel EUR 0.197, aluminium EUR 0.040, plastic film and flexible packaging EUR 1.269. For commercial and industrial packaging it lists EUR 0.0025 per kilogram through its integrated management and, for other management, EUR 0.037 for paper and cardboard (Ecoembes). The page notes that the commercial prices are indicative until the 2027 ones are final. We did not find which of the two categories a shipping box falls under.

Marketplaces and fulfilment providers check your registration before you sell

A platform that lets consumers conclude distance contracts with you, and that falls under Section 4 of Chapter III of the Digital Services Act, must obtain two things before you use it: your registration in the country where the consumer is, with the number, and your self-certification that you meet the producer duties there (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex.). It must make best efforts to judge whether they are complete and reliable, and a country may allow an automated check against its register (Art. 45(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 5Click 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.). That Section does not apply to a micro or small platform, nor for 12 months after it loses that status unless it is a very large platform (Art. 29(1)Regulation (EU) 2022/2065, Digital Services ActArticle 29, paragraph 1Click opens the article on EUR-Lex., Art. 29(2)Regulation (EU) 2022/2065, Digital Services ActArticle 29, paragraph 2Click opens the article on EUR-Lex.).

A fulfilment service provider gets the same information from you when you sign its contract, checks it, and suspends its service for your packaged goods offered to EU consumers if you do not correct what is wrong (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.). You can challenge the suspension before a court of the country where the provider is established (Art. 45(9)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 9Click opens the article on EUR-Lex.).

The countries add to this:

• Germany. A distributor may not make packaging available when the producer is not registered or has no system participation, and a fulfilment provider may not serve an unregistered producer. The ZSVR gives platforms and fulfilment providers an automated data comparison with LUCID (§ 13(3), § 13(4) VerpackDG).
• France. A marketplace is the producer for the quantities it places on the market for third parties, unless it holds proof that they have an IDU (ADEME, Ministry). Neither page says the PPWR changed this rule.
• Spain. Platforms obtain your Spanish register number and a self-certification that you belong to a system and, if you sell from outside Spain, have a representative. They check the public register list, and from 12 August 2026 they are no longer producers by default (MITECO).

If you sell through a marketplace, you may give it a written mandate to meet the cost duties of Article 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).

Packaging weights: you report totals by material, not a weight for each product

No text we read asks for a weight per SKU. The rules ask for totals per country, per material, per year. The EU data for the yearly report is the weight of each packaging category of Annex II, Table 1, which lists 22 of them. A producer that makes less than 10 tonnes available in a country in a year reports only seven rows: glass, plastic, paper and cardboard, ferrous metal, aluminium, wood and other, plus the total (Art. 44(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 7Click 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., Annex IX Part B, Annex II Table 1). A country may ask for reports every quarter (Art. 44(9)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 9Click opens the article on EUR-Lex.). Each country then says how.

• Germany. The system participation agreement and the LUCID report both hold the material type and the mass, in kilograms to the third decimal. The ZSVR says to get material, weight and volume from your suppliers early, and lists as shipping packaging the boxes and bags and also the labels, adhesive tape and filler (ZSVR, ZSVR).
• Spain. Weight by type of material and the number of units. You count every element: the main item, lids and closures, handles, applicators and seals, and the fixing and protection elements, among them straps, filler material and bubble wrap (Annex IV, point 2, RD 1055/2022).
• France. The simplified declaration needs no weights: you count the units sold per product family and Citeo applies a tariff that is “ajusté produit par produit” (adjusted product by product), “et vous n’avez donc pas de données techniques à fournir” (so you have no technical data to supply). It is open from 10,000 to 500,000 units. For the bonus and penalty system, Citeo points to the declaration by unit (Citeo).

We found no official method for averaging or sampling weights over many products. The totals you need are what leaves your warehouse for each country: the parcels sent, times the weight of the box or mailer type used, plus the product packaging of each item shipped. Weigh each box and mailer type once and keep the figure.

Buying ready-made packaging does not make your supplier the producer of your parcels

Two questions get mixed up. Who is the manufacturer decides who owes the conformity paperwork, with one exception for micro-enterprises below. Who is the producer decides who owes the registration and the recycling fee. The PPWR treats them separately (Art. 3(13)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13Click opens the article on EUR-Lex., Art. 3(15)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15Click opens the article on EUR-Lex.).

• Your name or brand on the packaging. If you have packaging designed or made under your own name or trademark, you are the manufacturer, “regardless of whether any other trademark is visible”, so a supplier’s name beside yours changes nothing (Art. 3(13)(a)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (a)Click opens the article on EUR-Lex.). Importing or distributing under your own name has the same effect (Art. 21Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 21Click opens the article on EUR-Lex.). The supplier owes you the information and documents you need (Art. 16(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex., ZSVR).
• Producer is a separate test. You are the producer of the parcel you send to a buyer in another country, because you are the one that makes it available there for the first time, directly to that buyer (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.). Buying a compliant box does not move that.
• Unbranded shipping packaging. The ZSVR says that if you put materials together, such as a carton, tape and filler, you are the manufacturer and the producer of the unit you complete. If you change a box that is already complete in a way that could affect its recyclability, you become the manufacturer under Article 21Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 21Click opens the article on EUR-Lex. (ZSVR).
• A micro-enterprise with an EU supplier. If a micro-enterprise has packaging made under its own name and the supplier of that packaging is located in the EU, the supplier is the manufacturer for the conformity paperwork of Article 15Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15Click opens the article on EUR-Lex., so it hands that paperwork to the supplier (Art. 15(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 12Click opens the article on EUR-Lex., Art. 21Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 21Click opens the article on EUR-Lex., second subparagraph). This is true wherever in the EU the supplier sits, and it does not depend on where you are established. If the supplier is outside the EU, this rule does not apply and the paperwork stays with you.
• A supplier in the same country, and you are a micro-enterprise. The general manufacturer definition moves the label to the supplier only where the supplier is located in the same EU country as the brand owner (Art. 3(13)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (b)Click opens the article on EUR-Lex.). The ZSVR reads that as: the supplier is also the producer. For a micro-enterprise that orders from another EU country or from outside the EU, the ZSVR says the micro-enterprise itself is the manufacturer (ZSVR). Point (b) compares the country of the brand owner with the country of the supplier, and a seller established outside the EU is in no EU country, so on its words it does not reach you. That limit does not touch the paperwork rule above.

Germany: LUCID, a German representative and a system, in six steps

Germany applies the PPWR through the Verpackungsrecht-Durchführungsgesetz (VerpackDG) of 13 July 2026, in force since 12 August 2026. What Germany adds, down to what to type in each LUCID field, is on LUCID packaging registration in Germany.

1. Appoint one authorised representative in Germany, by a written mandate in German, before your first sale (§ 5(2), § 5(4) VerpackDG).
2. Register in LUCID yourself, before the first sale: company data, the representative, your brand names and your packaging (§ 6(1), § 6(2) VerpackDG). The representative takes over everything else, not this step.
3. Your authorised representative joins one or more systems in its own name, for packaging that ends up with households, shipping boxes included, before your first sale. It states the material, the mass and your LUCID number (§ 7(1), § 5(2) VerpackDG).
4. Report the same material and mass to LUCID without delay. If you made available under 10 tonnes of such packaging in the previous year, report once a year, by 1 June (§ 9(1), § 9(2) VerpackDG). A service provider cannot file it for you; your authorised representative can (§ 5(1), § 5(2) VerpackDG).
5. Give your LUCID number to each marketplace and fulfilment provider.
6. By 15 May each year, file a declaration of completeness for the previous year, checked by a registered expert or auditor. You are exempt below 80 tonnes of glass, 50 tonnes of paper and cardboard and 30 tonnes of each other material, unless the ZSVR or the state authority asks for one (§ 10(1), § 10(4) VerpackDG).

The deadlines of the changeover are in § 68. Whoever was registered under the old Verpackungsgesetz counts as registered, and must make the changes the new law requires by 12 November 2026. A producer that has to register for the first time under the new law, and was not obliged under the old one, had to register by 12 September 2026. That deadline is for businesses newly in scope. The ZSVR says online retailers have often been producers in practice already, and a seller new to the German market registers before its first sale under § 6(1). A system participation made before 12 August 2026 runs on for 31 December 2026 at the longest (§ 68(1), § 68(2) VerpackDG).

France: an accredited organisation, an IDU and the Triman logo

France asks you to join an accredited producer responsibility organisation, which registers you and gives you your unique identification number, the IDU (ADEME). A producer not established in France must also designate a representative established there by written mandate, unless a marketplace established in France meets its duties for the product (L. 541-10-9-1, loi n° 2026-602 du 8 juillet 2026).

1. Pick one of the accredited organisations for household packaging: Adelphe, Citeo or Leko (ADEME).
2. Join it and send your details. For a company outside France, ADEME asks for an intra-Community VAT number or, if you have none, the registration number issued by the tax authority of your country of residence. In a collective scheme you cannot register as an individual: the organisation registers you in ADEME’s declaration tool and sends the IDU (ADEME).
3. Show the IDU in your general terms of sale and on your website (ADEME).
4. Declare your packaging to the organisation every year, for the previous year. The organisation sends it to ADEME by 31 May (Service Public Entreprendre).
5. Put the Triman logo, or another mandatory EU sign, next to the sorting instructions your organisation sets. They go on the product, on its packaging, or on the documents supplied with it if neither is possible. Household drink packaging made of glass is left out. Under 10 cm² on the largest side, with no other document supplied, both may go on a digital medium instead; from 10 to 20 cm² only the instruction may (Service Public Entreprendre).

A producer that does not meet these duties faces a fine of up to EUR 7,500 per unit or tonne of product placed on the market, a daily penalty of up to EUR 20,000, and a further fine of up to EUR 30,000 for not being registered, for wrong data or for leaving the IDU off the documents that must show it (Ministry). The Triman duty has a fine of its own. Failing the sign and the sorting instruction of L. 541-9-3 is punished under L. 541-9-4, up to EUR 3,000 for a person and EUR 15,000 for a company (L. 541-9-4), and the Ministry says it can be applied per product without the sign (Ministry FAQ, question 9). The marks themselves are on packaging recycling symbols.

Spain: the producer register at the Ministry, a Spanish representative and a system

1. Designate your representative on Spanish territory (Art. 17.2 RD 1055/2022).
2. Your representative registers you in the packaging section of the producer register through the Ministry’s electronic office. The application gives the category of packaging, whether it is single-use or reusable, and the system you belong to. Attach a one-page certificate of membership of the collective system, and do it within a month of joining it (MITECO).
3. You get a number in the form ENV, the year, and nine digits. It goes on your invoices and other documents that accompany the sale (MITECO).
4. Report each year the weight by type of material and the number of units (Annex IV RD 1055/2022). For 2026 the window runs to 31 March 2027 inclusive (MITECO’s page says it opens on 2 January; procedure sheets SIA 2962548 and SIA 2945277 say 1 January), and a missing declaration is an administrative infringement under Article 108 of Ley 7/2022. The Ministry gives a special rule for 2026: you declare what you made available before and after 12 August 2026 according to who counted as the producer on the date of the sale. Under 15 tonnes a year, the declaration is simplified (MITECO, Art. 16 RD 1055/2022).
5. Change the registered categories or systems between 1 October and 31 December each year (MITECO).
6. Household packaging must say which container it goes in; where the materials separate easily, it names the container for each (Art. 13(2) RD 1055/2022).

What Spain adds for packaging, with the representative route, the collective systems, the penalties and the 2026 declaration, is on Spain packaging EPR.

What the law leaves open

• A non-EU seller that sells from stock in an EU warehouse. Cases c and d of Article 3(15) look at where you are established and at the buyer, and do not say where the parcel starts. The ZSVR describes the case as one where a foreign company “ships from abroad directly to a (private or commercial) end user” (ZSVR). No official text we read says how a seller outside the EU that sells to a buyer in the same country from an EU warehouse is treated. On the words of the definition you are still the producer there.
• A box that your EU supplier already counts. The ZSVR says that the first company in a supply chain that supplies complete, unbranded packaging is the producer of the empty packaging. Nothing we read says whether that relieves the seller that fills it and ships it abroad. Until an official text says so, treat the shipper as the producer of its own parcels.
• Spain: transport packaging from couriers. Article 17.5 of Real Decreto 1055/2022 makes courier companies meet the producer duties for the transport packaging they supply in distance sales, and platforms for the same packaging when they facilitate a third party’s sale. The Ministry’s page on the 2026 changes does not say whether that provision still applies next to the PPWR definition.