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Entering the European market often starts with a familiar checklist. You check import duties, set up VAT, prepare your shipping plan, and make sure your products meet EU standards. Everything seems clear — until a new term appears in the compliance requirements: EPR for packaging. Suddenly there are more questions than answers. Does this apply to your business if your products are manufactured outside Europe? Do you really need to register in every country where you sell? And why are companies responsible for the waste created by their packaging?
Even more confusing might be that each country runs its own program, each has their own quirks and the obligations are not always explained in one place.
So in this article, we’ll walk through how EU packaging EPR works, why these regulations exist, and what responsibilities e-commerce sellers have when placing packaged products on the European market. Most importantly, we’ll show you how to prepare your business for these requirements before you start selling in the EU.
What is EPR and why it exists in the EU
If you’re planning to sell products in Europe, sooner or later you’ll come across the term Extended Producer Responsibility, or EPR. It might sound quite imposing at first glance, but it's actually pretty straightforward.
EPR is a system used across the European Union to make companies responsible for the packaging they place on the market. In practice, this means that businesses selling packaged products in the EU must register in national EPR systems, report how much packaging they introduce to the market, and pay fees that help finance the collection and recycling of packaging waste.
The EU introduced these regulations because packaging has become one of the largest sources of waste generated by consumer goods. Every product sold in Europe typically enters the market in some form of packaging — from product boxes and protective materials to shipping cartons used in e-commerce deliveries. Once the product reaches the customer, that packaging immediately becomes waste that must be collected, sorted, and recycled. And instead of leaving the issue to the municipalities, the system shifts part of that responsibility to the companies that introduce packaged products to the market.
Companies that place packaged products on the market must join a national packaging recovery scheme. These organizations organize the collection and recycling of packaging waste and require companies to report the amount of packaging they introduce to the market, and based on this data, businesses pay environmental fees that help fund the national recycling system.
One detail often surprises companies entering the European market though: there is no single EU-wide EPR registration. Although the principle of Extended Producer Responsibility is defined in EU legislation, the systems themselves operate at the national level. In practice, this means that if your business sells products in several EU countries, you typically need to register in each of those markets separately and report packaging volumes according to local requirements.
At this point, many e-commerce businesses start asking the same question: if the products are manufactured outside the EU, who is actually responsible for packaging compliance?
Why e-commerce sellers are considered “producers”
One of the most confusing parts of the EU packaging EPR system is the term “producer.” In everyday language, a producer usually means the company that manufactures a product - but in the context of EPR, however, the definition is different. Under EU packaging regulations, a “producer” is the company responsible for placing packaged products on the market in a specific country. In practice, this usually means the business that sells the product to the end customer in that market — even if the product itself was manufactured elsewhere. For e-commerce businesses selling to customers in Europe, this distinction is important as even if your products are manufactured in the United States or Asia, you may still be considered the “producer” under EPR rules if your company is the one introducing those packaged goods to customers in an EU country.
In practice, this responsibility usually falls on the company that sells the packaged product to the end customer in a specific EU country. For example, if a brand ships products from outside the EU directly to customers in Germany, France, or another EU market, that brand is typically responsible for complying with packaging EPR rules in that country. The same applies when products are sold through online channels. A brand selling through its own online store to customers in the EU, or using marketplaces such as Amazon to reach those customers, may still be considered the producer for packaging EPR purposes.
What matters is which company is responsible for placing the packaged product on that national market - and that's usually you, as the brand owner.
What packaging is covered by EPR
When companies first learn about packaging EPR, they often assume the rules apply only to the packaging of the product itself — for example the box, bottle, or container the item is sold in. But in fact, packaging EPR typically applies to all packaging that becomes waste once the product reaches the end consumer. This distinction is important because a single order often includes several different packaging elements. A product may be packed in its own retail box, placed inside a shipping carton, and secured with protective fillers such as paper or bubble wrap. In many national EPR systems, each of these materials must be included in the packaging volumes reported by the company. So now let's look at the exact elements of product packaging that typically falls under the EPR directive.
Product packaging
The first category is product packaging, sometimes referred to as primary or sales packaging. This is the packaging that directly contains the product and is usually part of how the product is presented to the customer.
Typical examples include:
product boxes and cartons
bottles, jars, tubes, or containers
blister packs
product sleeves or wrapping
internal inserts used to hold or protect the product inside the box
What matters for the EPR directive is whether that packaging is placed on the market together with the product and eventually becomes waste after the customer opens the package. If it does, companies are generally expected to include the material and its weight in their packaging reports as part of the company’s packaging declarations in national EPR systems.
Shipping packaging used in e-commerce
When a product is ordered online, it is usually placed inside additional packaging that protects it during transport, such as:
cardboard shipping boxes
plastic mailing envelopes or poly mailers
padded envelopes
outer cartons used to combine multiple items in one shipment
These materials also become waste once the package is opened by the customer. Because of this, most national EPR systems require companies to report the weight and type of these materials as well.
When companies start preparing their EPR reporting, many of them often focus only on the packaging designed for the product itself — such as the product box or container. However, in most e-commerce operations the product is also placed in an additional shipping box or mailing envelope before it is sent to the customer, these materials also reach the end consumer and therefore usually need to be included in the packaging volumes reported under EPR.
Protective and filling materials
Another category covered by packaging EPR includes the materials used to protect products during transport. These materials are commonly added to prevent damage during shipping, especially for fragile or sensitive items, such as:
bubble wrap
paper fillers or packing paper
air pillows or air cushions
foam protection
cardboard inserts or separators
Those items as well become a waste once the product is unpacked and for this reason, they must be included in the packaging quantities that must be reported under EPR.
How packaging EPR works across EU countries
Packaging EPR follows the same general principle across the European Union, but the systems themselves are organized at the national level - there is no single EU-wide registration for packaging EPR. Instead, each country operates its own system for managing packaging waste. Companies that place packaged products on the market must usually register in the national packaging register, report the amount of packaging they introduce to the market, and contribute financially to the recycling system through environmental fees. To manage these obligations, most countries work with producer responsibility organizations (PROs) as these organizations coordinate the collection, sorting, and recycling of packaging waste and handle the financial contributions paid by companies.
Their structure is similar across Europe, but the specific procedures typically vary from one country to another and each national system has its own registration process, reporting rules, and fee structure. As an example, let's look at three main European countries (Germany, France and Spain) systems.
Germany
Germany operates one of the most structured and strictly enforced packaging EPR systems in Europe under the German Packaging Act (VerpackG). The system is designed to ensure that companies placing packaged products on the German market contribute to the costs of collecting and recycling packaging waste generated by households. For companies selling into Germany, the first step is registration in the LUCID packaging register, managed by the Central Agency Packaging Register (ZSVR). During this process, businesses provide basic information about the company, confirm that they are subject to packaging EPR obligations, and identify the recycling system they will participate in.
Registration in LUCID is publicly visible. This means authorities, competitors, and online marketplaces can verify whether a company is properly registered. If a company is not listed in the register, it is not legally allowed to sell packaged products to consumers in Germany. Companies must also participate in a licensed recycling scheme, commonly referred to as a dual system. These organizations manage the collection and recycling of household packaging waste across Germany. Businesses sign a contract with one of the approved system operators and declare the amount of packaging they expect to place on the German market. Once sales begin, companies must regularly report the volume of packaging introduced to the market, usually broken down by material type such as paper and cardboard, plastics, glass, aluminum, or steel. Based on these reported quantities, the recycling system calculates environmental fees that the company must pay to support the national recycling infrastructure.
Germany is known for enforcing packaging EPR requirements strictly and companies that fail to register in LUCID or participate in a recycling system may face fines and can be prohibited from selling packaged goods in the country. Online marketplaces such as Amazon may also request proof of EPR registration before allowing sellers to list products for the German market.
France
France operates its packaging EPR system through organizations known as eco-organisations, which are approved by the government to manage packaging waste on behalf of companies placing products on the market. One of the largest and most widely used organizations for household packaging is CITEO. Companies selling packaged products to consumers in France must register with an authorized eco-organisation and sign a compliance contract before placing packaging on the French market. During the registration process, businesses provide details about their company and the types of packaging they use. Once registered, the company becomes part of the national system that finances the collection and recycling of household packaging waste.
After joining the system, companies are required to report the amount of packaging they introduce to the French market. These reports typically break down packaging by material type, such as paper and cardboard, plastics, glass, aluminium, or steel. The weight of each material category is used to calculate the environmental contributions that companies must pay.
A distinctive feature of the French system is the use of eco-modulation fees. This means that the amount companies pay can vary depending on how environmentally friendly their packaging is. Packaging that is easier to recycle or contains recycled materials may benefit from lower fees, while packaging that is difficult to recycle can result in higher contributions. The goal of this system is to encourage companies to design packaging that is easier to process within the national recycling infrastructure.
France also places strong emphasis on consumer information and transparency. Many products sold on the French market must display specific recycling instructions, such as the Triman logo, which informs consumers that the packaging should be sorted for recycling. For companies entering the French market, this means that packaging design and labeling may need to be adjusted to comply with national recycling guidance.
Spain
Spain has significantly strengthened its packaging EPR framework in recent years through updated waste regulations and the introduction of stricter reporting and registration requirements. Companies that place packaged products on the Spanish market must register in the national Producer Register for Packaging, which is managed by the Spanish Ministry for the Ecological Transition. This registration identifies the company as a producer responsible for packaging waste generated by the products it sells in Spain.
After registering, businesses must participate in an authorised packaging waste management system. These systems organise the collection and recycling of household packaging waste across the country and distribute the associated costs among the companies placing packaging on the market. Like other EPR systems in Europe, Spain requires companies to report the amount of packaging they introduce to the market. These reports typically include the weight of packaging materials broken down by category, such as paper and cardboard, plastics, glass, and metals. The reported quantities are used to calculate environmental fees that companies must pay to support national recycling operations.
Spain also requires companies to maintain records of the packaging they place on the market and submit periodic declarations to the relevant authorities or authorised compliance systems. For businesses selling from outside the EU directly to Spanish consumers, the regulations may require appointing an Authorised Representative in Spain who takes responsibility for managing EPR compliance and communication with the national register.
What e-commerce sellers must do to comply with packaging EPR
If you’re preparing to start selling in the European Union and haven’t yet dealt with packaging EPR requirements, the rules can look confusing at first. Many companies run into the same situation when they begin planning their EU expansion. The good news is that EPR compliance usually becomes much easier once you break it down into a few practical tasks.
The steps below explain what companies typically need to do to prepare for packaging EPR before selling products to customers in the EU.
1. Identify all packaging used in your fulfillment process
Before registering in any EPR system, companies usually need to identify the types of packaging used when delivering products to customers. This includes not only product packaging but also shipping packaging and protective materials used during transport.
For example, a typical e-commerce order may involve:
product boxes or containers
cardboard shipping cartons
plastic mailing envelopes
paper fillers, bubble wrap, or air cushions
Each of these packaging elements may need to be included in EPR reporting because they become waste once the customer opens the package.
2. Estimate packaging materials and weights
In most packaging EPR systems, companies are required to report the weight of packaging materials they introduce to the market, rather than simply the number of packages they ship. This means businesses must determine how much each packaging component weighs and which material category it belongs to. Companies usually start by analysing the packaging used for a specific product. For example, a product might be packed in a cardboard retail box, shipped in a larger cardboard carton, and protected with paper fillers or plastic cushioning. Each of these elements must typically be measured and assigned to a material category.
Once the weight of each packaging component is known, companies estimate how much packaging they will place on the market by multiplying these weights by their expected sales volume. If a product is sold thousands of times per year, even small packaging components can add up to significant amounts that must be reported to national EPR systems.
3. Register in national EPR systems
Because packaging EPR operates at the national level, companies generally need to register in each country where they sell packaged products to consumers. The registration process usually involves submitting your company information to a national packaging register or signing a compliance contract with an authorized recycling organization. During registration, you will typically be asked to provide:
company name and legal entity information
the markets where the products are sold
the types of packaging used
the recycling system or compliance organisation they will work with
In some countries, businesses located outside the EU must appoint an Authorised Representative who manages EPR compliance on their behalf. This representative acts as the company’s local contact for the national EPR system and is responsible for handling reporting and communication with the authorities. Regardless of whether an authorised representative is required, companies must usually complete EPR registration before placing packaged products on the market. In many EU countries, selling packaged goods without a valid registration can lead to fines or restrictions on market access.
4. Report packaging quantities placed on the market
After completing registration, companies are typically required to submit regular reports describing the amount of packaging they place on the market.
These reports usually include:
the total weight of packaging introduced during a specific reporting period
a breakdown of packaging by material type
in some cases, additional information about packaging categories or recyclability
Reporting frequency can vary depending on the country and the size of the business. Some systems require quarterly reporting, while others allow companies to submit annual declarations. Accurate reporting is important because the reported quantities determine the financial contributions companies must pay into the recycling system.
5. Pay environmental contributions to support recycling systems
Once packaging quantities have been reported, companies are required to pay environmental contributions, often referred to as eco-fees.
In most EPR systems, these fees are calculated based on the weight of packaging materials reported by the company. Each material category usually has a specific fee rate set by the national system or the producer responsibility organisation. When companies submit their packaging reports, the reported quantities are multiplied by these rates to determine the total environmental contribution.
For example, if a company reports a certain amount of paper and cardboard packaging, plastic packaging, and glass packaging introduced to the market during the reporting period, the recycling organization applies the relevant fee rate for each material type. The final contribution is calculated based on the total weight of each material category.
Keep in mind that if you sell in several EU markets, this process must usually be managed separately for each country, since the reporting systems, fee structures, and compliance procedures can differ between national EPR programs.
Preparing your business for packaging EPR before selling in the EU
When companies first come across packaging EPR requirements, the system can look more complicated than it really is. Different countries have their own registers, reporting rules, and recycling schemes, so at first it may feel like there are too many moving parts to keep track of. In reality, most businesses preparing to enter the EU market go through a similar process. The key is simply understanding what packaging you place on the market, registering in the relevant national systems, and setting up a way to track and report the packaging materials used in your shipments.
Once these elements are in place, EPR becomes another compliance step that can be managed alongside other market entry requirements such as VAT registration, customs procedures, or product labeling. The most important thing is not to leave it until the moment you are ready to start selling. Completing EPR registration and preparing your packaging data early helps avoid delays, marketplace restrictions, or compliance issues once your products begin reaching customers in the EU.
At FLEX Logistics, we regularly help e-commerce brands prepare their EPR registrations and set up packaging reporting processes across multiple European markets. If you’re planning to start selling in the EU and want to make sure everything is set up correctly from the beginning, feel free to reach out to our team. We’ll be happy to walk you through the requirements and help you organise the EPR process for your business.
