What Is EPR in the EU? A Seller's Guide

By Operator One Editorial — 13 September 2026

Key takeaways

Extended Producer Responsibility (EPR) makes the producer of packaging, electrical equipment, batteries and, soon, textiles pay for and organise the end-of-life management of those products, under the Waste Framework Directive and stream-specific EU laws.
There is no single EU-wide EPR registration: a seller registers per Member State and per stream, so 8 markets across 3 streams can mean up to 24 registrations.
The Packaging and Packaging Waste Regulation (EU) 2025/40 has applied since 12 August 2026, but as of September 2026 its harmonised national producer registers under Article 44 are not yet legally due.
The producer is whoever first makes the product available in a Member State, which can be the brand, a reseller, an importer or a Merchant of Record, and not automatically the brand owner.
Marketplaces must collect EPR registration numbers for the consumer's Member State before letting a producer sell, and missing numbers can restrict or remove listings.

What it is

Extended Producer Responsibility (EPR) is a set of measures under which producers of products bear financial responsibility, or financial and organisational responsibility, for managing the waste stage of a product's life cycle, as defined in Article 3(21) of the EU Waste Framework Directive 2008/98/EC, inserted by Directive (EU) 2018/851. In practice, the producer registers in each country, finances collection and recycling, usually through a producer responsibility organisation (PRO), and reports quantities sold.

EPR is a producer obligation, not a product certificate: it attaches to the entity that sells or first makes a product available in a given country, and it does not transfer between entities. For related terms such as authorised representative, PRO and UIN, see the compliance glossary.

The legal basis

The framework: Waste Framework Directive Article 8a

Article 8a of the Waste Framework Directive, as amended by Directive (EU) 2018/851, sets general minimum requirements for every EPR scheme in the EU, covering defined roles, targets, reporting and equal treatment of producers. Under Waste Framework Directive Article 8a(7), EPR schemes set up before 4 July 2018 had to comply with those minimum requirements by 5 January 2023. Waste Framework Directive Article 8a(4)(a) requires producer contributions to cover waste management costs, although that cost-coverage rule does not apply to schemes under the End-of-Life Vehicles, Batteries and WEEE Directives. Waste Framework Directive Article 8a(4)(b) requires fees to be modulated by product characteristics such as recyclability (eco-modulation), and Article 8a(4)(c) caps contributions at what is necessary to provide the service cost-efficiently. Waste Framework Directive Article 8a(5) says Member States shall allow producers established in another Member State to appoint an authorised representative and may lay down requirements for that representative; the mandatory appointment rules come from the stream laws below.

Packaging: Regulation (EU) 2025/40 (PPWR)

The Packaging and Packaging Waste Regulation (EU) 2025/40 was signed on 19 December 2024, following the Council decision of 16 December 2024, and has applied since 12 August 2026 as a directly applicable regulation, although many of its obligations carry later dates, such as Article 67(5) from 12 February 2029. PPWR Article 70(1) repeals the Packaging Directive 94/62/EC with effect from 12 August 2026, subject to transitional exceptions. PPWR Article 3(1)(15), points (c) and (d), makes a business that supplies packaged products directly to consumers in another Member State the producer in that Member State, which means whoever sells or first makes the packaging available there (brand, reseller or MoR). PPWR Article 44(2) requires producers to register in each Member State where they first make packaging available, and a PRO can meet that obligation on the producer's behalf unless the Member State specifies otherwise. PPWR Article 45(3) requires producers under points (c) and (d) to appoint an authorised representative in each Member State other than their Member State of establishment, and lets Member States require the same of third-country producers. PPWR Article 45(2) adds the costs of labelling waste receptacles under Article 13 and of compositional surveys to what producers fund. PPWR Article 6(8) modulates fees by recyclability performance grade, starting 18 months after the implementing acts under Article 6(4) and 6(5) enter into force, and PPWR Article 7(7) separately allows modulation by recycled content.

Batteries, electronics, textiles and single-use plastics

Under Article 96(c) of the Batteries Regulation (EU) 2023/1542, Chapter VIII on extended producer responsibility has applied since 18 August 2025. Batteries Regulation Article 3(47)(d) treats a distance seller as a producer, so an electronics seller owes battery EPR as well as WEEE EPR. The WEEE Directive 2012/19/EU makes a distance seller a producer under Article 3(1)(f)(iv) and requires registration in the Member State of sale under Article 16. Directive (EU) 2025/1892 of 10 September 2025 adds textile EPR as Articles 22a to 22d of the Waste Framework Directive, with a transposition deadline of 17 June 2027. The Single-Use Plastics Directive (EU) 2019/904 Article 8 imposes EPR, including clean-up and awareness-raising costs, on the products listed in Part E of its Annex, such as tobacco filters, wet wipes and balloons.

Who it applies to

EPR applies to the producer as each law defines it, and a common error is to assume the brand owner is always the producer. Depending on who first makes a product available in a Member State, the producer may be the manufacturer, the importer, the distributor or a third-country distance seller shipping direct to consumers. An EU-established Merchant of Record that sells as seller of record generally fits the producer definition in the countries where it sells, but that must be confirmed per country and per stream.

Packaging: any business that first makes packaged products available in a Member State, under PPWR (EU) 2025/40; in Germany the VerpackDG replaced the VerpackG from 12 August 2026.
Electrical and electronic equipment: producers under WEEE Directive 2012/19/EU, where Article 17 requires an EU-established distance seller to appoint an authorised representative in the destination Member State.
Batteries: producers under Batteries Regulation (EU) 2023/1542, where Article 56(3) requires a distance seller to appoint an authorised representative in each Member State it sells in.
Textiles: Waste Framework Directive Article 22a(14) requires Member States to set up textile EPR schemes by 17 April 2028 for the products in Annex IVc, with mattresses optional under Article 22a(2); Article 22a(3) requires an authorised representative, which a PRO can fulfil under Article 22a(4), and Article 22b(2) requires registration per Member State.
Single-use plastics: producers of the Part E products under Directive (EU) 2019/904, where Article 8(7) sets the authorised representative rule.

Country rules differ, and this page does not repeat them. See our country guides: France EPR and the UIN for the AGEC streams; Germany EPR (LUCID, stiftung ear, batteries) for the VerpackDG regime; Spain EPR under RD 1055/2022 for packaging enforcement; Italy EPR (CONAI, RAEE, batteries); Netherlands EPR (Verpact, WEEE NL); Belgium EPR (Fost Plus, Valipac); Poland BDO packaging registration; Portugal EPR; Czechia and Slovakia EPR; and Austria, Sweden and UK EPR.

How to get it, step by step

Map products to streams and countries. List every Member State you ship to and every stream your products touch: packaging under PPWR (EU) 2025/40, electronics under WEEE Directive 2012/19/EU, batteries under Regulation (EU) 2023/1542, textiles and single-use plastics. Eight markets across three streams can mean up to 24 separate registrations.
Identify the producer in each country. Apply PPWR Article 3(1)(15), Batteries Regulation Article 3(47) and WEEE Article 3(1)(f) to find who first makes each product available in each Member State: brand, importer, reseller or Merchant of Record. The registration belongs to that entity and cannot be moved to another company later.
Appoint an authorised representative where required. In Germany, stiftung ear does not let a foreign company register itself for WEEE: a German authorised representative must be appointed by a written mandate in German, signed by both parties, for at least 3 months. ZSVR requires the same for a foreign company without a German branch selling directly to end users.
Register with the national register. In Germany, register packaging in the LUCID register run by ZSVR before first placing on the market, entering master data, packaging types, brand names and a declaration; LUCID registration is free. In France, the PRO registers its member in ADEME's SYDEREP system, which issues one UIN per scheme, while producers running an individual system apply through ADEME.
Join a compliance scheme and pay fees. In Germany, VerpackDG Section 7 requires a system participation agreement with a dual system for consumer packaging, and in the EU generally producers entrust their obligations to an authorised PRO under PPWR Article 46(1), which Member States may make mandatory. Scheme fees are eco-modulated by the PRO and are not set by the register.
Load numbers into marketplaces and report. Enter each registration number, such as the 13-digit LUCID number, in the marketplace's EPR settings, and show the French UIN in your terms of sale. Then file periodic volume reports; Germany's VerpackDG Section 5(1) does not allow registration or data reports to be delegated to commissioned third parties.

EPR structure by stream (EU level, as of September 2026)

Stream	EU instrument	Distance seller is producer	Authorised representative	Platform check in EU text	Key date
Packaging	Regulation (EU) 2025/40 (PPWR)	Art. 3(1)(15)(c) and (d)	Art. 45(3), each Member State other than establishment	Yes, Art. 45(4)	Applies from 12 August 2026
Batteries	Regulation (EU) 2023/1542	Art. 3(47)(d)	Art. 56(3), each Member State sold to	Yes, Art. 62(6)	EPR chapter from 18 August 2025
Electrical and electronic equipment	Directive 2012/19/EU (WEEE)	Art. 3(1)(f)(iv)	Art. 17(2), destination Member State	No clause in the Directive	Registration under Art. 16
Textiles	Directive (EU) 2025/1892 (WFD Arts 22a to 22d)	Per national transposition	Art. 22a(3), PRO can fulfil it under Art. 22a(4)	Yes, Art. 22a(13)	Transposition 17 June 2027; schemes by 17 April 2028
Single-use plastics	Directive (EU) 2019/904	Per national transposition	Art. 8(7)	Not in Art. 8	EPR under Art. 8

On timing, an Amazon-commissioned study published on 15 May 2026 found that EPR registration takes 2 to 6 weeks per country and counted 64 distinct data fields across 10 countries, from 11 fields in Belgium and Spain to more than 20 in Sweden, with an average of 16. stiftung ear's costs-and-fees guide, consulted in September 2026, gives a quarterly fee of EUR 3.80 per battery type as an example, without an effective date.

What happens if you skip it

Germany, packaging: under VerpackDG Section 66, failing to register can be fined up to EUR 100,000, and placing system-participation packaging on the market without joining a dual system can be fined up to EUR 200,000.
France: according to ADEME, breaches of the UIN rules can lead to a fine of up to EUR 30,000 plus a daily penalty of up to EUR 20,000, and ADEME can withdraw a UIN.
Batteries, EU-wide: Batteries Regulation Article 55(2) says a producer may only make batteries available in a Member State once registered there through its electronic system.
Marketplace access: under PPWR Article 45(4), an online platform must not let a producer offer packaged products to consumers in a Member State until it holds that producer's registration details and self-certification, and PPWR also requires fulfilment service providers to swiftly suspend services to non-compliant producers, with a right of challenge under Article 45(9).

How marketplaces check

PPWR Article 45(4) requires online platforms, before allowing a producer to use their service, to obtain the producer's registration information for the consumer's Member State, including registration numbers, and a self-certification that the producer offers only compliant products. PPWR Articles 45(5) and 45(6) require platforms to make best efforts to assess whether that information is complete and reliable, including through automated checks. Under the last subparagraph of PPWR Article 45(4), a platform can meet a producer's Article 45(2) cost obligations by written mandate, but that does not cover registration or reporting. Batteries Regulation Article 62(6) sets comparable platform duties, and Article 55(13) makes the battery producer registers freely accessible. For textiles, Waste Framework Directive Article 22a(13) requires platforms to collect registration details for the consumer's Member State and a self-certification before use.

The WEEE Directive contains no online-platform verification clause, so WEEE checks rest on national law and on the Digital Services Act (EU) 2022/2065. DSA Article 30(1)(d) and (e) require platforms to collect a trader's trade-register details and a self-certification of compliance, Article 30(2) requires best efforts to verify that information, and Article 30(3) requires swift suspension where it stays inaccurate.

On Amazon's German seller EPR page, sellers in Germany enter the 13-digit LUCID registration number and the stiftung ear registration, France lists several EPR categories, and Amazon states that missing EPR data may restrict or remove listings or lead to deactivation, with Amazon complying on the seller's behalf in some cases. Because each check is against the number for the consumer's Member State, a German LUCID number does not cover France, Spain or Italy.

Frequently asked questions

Is there one EU-wide EPR number?

No. Under PPWR Article 44(2), WEEE Article 16, Batteries Regulation Article 55(2) and WFD Article 22b(2), registration is per Member State and per stream, and marketplaces check the number for the consumer's Member State.

Are the PPWR harmonised packaging registers live in September 2026?

Not under PPWR. Article 44(1) gives Member States 18 months from the first implementing act on register format, which Article 44(14) required by 12 February 2026; packaging-journal.de reported on 10 August 2026 that the act was still a draft, so that 18-month clock has not started.

Is the brand owner always the producer?

No. The producer under PPWR Article 3(1)(15), Batteries Regulation Article 3(47) and WEEE Article 3(1)(f) is whoever sells or first makes the product available in that Member State: brand, importer, reseller or Merchant of Record.

Can a third party register for me?

Sometimes. PPWR Article 44(3) lets Member States allow an authorised representative to register under a written mandate, but Germany's VerpackDG Section 5(1) excludes delegating registration and data reports to commissioned third parties, so check each country.

Do I need battery EPR if I sell electronics?

Usually yes. Batteries Regulation (EU) 2023/1542 Article 3(47)(d) treats distance sellers as producers, so a seller of devices with batteries owes battery EPR in addition to WEEE EPR in each Member State of sale.

Will the authorised representative requirement be dropped?

Not yet. In December 2025 the Commission proposed, in its Environmental Omnibus (COM(2025) 983 and a companion regulation), to suspend the authorised representative obligation for EU-established producers until 1 January 2035, but as of September 2026 the European Parliament's Legislative Train lists the file as tabled and it is not law.

When does textile EPR start?

Directive (EU) 2025/1892 must be transposed by 17 June 2027, and Waste Framework Directive Article 22a(14) requires textile EPR schemes to be in place by 17 April 2028.

Does a French UIN have to be shown anywhere?

Yes. ADEME states that producers must show their UIN in their general terms of sale, and French Code de l'environnement Article L. 541-10-9 sets the obligations of marketplaces; ADEME also offers a producer search tool.

Does registration cost money?

The register itself can be free: ZSVR states that LUCID registration costs nothing because ZSVR is financed by the dual systems. The main cost is the eco-modulated scheme fee under Waste Framework Directive Article 8a(4)(b), which varies by PRO and material.

Where a Merchant of Record carries EPR

When a Merchant of Record such as Operator One is the legal seller, it generally fits the producer definition in the countries where it sells, so the EPR obligations for the goods it sells generally sit with it, confirmed per country and per stream. Because EPR does not transfer between entities, registrations a brand already holds stay with the brand, and a brand shipping from its own stock to consumers in another Member State may still be a producer there. Local authorised representatives are commonly arranged through Operator One onboarding, but not in every market. Listings show Brand as the client and Sold by as Operator One. To check your streams and countries, contact our team.

Sources: Directive (EU) 2018/851 amending the Waste Framework Directive; Regulation (EU) 2025/40 (PPWR); Regulation (EU) 2023/1542 (Batteries); Directive 2012/19/EU (WEEE), consolidated; Directive (EU) 2025/1892 (textiles); Directive (EU) 2019/904 (single-use plastics); European Parliament Legislative Train, EPR authorised representative omnibus; ZSVR, LUCID registration; VerpackDG Section 66; stiftung ear, authorised representative; ADEME, unique identification number; Amazon.de, EPR compliance for sellers.

What Is Extended Producer Responsibility (EPR) in the EU?