Packaging EPR Country by Country

European Union · Packaging and Packaging Waste Regulation (EU) 2025/40 · Selected markets · Reviewed August 25, 2026.

The short answer

Packaging EPR country by country does not mean one EU application copied into several portals. The Packaging and Packaging Waste Regulation (PPWR) applies from August 12, 2026, but Article 44 still requires a producer to register in each Member State where it first makes packaging or packaged products available, or unpacks packaged products without being an end user.

For every destination market, separate four jobs: determine who the producer is, register through the national route, arrange the required collection scheme or producer responsibility organisation, and then submit matching evidence to any marketplace. A registration number, a scheme contract, a material declaration and a marketplace approval are related records—not substitutes for one another.

JurisdictionEuropean UnionNational requirements may apply

Scope: this is an operational guide to eight selected EU markets: Germany, France, Spain, the Netherlands, Austria, Belgium, Poland and Ireland. It is not a complete European directory and does not cover batteries, electrical equipment, textiles or single-use-plastics obligations that may apply alongside packaging.

1 · ROLE

Who is the producer?

Map the manufacturer, importer, distributor and direct seller for each destination. The answer can change with the sales route.

2 · REGISTER

Which national filing?

Use the destination country’s official register. PPWR standardises data fields; it does not create one transferable EU number.

3 · FINANCE

Which scheme or PRO?

Registration can be separate from the contract that finances collection and recycling, and from periodic material reporting.

4 · PLATFORM

What needs to match?

Marketplaces verify the legal entity, country, packaging category and registration evidence. Their approval does not create compliance.

The PPWR baseline across EU countries

Rule What it means Common mistake
Article 44 registration Register in every Member State where you qualify as the producer for packaging placed on that market Treating a German, French or other national number as an EU-wide number
Below 10 tonnes Article 44(8) provides simplified annual reporting for small quantities Reading simplified reporting as an exemption from registration
Article 45 EPR The producer is responsible for the extended-producer-responsibility obligations in each relevant Member State under Article 45 of PPWR Assuming a registry filing also completes scheme membership, fees and declarations
Online platforms Covered platforms obtain registration information and producer self-certification before allowing covered producers to use their services Treating a platform status as a regulator’s compliance decision

The authorised-representative rule is a moving legislative issue. Article 45(3) currently contains an appointment requirement. Commission proposal COM(2025) 982 would suspend part of that requirement until January 1, 2035, for producers established in the EU, but the proposal had not become law as of this review. Use the regulation and the current national authority instructions—not a summary of the proposal—when deciding whether to appoint a representative.

Packaging EPR country-by-country matrix

This matrix identifies the operational starting point, not every filing field. National systems are changing as PPWR is implemented, so retain the dated authority page used for each decision.

Country Official route Scheme or reporting layer Cross-border point
Germany Register free of charge in LUCID with ZSVR. The LUCID number is German-only and new records may not appear in the public register immediately. Packaging subject to system participation needs a separate contract with a system and matching volume reports to both the system and LUCID. ZSVR states that a foreign company selling directly to German end users without a German branch must appoint an authorised representative from August 12, 2026.
France The producer obtains a unique identifier, or IDU, for each applicable EPR stream through the SYDEREP system. ADEME describes the IDU as proof of registration for that stream. The producer obligations page describes joining an approved eco-organisation for the relevant packaging stream or using an approved individual system; declarations and contributions remain separate from the identifier. Determine who first places the packaged product on the French market. Marketplaces request the French EPR identifier and matching legal-entity information.
Spain Register in the packaging section of the Product Producers Register maintained by MITECO. The published number format begins with ENV, followed by the registration year and digits. Provide the collective or individual extended-responsibility-system information and complete packaging declarations through the applicable national route. MITECO states that a foreign producer selling directly to final users in Spain must appoint an authorised representative. The same official page says online platforms must collect registration evidence and self-certification.
Netherlands Verpact is the collective packaging organisation and provides the current registration and declaration route. Its August 2026 guidance says PPWR removed the former general packaging threshold. Register, report packaging quantities and pay the applicable waste-management contribution through the current Verpact process; deposit and single-use-plastics rules can add separate records. Direct cross-border sales can make the foreign seller the producer in the customer’s country. Do not rely on pre-PPWR articles that repeat the former 50,000 kg threshold as a current exemption.
Austria Packaging actors and appointed representatives use Austria’s electronic data-management system, EDM, including the ZAReg registration route. The responsible party participates in an authorised collection and recovery system and reports the relevant packaging quantities. Austria’s business portal states that a foreign distance seller supplying packaging directly to private final consumers in Austria must appoint an authorised representative.
Belgium The Interregional Packaging Commission oversees the packaging obligations across the three regions. Fost Plus handles household packaging and Valipac handles industrial and commercial packaging for participating businesses; the correct route depends on the packaging destination. The producer-role analysis changed with PPWR. Use the Commission’s current decision tree and identify where the packaging becomes waste before selecting a scheme.
Poland The BDO register remains the operational national database for businesses placing packaged products on the Polish market. Registration is handled through the competent regional marshal. The BDO record, packaging reporting and recovery obligations are separate operational steps. The BDO number is used on business documents where the Polish rules require it. Poland’s national PPWR implementation is still transitioning. Confirm the current producer and representative route with BDO or the competent marshal before filing.
Ireland Ireland is still a transition case: the EUNR directory records no national packaging producer register, while PPWR requires Member States to establish one. Repak is the existing approved packaging compliance scheme and is licensed through 2035. Its distance-seller process is the practical starting route while the national register layer develops. Repak’s application states that a business outside Ireland, not registered for Irish VAT, that places packaged goods on the Irish market for private consumers must register under PPWR.

Why Italy is not in the table: we did not find a sufficiently clear current official post-PPWR page that resolved the registration and cross-border route for this review. CONAI remains the national packaging organisation listed by the European Union Network for Packaging Registers, but sellers should confirm the applicable 2026 procedure directly before relying on an older guide.

What changes from one country to the next?

The EU trigger is common, but the operating layer is national. Countries use different registers, identifier formats, collective systems, reporting calendars, packaging categories and representative procedures. Even the institutional structure differs: Germany separates LUCID registration from system participation; France issues an IDU by EPR stream; Belgium separates household from industrial and commercial packaging; Ireland is moving from its established compliance-scheme route toward the PPWR register model.

The useful question is not “which country is easiest?” It is “what exact chain applies to this product, legal entity, sales route and destination?” A provider that answers with one price before collecting those facts may be quoting a partial service.

A pre-expansion checklist for sellers

  1. List the destination countries. Use actual delivery destinations, not the country where the marketplace account was opened.
  2. Map the supply chain per country. Record the manufacturer, importer, distributor, fulfilment entity, direct seller and end user.
  3. Decide who is the producer. Apply PPWR and the current national instructions to each route. Do not let a dropdown menu make this legal determination for you.
  4. Open the official national route. Use the regulator, register or recognised scheme page. Treat a provider’s country list only as a lead.
  5. Check representation. Determine whether your establishment and direct-sales model require an authorised representative, and record the authority source and review date.
  6. Register the correct legal entity. Preserve the issued number, legal name, address, tax identifier, packaging stream and supporting confirmation exactly as recorded.
  7. Arrange the scheme layer. Join the correct PRO or system where required, then configure packaging categories, material weights and reporting ownership.
  8. Submit marketplace evidence last. Copy the registry data exactly, confirm the correct category and allow for public-register synchronisation.
  9. Calendar the reporting cycle. Store renewal, declaration and payment dates by country; national calendars do not align.

Marketplace verification is a separate layer

Article 45(4) explains why marketplaces ask for registration data, but the platform is checking a national record rather than creating it. If a submission fails, compare the account name, register name, identifier, country and packaging category character for character. Check whether the record is public yet and whether the form also requires scheme participation.

See the country-specific workflow for Amazon Ireland packaging EPR evidence and the broader walkthrough of Zalando packaging EPR verification. A platform rejection does not normally justify buying a duplicate registration.

When outside help is worth paying for

Outside help becomes useful when you enter several countries at once, need local representation, cannot determine the producer from a mixed distributor-and-direct-sales model, or need recurring material declarations managed in unfamiliar systems and languages. Ask a provider to itemise registration, representation, scheme membership, quantity reporting and marketplace support. “Full compliance” is not a useful scope unless those deliverables are named.

Starting with Ireland?

Our comparison of Irish packaging EPR routes separates the official Repak route from registration, representation and reporting services. It is an Ireland-specific comparison, not a provider shortlist for every EU country.

Frequently asked questions

Is there one EU-wide packaging EPR number?

No. PPWR Article 44 requires registration in each Member State where the business qualifies as the producer. Harmonised information requirements do not turn national identifiers into one EU number.

Does selling less than 10 tonnes exempt me from registration?

No. Article 44(8) provides simplified reporting for producers whose quantities stay below 10 tonnes during a calendar year. It does not remove the Article 44 registration requirement.

Is a registration number the same as a PRO contract?

No. Registration records the producer with the national route. A PRO or system contract finances collection and recycling and normally adds material declarations and fees. Some countries separate these functions more visibly than others.

Do I need packaging EPR if I sell from another country?

Yes, when the direct cross-border route makes the foreign seller the producer in the destination market. Spain, Austria, Germany and Ireland publish specific cross-border or representative instructions, but the exact route still depends on where the seller is established and how the goods reach the end user.

Why did my marketplace reject a valid number?

Common causes include a legal-name mismatch, the wrong country or packaging category, a missing scheme confirmation, or a new registration that is not yet visible in the public register. Diagnose the mismatch before creating another registration.

Do packaging rules also cover batteries and electronics?

No. Packaging, batteries and electrical equipment are separate EPR streams with separate identifiers and reporting. A product can trigger more than one stream in the same country.

How often should I re-check the country requirements?

Check before every new-country launch and review active markets at least quarterly while PPWR implementation is changing. Keep the source URL and access date with each decision so an old threshold or procedure is easy to spot.

Sources and review date

Last fact-checked: August 25, 2026.

XrdaGrid provides general informational content about regulatory and marketplace documentation. This selected-market guide is not legal advice, does not determine producer status for a specific supply chain and does not guarantee registration or marketplace acceptance.