EPR Obligations by Country in 2026

Table of content

Key takeaways

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has applied since 12 August 2026.
Under the PPWR, producers selling directly to end users in an EU country where they are not established must appoint an authorised representative there.
A Commission proposal to suspend that authorised representative rule stalled after the Council discontinued negotiations on 24 June 2026.
EPR rules under the EU Batteries Regulation (EU) 2023/1542 have applied since 18 August 2025.
Every EU Member State must set up a textiles EPR scheme by 17 April 2028 under Directive (EU) 2025/1892.
Spain charges a plastic packaging tax of €0.45 per kg of non-recycled plastic, on top of packaging EPR.

In short: Extended producer responsibility (EPR) makes the first business to supply packaging, electronics, batteries or textiles in a country pay for their recycling. Online sellers shipping direct to consumers abroad usually count as the producer there. That means registering, joining a scheme and reporting volumes in each country, often through an authorised representative.

Updated October 2026. This guide summarises EPR rules for cross-border online sellers as they stand in October 2026. It covers the EU Packaging and Packaging Waste Regulation (PPWR), in application since 12 August 2026. It also covers battery EPR, WEEE, the coming textiles EPR schemes and the main national registers. Each section links to a more detailed Taxually guide where one exists.

What is extended producer responsibility (EPR)?

EPR is a policy that shifts the cost of waste management from taxpayers to the businesses that put products on the market. Producers finance the collection, sorting and recycling of their products once they become waste.

In practice, EPR usually involves four obligations in each country where you sell:

Registration: you register with the national producer register and receive a registration number.
Scheme participation: you join a producer responsibility organisation (PRO) or compliance scheme, or run an approved individual system.
Reporting: you report the weight or units of products and packaging you placed on that market.
Fees: you pay contributions based on those volumes, often adjusted by material and recyclability.

EPR is not a tax in most countries, although some countries run environmental taxes alongside it. Spain's plastic packaging tax is one example. For the background and benefits of EPR, see our guide to extended producer responsibility.

Who counts as a producer for cross-border online sellers?

For EPR, the producer is generally the first business that makes a product or packaging available in a country. If you ship from abroad directly to an end user in that country, you are usually the producer there.

The PPWR separates two roles. Germany's Central Agency Packaging Register (ZSVR) explains the split as follows:

Manufacturer: responsible for packaging conformity, shown through technical documentation and a declaration of conformity.
Producer: carries EPR obligations in the Member State where the packaging becomes waste, including registration, reporting and financing recycling.
Brand principle: a company whose name or brand appears on the packaging is treated as both manufacturer and producer.
Foreign sellers: a foreign company is the producer only if it ships directly from abroad to an end user in that country.

If you sell to a local importer or distributor instead, that business usually becomes the producer. The same logic runs through WEEE and battery rules, which also treat distance sellers as producers in the country of the end user.

What does the PPWR change for online sellers from 12 August 2026?

The PPWR, Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied since 12 August 2026. It replaced most of the 1994 Packaging Directive with a single regulation that applies directly in every Member State.

Key points for sellers:

Producer registers: each Member State keeps a register of producers, managed by its competent authority and treated as a public register.
Authorised representative: producers selling directly to end users in a Member State where they are not established must appoint an authorised representative there (Article 45(3)).
Online platforms: before letting producers use their services, platforms must obtain information about the producers' EPR compliance and make best efforts to check it.
Design rules: separate PPWR rules cover packaging design and labelling. The Commission states that packaging on the EU market must be recyclable in an economically viable way by 2030.

National EPR schemes stay in place. You still register and pay fees country by country, but the core definitions are now harmonised. See our overview of packaging waste regulations for e-commerce.

Is the authorised representative rule being suspended?

Not as of October 2026. On 10 December 2025, the Commission proposed suspending the authorised representative obligation in PPWR Article 45(3) and Batteries Regulation Article 56(3) until 1 January 2035.

The proposal only covered producers established in another EU Member State. Rules for producers based outside the EU would not change. On 24 June 2026, the Council said it had discontinued negotiations on the two EPR proposals. It cited strong reservations from a large majority of Member States. Until any change is adopted, the obligation applies.

What are the EPR rules for batteries in 2026?

The EU Batteries Regulation, Regulation (EU) 2023/1542, has applied since 18 February 2024. Its new EPR rules have applied since 18 August 2025.

Who: producers of batteries, including batteries incorporated in other products.
Distance sellers: a producer selling batteries by distance contract to end users in another country needs an authorised representative there, according to Sweden's environmental agency.
Germany: stiftung ear revoked the registrations of foreign producers without an authorised representative on 18 August 2025. Producers must also join a producer responsibility organisation for each battery category.
Categories: Germany now uses five battery categories: portable (device), light means of transport (LMT), electric vehicle, industrial, and starting, lighting and ignition (SLI) batteries.

How does WEEE apply to online sellers?

Under the WEEE Directive 2012/19/EU, sellers of electrical and electronic equipment must register in each Member State where they sell to end users. Distance sellers must appoint an authorised representative in each of those countries.

Registration: Article 16 requires each Member State to keep a producer register that includes distance sellers.
Authorised representative: under Article 17(2), a producer selling EEE at a distance into another Member State must appoint a representative there. The appointment must be in writing.
Review: the Commission published an evaluation of the WEEE Directive in July 2025. As of October 2026, the Directive's core obligations still apply.

Our guide What is WEEE? explains product categories and compliance steps in more detail.

When does textiles EPR start across the EU?

Every EU Member State must have a textiles EPR scheme by 17 April 2028. The obligation comes from Directive (EU) 2025/1892, which amends the Waste Framework Directive.

Entry into force: 16 October 2025.
Transposition deadline: 17 June 2027.
EPR schemes in place: by 17 April 2028.
Products: clothing and accessories, hats, blankets, bed and kitchen linen, and curtains. Member States may include mattresses.
Micro-enterprises: get one extra year to comply after their national scheme is set up.

France already runs a textiles EPR channel (TLC) through its national register. Other countries will add schemes as they transpose the directive.

What do online marketplaces have to check?

In several countries, marketplaces must verify that sellers are registered, or they become liable themselves. This is why many sellers first learn about EPR when a marketplace asks for a registration number.

Germany: online platforms must obtain confirmation of the seller's LUCID registration and a self-certification of EPR compliance. Without it, the packaged products may not be offered on the platform. Fulfilment providers must stop services if sellers do not fix missing information.
France: since 1 January 2022, marketplaces must contribute to EPR for their third-party sellers unless they hold proof that the seller already complies. A seller's unique identifier (IDU) counts as that proof.
Spain: if a foreign producer sells through a platform without an authorised representative, the platform acts as the producer for financial and information obligations.
United Kingdom: operators of websites or apps that let non-UK businesses sell into the UK may be carrying out the "online marketplace" packaging activity.
Sweden: marketplace operators are treated as intermediaries, so the seller remains responsible.

What are the EPR registers and rules by country?

Each country runs its own register, schemes and enforcement. The list below summarises the main packaging rules for online sellers, plus other streams where confirmed. Check each authority's guidance for your product mix.

Germany: packaging producers register in the LUCID Packaging Register (ZSVR) and join a dual system. Since 12 August 2026, foreign producers without a German branch selling directly to end consumers must appoint an authorised representative. WEEE and batteries register with stiftung ear. See What is a LUCID number? and EPR in Germany.
France: producers register in ADEME's SYDEREP register and receive a unique identifier (IDU) for each EPR channel. Channels include household packaging and paper, EEE, batteries, textiles and footwear (TLC), toys, sports goods, furniture and building products. France also has its own sorting-label rules (Triman). See EPR in France and the Triman logo.
Spain: packaging producers register in the Registro de Productores de Producto, packaging section (MITECO), under Royal Decree 1055/2022. Foreign producers must appoint an authorised representative in Spain. Spain also charges a plastic packaging tax of €0.45 per kg of non-recycled plastic. See Spanish plastic tax and EPR and Spanish packaging regulations.
Italy: packaging EPR runs through CONAI, the national packaging consortium, which collects the CONAI environmental contribution (CAC). CONAI publishes PPWR guidance and a tool for comparing EU country rules.
Netherlands: packaging producers register with Verpact, the Dutch packaging EPR organisation. Registration applies above 50,000 kg of packaging placed on the Dutch market per calendar year.
Austria: since 1 January 2023, foreign companies selling packaged goods to Austrian end consumers must appoint an Austria-based authorised representative. Both are registered on the ministry's EDM platform, with a notarised power of attorney.
Poland: businesses register in BDO, the national database on products, packaging and waste management, run with the Ministry of Climate and Environment.
Belgium: the Interregional Packaging Commission (becoming EPRiBEL) oversees packaging EPR. Fost Plus (household packaging) and Valipac (industrial packaging) are the accredited organisations.
Sweden: sellers shipping from abroad directly to Swedish end users are packaging producers and must register with the Swedish Environmental Protection Agency. Battery producers receive an EPR number starting "SEBATT", and distance sellers of batteries need an authorised representative.
United Kingdom: packaging EPR (pEPR) applies to organisations with turnover of £1 million or more handling over 25 tonnes of packaging. Large organisations (£2 million or more and over 50 tonnes) report every six months and may pay waste disposal fees.

What are the penalties for non-compliance?

Penalties vary by country, but the most immediate risk for online sellers is losing access to marketplaces. Fines and sales bans can follow.

Germany: packaged products without LUCID confirmation may not be offered on online platforms, and fulfilment providers must stop their services.
Germany (batteries): foreign producers without an authorised representative had their battery registrations revoked from 18 August 2025.
Austria: the authorised representative bears administrative penalties for breaches of Austrian packaging law.
Sweden: failure to register can lead to an injunction combined with a fine. Since 1 January 2024, late registration triggers an environmental sanction fee.
United Kingdom: missing a reporting deadline can lead to a late fee.

Fine amounts change and depend on national law. Check the current penalty rules with each authority before relying on a figure.

How do you get EPR-compliant step by step?

Start by mapping where you sell and what you ship, then work through each country's register. The steps below apply to most packaging, WEEE and battery schemes.

Map your sales: list each country where you ship directly to end users, including marketplace and own-store sales.
Map your products: identify packaging, electrical items, batteries (including built-in ones) and textiles for each SKU.
Confirm your role: check whether you, a local importer or the marketplace is the producer in each country.
Appoint representatives: where required, sign a written mandate with an authorised representative in each country.
Register and join schemes: register with the national authority and sign up with a PRO for each product stream.
Share numbers with marketplaces: enter your registration numbers in each marketplace seller account.
Report and pay: collect weight and material data by SKU and file reports on each country's schedule.

Our article on operationalising producer responsibility covers data models and SKU-level packaging data. Amazon sellers can also read tax, VAT and EPR for European expansion.

How do you choose an EPR compliance provider?

Choose a provider that covers your countries and product streams, and that can act or arrange representation where the law requires it. Options include national PROs, specialist authorised representative firms, and multi-country compliance platforms.

Country coverage: does it cover every country where you ship directly to end users?
Stream coverage: does it handle packaging, WEEE, batteries and textiles, or only some of them?
Authorised representative: can it act as, or arrange, your authorised representative where required?
Marketplace integration: can it supply registration numbers in the format each marketplace needs?
Data handling: can it turn SKU-level weight and material data into each country's report format?
Transparent pricing: are service fees separate from the scheme contributions you pay to PROs?
Regulatory updates: does it track changes such as the PPWR and new textiles schemes?

Taxually's EcoTax covers EPR registration and reporting for packaging, WEEE and batteries in Germany, France and Spain. It also covers further French EPR channels and the Spanish plastic tax.

Sources

Author

Taxually Editorial Team

•

Content team

The Taxually Editorial Team writes Taxually's guides and news on VAT, sales tax, e-invoicing and environmental taxes for online sellers and growing businesses. Articles are based on official sources, such as national tax authorities and the European Commission, and aim to explain complex rules in plain language.

FAQ

Frequently asked questions

Do I need EPR registration if I only sell through Amazon or another marketplace?

Usually yes. If you ship from abroad directly to end users, you are normally the producer in that country. Marketplaces in Germany, France and Spain must check or cover sellers' EPR compliance.

When did the PPWR start to apply?

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025. It has applied since 12 August 2026.

Do non-EU sellers need an authorised representative for packaging EPR?

Yes, where they sell directly to end users in an EU country. The Commission's December 2025 suspension proposal only covered producers established in another EU Member State.

When did the new battery EPR rules start?

EPR rules under the EU Batteries Regulation (EU) 2023/1542 have applied since 18 August 2025. Distance sellers need an authorised representative in each country where they sell to end users.

When will textiles EPR apply across the EU?

Directive (EU) 2025/1892 requires every Member State to set up a textiles EPR scheme by 17 April 2028. Micro-enterprises get one extra year to comply.

What is the UK packaging EPR threshold?

UK packaging EPR applies to organisations with turnover of £1 million or more that handle over 25 tonnes of packaging a year. Large organisations have turnover of £2 million or more and handle over 50 tonnes.

Is EPR the same as a plastic tax?

No. EPR funds the collection and recycling of products through producer schemes. A plastic tax, such as Spain's €0.45 per kg levy, is a separate tax paid to the tax authority.

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EPR Obligations by Country in 2026: Packaging, WEEE, Batteries and Textiles

EPR rules for online sellers in 2026: who counts as a producer, the PPWR from 12 August 2026, battery, WEEE and textiles EPR, marketplace checks, and registers in 10 countries.