What is EPR?
Extended Producer Responsibility (EPR) is the principle that the business putting a product on a market is responsible for it at the end of its life. In practice, it means registering with each country’s authority or register, reporting the quantities you sell, and paying a compliance scheme to collect and recycle the waste.
EPR applies country by country. A brand selling to consumers in Germany, France and the Netherlands usually needs separate registrations in each, even if all orders ship from one warehouse. Online marketplaces in several countries must check that sellers are registered and can block those who aren’t.
Core principle: If you put packaging or regulated products onto a country’s market, you pay for their recycling there, and you have to register before your first sale.
Main EPR schemes for e-commerce
Packaging
Covers the boxes, mailers, fillers and product packaging that reach consumers. Germany requires registration in the LUCID register and participation in a dual system before selling. France requires a unique identifier (IDU) and the Triman sorting information.
Why it matters: Every e-commerce shipment contains packaging, so almost every brand is affected.
Electrical and electronic equipment
Covered by the WEEE rules, with a registration number per country and take-back obligations.
Batteries
The EU Batteries Regulation (EU) 2023/1542 requires producers to register in each country where they sell batteries, including those built into products.
Textiles and other categories
EU rules agreed in 2025 require all EU countries to set up EPR for textiles and footwear in the coming years, and some countries already have schemes for furniture or other products.
Watch out for: Fashion brands should expect new registrations and fees.
Who counts as the producer?
For EPR, the producer is usually the business that first makes the product or packaging available in a country. For a non-EU brand selling directly to consumers, that is normally the brand itself. Under the EU Packaging and Packaging Waste Regulation, which applies from 12 August 2026, producers not established in a country can be required to appoint an authorised representative there.
What to do in practice
- List the countries you sell to and the categories you sell: packaging, electronics, batteries, textiles.
- Register in each country before the first sale, directly or through an authorised representative or compliance service.
- Join a compliance scheme where required, and report quantities by material and weight.
- Add registration numbers to your marketplace accounts.
- Keep packaging data per product and shipping box, so reports are accurate.
Example: A Swiss sneaker brand ships EU orders from a fulfilment centre in Germany to customers in Germany, Austria and France. It registers its shoe boxes and shipping cartons in LUCID and with a dual system in Germany, and uses a compliance service for Austria and France. Its fulfilment provider supplies the weight of mailers and filling material used each quarter for the reports.
Read more in Selling in the EU from outside the EU: VAT, EORI and stock.
Frequently asked questions
Does EPR apply to non-EU sellers?
Yes. EPR obligations follow sales to consumers in a country, not where the seller is based.
Do I need to register in every country?
Usually yes, for each country where you sell and each category covered, such as packaging, electronics or batteries.
Who pays EPR for shipping boxes from my fulfilment centre?
Usually the brand selling the goods, as the producer placing that packaging on the market. Agree how packaging data is reported with your fulfilment provider.
What is LUCID?
Germany’s central packaging register. Businesses must register there before selling packaged goods to German consumers.
