Question 1

Does one EPR registration cover all EU countries?

Accepted Answer

No. Packaging EPR is organised country by country: each member state has its own producer register and its own schemes, and gives its own number (LUCID in Germany, an IDU per stream in France, ENV in Spain, a CONAI number in Italy). The PPWR harmonises the rules but keeps a register in each member state. What can be shared is the work: one set of packaging data and one provider.

Question 2

Do I need an authorised representative in every EU country I sell to?

Accepted Answer

Since 12 August 2026 the PPWR requires a producer that sells packaged goods directly to end users in a member state where it is not established to appoint an authorised representative established there. The duty is per country: one representative per member state. France already required a representative from 10 July 2026 under its own law. A proposal to pause the duty for small EU companies is under discussion but is not law.

Question 3

What is the difference between EPR registration, representation and reporting?

Accepted Answer

Three separate duties, per country. Registration: you are entered in the national producer register and get its number. Scheme membership: you join a scheme (dual system, eco-organisme, SCRAP, CONAI) that collects and recycles, and pay its fees. Representation: if you are not established there, a representative established in the country takes on your obligations under a mandate. Reporting: you declare the packaging you placed on the market, usually yearly.

Question 4

Does the PPWR replace national packaging EPR registrations?

Accepted Answer

No. The PPWR, Regulation (EU) 2025/40, applies since 12 August 2026 and sets EU-wide rules, including the authorised-representative duty. Registers, schemes, fees and declarations remain national, run under each country's law (VerpackDG in Germany, the Environmental Code in France, Royal Decree 1055/2022 in Spain). Existing registrations stay valid; the PPWR adds obligations on top.

Question 5

Is there a minimum quantity below which EU packaging EPR does not apply?

Accepted Answer

There is no EU-wide exemption for small sellers. In Germany there is no de minimis threshold (ZSVR). In Spain even small quantities must be registered; under 15 tonnes a year you file a simplified declaration. In Italy volume decides how often you declare to CONAI, not whether you are a producer. Other countries set their own thresholds, which is why we confirm each country before filing.

Question 6

Does a warehouse or VAT number in a country make me established there for EPR?

Accepted Answer

Generally no. EPR obligations follow where you make packaging available to buyers, and the representative duty depends on whether your company is established there. Stock held by Amazon FBA or a logistics provider, or a local VAT registration, is not your establishment: Germany, France and Italy all treat it that way. A company based abroad selling through a local warehouse still needs a representative in that country.

Question 7

Does Amazon's EPR service also cover my own website and other marketplaces?

Accepted Answer

No. In France, Amazon's Pay on Behalf reports and pays for your Amazon.fr sales only; it does not register you, so your own website, other marketplaces and B2B sales into France are not covered. In Germany, Amazon 'complying on your behalf' is not a representative: it signs no mandate. Your own registrations and numbers cover every channel; Amazon then asks you for those numbers.

Question 8

Can I use the same packaging data for several countries?

Accepted Answer

Yes, as a base. The packaging of a product (materials and weights, including the shipping box) is the same wherever it goes, so you describe it once. What differs by country is the quantity, counted by delivery country, and the categories each scheme declares in (materials, household or commercial, and in France separate product streams). EPR EU Rep keeps one packaging record per product and produces each country's figures from your orders.

Question 9

Is UK packaging EPR covered by the EU rules?

Accepted Answer

No. Since Brexit the UK runs its own extended producer responsibility for packaging, separate from the PPWR: producers register with their environmental regulator, report packaging data and, if large producers, pay waste disposal fees to PackUK. Whether you are obligated, and as a large or small producer, depends on UK thresholds. There is no EU-style authorised representative. We check whether you are obligated before filing.

Question 10

Is the GPSR responsible person the same as the EPR authorised representative?

Accepted Answer

No. The GPSR responsible person (Regulation 2023/988, Art. 16) must be established somewhere in the EU and answers for a product's safety across the whole EU market. The EPR authorised representative (PPWR) is appointed per member state, established in that country, and takes on packaging registration, scheme membership and declarations there. A non-EU brand selling to consumers in three EU countries can need one GPSR responsible person and three EPR representatives.

Question 11

What labels does a product need to be sold in several EU countries?

Accepted Answer

Two layers. EU-wide, under the GPSR: a product identifier, the manufacturer's name and contact details, the EU responsible person's details if the manufacturer is outside the EU, and instructions and safety information in a language set by each country of sale. National, for packaging: for example France's Triman logo with the Info-tri sorting instruction on household packaging, and Italy's environmental labelling of all packaging. Product-specific rules such as CE marking come on top.

Answers

Where EPR applies

Representatives

Marketplaces and your own shop

Figures and reporting

Beyond EPR: product safety and labels