【2026】What You Need to Know About EPR When Doing Business in Europe — Practical Points for Five Key Countries

The Rules Every EU Country Shares

Registers and contact points differ from one member state to the next, but the framework below is common to most of them.

1. “Producer” Is a Broad Definition

Under EPR, the producer is not necessarily the manufacturer. Depending on the product category and the national rules, it is generally the business that first makes a product available on that country’s market — which can mean the manufacturer, the importer, the brand owner, a cross-border e-commerce seller, or a marketplace seller.

A business shipping directly from outside the EU can be the producer under some schemes and not under others, depending on what it sells, how the sale is structured, and where the goods are placed on the market. That determination comes first: everything else follows from it.

2. It Is Not Only About Packaging

Packaging EPR is the best-known scheme, but the scope has been widening for years — electrical and electronic equipment (WEEE), batteries, and, more recently, textiles. The starting point is to establish which schemes your product categories trigger, in each country, before looking at any registration form.

3. Registration and PRO Membership Are National

There is no single EU-wide window where one registration covers everything. For every country you sell into, you register with that country’s national producer register and contract with an approved PRO (Producer Responsibility Organisation). Five markets means five registrations and, generally, five contracts.

4. Volume Reporting and Fees

Once registered, you report the weight and type of the packaging materials you have placed on the market — annually, quarterly, or on another schedule depending on the country — and pay the corresponding eco-contribution. More countries now apply eco-modulation, where the fee varies with how recyclable the packaging is. Packaging design and compliance cost are no longer separate conversations.

5. Non-EU Businesses Usually Need an Authorised Representative

A business without an establishment in the EU may be required to appoint a registered authorised representative in each member state where its packaging reaches users. Article 45 of the PPWR (Regulation (EU) 2025/40), in force since 11 February 2025 and applicable from 12 August 2026, makes this an EU-wide requirement.

One point deserves care here, because it is being reported loosely. The European Commission proposed suspending the authorised-representative obligation until 2035 as part of its Environmental Omnibus package — but that proposed suspension concerns producers established in the EU. Non-EU producers were never within its scope, and member states may in any case require an authorised representative for them for traceability and enforcement. In Parliament the suspension is now being narrowed further, to micro and small enterprises only, with a committee vote expected around October 2026. If your company is outside the EU, none of this changes what applies to you on 12 August 2026.

6. What Non-Compliance Actually Costs

Fines are the least of it. The practical consequences are marketplace listing suspensions — Amazon, eBay and others check registration numbers before activation — and consignments held at customs. Both stop revenue in a way a penalty notice does not. The corollary is worth stating plainly: register and report correctly and these risks simply do not arise.

France: CITEO Registration and Triman Labelling

France operates one of the most thorough EPR regimes in Europe. For packaging, you register with CITEO — or another approved body such as Léko or Adelphe — and pay the corresponding fees.

Three points are specific to France:

• The IDU (identifiant unique): a registration number issued by ADEME, the French agency for ecological transition, once your PRO registration is complete. Marketplaces and customers will ask for it.
• Triman and Info-tri labelling are mandatory: packaging must carry sorting information — the Triman mark plus the Info-tri panel — designed for the French consumer, not adapted from another market.
• The scheme now extends to business-to-business packaging: the new professional-packaging stream (EPRO) entered into force on 1 July 2026, with three eco-organisations approved in June 2026 (Citeo Pro, Léko Pro and Twiice) and operational deployment set for 1 January 2027. Businesses in scope are expected to join an eco-organisation before the end of 2026.

Procedures run primarily in French, so many foreign businesses work through a registration agency with English-language support. The useful first step is narrower than it looks: establish which category your products and packaging fall into, and the rest of the process follows from that.

Germany: LUCID Registration and Dual-System Contracts

Germany’s system is the one cross-border sellers tend to know already. It has two steps that are easy to confuse and are not interchangeable:

• A licensing contract with a dual system — an approved collection and recycling operator — with fees based on your packaging volume.
• Registration with LUCID, the register run by the ZSVR (Zentrale Stelle Verpackungsregister). You receive a registration number beginning with “DE”, which Amazon, eBay and other marketplaces require before you can list.

The 2026 change is structural. With the PPWR applying from 12 August 2026, Germany’s implementing act — the Verpackungsrechts-Durchführungsgesetz, VerpackDG — takes over from the old Verpackungsgesetz on the same date, and carries transitional deadlines worth diarising: businesses registering for the first time are expected to do so by 12 September 2026, while those already in LUCID have until 12 November 2026 to bring their registration into line with the new requirements. LUCID itself continues; what changes around it is the legal frame and the enforcement. The federal environment ministry publishes an overview of the packaging waste framework in English.

Spain: A Register in Transition

Spain’s packaging EPR system runs under Real Decreto 1055/2022. The framework is:

• Registration in the Registro de Productores de Producto, the producer register held by MITECO, the ministry for ecological transition, in its packaging section.
• A contract with an approved PRO — Ecoembes or another authorised body.
• For non-EU businesses, appointment of a local authorised representative.
• An annual declaration of the packaging placed on the market, filed by 31 March of the following year.

What makes Spain distinctive in 2026 is that the registration procedures themselves have been reworked in recent years, so guidance written under the old arrangements is still circulating alongside guidance written under the new ones — and the two are easy to mix up. First-time registrants may also find they owe declarations for past periods. Take stock of your actual position with a local partner before filing anything.

The PPWR has applied directly in Spain since 12 August 2026, alongside the existing national framework. Until Spain’s implementing rules are settled, the working assumption is continuity: keep complying with Real Decreto 1055/2022 while the national picture catches up.

Italy: CONAI Membership and a Detailed Fee Grid

Italy has one of Europe’s longest-running EPR systems, in place since 1998, with CONAI — the national packaging consortium — at its centre.

• CONAI membership and the material-specific environmental contribution (Contributo Ambientale CONAI, or CAC). Seven material consortia — plastic, paper, glass, steel, aluminium, wood, bioplastics — each with its own fee structure. Contributions for plastic packaging are confirmed to be revised from 1 October 2026, with rates rising across most recyclability bands.
• Environmental labelling is mandatory: packaging must state its material and sorting category.
• An Italian tax code is required to register directly: a business that cannot obtain a codice fiscale itself registers through an authorised representative or an EPR service provider. If you already hold an Italian VAT number, this step is generally in hand — how the VAT side works is set out in our guide to registering for Italian VAT and VIES.

Because the fee bands are granular, what you owe depends heavily on which band your packaging lands in — which is why the design of the packaging and the cost of the compliance are, in Italy more than elsewhere, the same decision.

United Kingdom: Outside the EU, Still Mandatory

The UK left the EU but operates its own scheme, pEPR (Packaging Extended Producer Responsibility), which has to be complied with separately. For sellers in Asia in particular it is a high-demand market, and one of the ones we are asked about most.

• Registration with PackUK, the scheme administrator operating under Defra, alongside the environmental regulator for the relevant nation — England, Scotland, Wales or Northern Ireland. The GOV.UK guidance sets out the process.
• The fee structure changes in stages. In the first year, April 2025 to March 2026, flat base fees applied per material regardless of recyclability. From April 2026 fees are modulated by a red–amber–green (RAG) recyclability rating: red-rated packaging pays a premium over the base fee, green-rated packaging pays less. 2026 is precisely when this system starts moving into full effect.
• Marketplace sales may sit with the marketplace. In some cases the online marketplace, rather than the individual seller, is treated as the obligated party. Confirm which role your business is in before assuming either.
• UK pEPR and EU PPWR are separate systems. Complying with one does not cover the other. If you ship to both, run the two compliance processes separately — relying on EU-side information alone is the most common way a gap opens up.

What Matters Is Following the Steps

European EPR differs by country in its registers and its procedures, but the thread running through all of it is the same three-step sequence: establish whether your business is the producer, register with the national register and an approved PRO in each country where you sell, then report your volumes and pay the fees.

What makes 2026 unusual is that all five markets moved within a single year — France extending to professional packaging in July, Germany’s VerpackDG taking effect in August, Spain running the PPWR alongside its national rules, Italy’s new plastic fee schedule in October, and the UK shifting to recyclability-based ratings from April. Guidance written eighteen months ago is not wrong so much as out of date, which is harder to notice.

We handle EPR registration and reporting as part of VAT compliance rather than as a separate vendor relationship — one file, one calendar, one team, across the countries where you actually sell. If you are not sure which schemes your products trigger, that is the question to start with, and it is the one we answer first.

Sources: Regulation (EU) 2025/40 (PPWR), EUR-Lex · European Commission, packaging waste · CITEO · ADEME · ZSVR / LUCID · BMUV, packaging waste · MITECO, Registro de Productores de Producto · CONAI, environmental contribution · PackUK · GOV.UK, register for packaging EPR.