EPR registration and EU packaging rules (PPWR)

Extended producer responsibility in plain words

Extended producer responsibility (EPR) means that the company which first makes packaging, electrical equipment or batteries available on a national market pays for their collection and recycling there. In most countries this company must register in a national register, join a compliance scheme and report the quantities it sells.

Who is obliged: you, your buyer or us?

The duty usually lies with the company that places the goods on the national market — often the importer. If your European distributor imports in its own name, it normally registers. If you sell delivered duty paid, through marketplaces or to consumers, the duty can fall on you as a foreign producer, and many countries then require a local authorised representative.

This is why we start with your sales model, not with a list of registers. The answer decides who registers, in which countries and for which materials.

Three EPR streams

Packaging. All sales packaging, outer boxes and shipping packaging. In Germany, for example, every company obliged under the Packaging Act must register itself in the LUCID register; an authorised representative based in Germany can then take over the reporting.

Electrical and electronic equipment (WEEE). Producers register per country and per equipment category; in several countries foreign producers must appoint a local authorised representative.

Batteries. Under the Batteries Regulation (EU) 2023/1542, producer responsibility for batteries applies from 18 August 2025. This includes batteries built into products such as toys, tools or electronics.

France and some other countries also have EPR streams for textiles, furniture, toys and other products. We check them for your categories.

The Packaging Regulation (PPWR) from 12 August 2026

Regulation (EU) 2025/40 on packaging and packaging waste applies from 12 August 2026. It turns many national rules into one EU law and adds duties for whoever places packaging on the market:

• conformity assessment and technical documentation for packaging, kept for 5 or 10 years;
• an EU declaration of conformity for packaging;
• traceability on the packaging: manufacturer, importer and batch or serial number;
• limits on lead, cadmium, mercury and hexavalent chromium;
• limits on PFAS in food-contact packaging;
• EPR in every member state where packaging is sold.

Requirements on recycled content and recyclability labelling follow step by step from 2028. Packaging you design now should already take them into account.

What we do

We map your duties per country, collect the packaging data from your factory (materials, weights per unit and per carton), organise registrations and scheme contracts through checked partners, and report quantities from our sales data. We do not choose for you whether to register yourself or through your buyer — we explain the options and their costs.