Packaging EPR in the EU: registering country by country, and what PPWR changes
Extended producer responsibility (EPR) means the business that puts packaging on a country’s market pays for collecting and recycling it. For cross-border sellers, “the business” is usually you: the box, tape, filling material and product packaging that arrive at the customer’s door all count.
EPR is national. Each country has its own register, its own compliance schemes and its own fees. Marketplaces in Germany and France must check that sellers are registered, which is why they ask for EPR numbers.
Germany: LUCID and system participation
Under the German Packaging Act (VerpackG), you must:
- Register in LUCID, the public register run by the Zentrale Stelle Verpackungsregister, before you ship. Registration is free and gives you a registration number.
- Join a dual system (Systembeteiligung) for packaging that ends up with private consumers, and pay fees based on weight and material.
- Report the same quantities to LUCID and to your dual system.
Marketplaces and fulfilment providers may not sell for you if you are not registered.
France: the unique identifier (UIN / IDU)
In France you join an approved compliance organisation (éco-organisme) for each relevant product stream, which gives you a unique identifier registered with ADEME (SYDEREP). Products and packaging also need the Triman logo and sorting information (Info-tri). France has EPR streams beyond packaging, including electrical equipment, textiles, furniture and toys.
Other countries
Spain, Italy, the Netherlands, Austria and most other EU countries have their own registers and schemes. Requirements differ: some require a local authorised representative for sellers based elsewhere, some set thresholds below which only registration is needed. Check each country you ship to, or use a provider that covers several.
What PPWR changes
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, replaces the old directive and applies from 12 August 2026. Over the following years it brings:
- harmonised rules for producer registers and for producers based in another country;
- recyclability requirements and limits on certain substances;
- harmonised labels for sorting, phased in later;
- rules to reduce empty space and unnecessary packaging.
PPWR does not remove national registration. Keep registering country by country, and expect marketplaces to ask for more packaging data.
Checklist
- List the countries you ship to and the packaging materials you use.
- Register as a producer in each country (LUCID in Germany, UIN in France, and so on).
- Join the required compliance schemes and report quantities.
- Add the national marks required (for example Triman in France).
- Put your EPR numbers into each marketplace.
Need help with several countries at once? Find a provider.
Frequently asked questions
Do I need EPR if I only ship parcels to consumers?
Usually yes. The box, filling material and product packaging that reach the consumer count as packaging placed on that country’s market, so you are the producer for EPR purposes in most countries.
Is one EU registration enough?
No. Registration and fees are national. You register in each country you ship to, although PPWR harmonises more of the rules over time.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)
- LUCID packaging register (Zentrale Stelle Verpackungsregister, Germany)
- SYDEREP (ADEME, France)
ohdock provides software tools and general information, not legal advice. Check the official texts, or ask a qualified adviser, for your situation.