Packaging EPR in the EU: registering country by country, and what PPWR changes

Updated 23 October 2026

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:

  1. Register in LUCID, the public register run by the Zentrale Stelle Verpackungsregister, before you ship. Registration is free and gives you a registration number.
  2. Join a dual system (Systembeteiligung) for packaging that ends up with private consumers, and pay fees based on weight and material.
  3. 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:

PPWR does not remove national registration. Keep registering country by country, and expect marketplaces to ask for more packaging data.

Checklist

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

ohdock provides software tools and general information, not legal advice. Check the official texts, or ask a qualified adviser, for your situation.