EPR for packaging, country by country

Extended Producer Responsibility puts the cost of collecting and recycling packaging on whoever first places it on a national market. If you ship a parcel to a customer in Germany, the cardboard, tape and filling inside it are your responsibility, not the customer's and not the courier's.

In practice this means three recurring obligations: register in the country, report how much packaging you placed on that market, and pay a fee based on those volumes and materials. Miss the registration and marketplaces can be required to stop listing you.

There is no single EU registration. Each member state runs its own register, and you need one in every country you ship to. Germany uses LUCID, run by the Zentrale Stelle Verpackungsregister, and additionally requires a contract with a dual system. France works through ADEME with a unique identifier and a producer responsibility organisation such as CITEO. Spain, Austria and Italy each run their own equivalents.

The thresholds are low or absent. Several countries have no minimum quantity at all, so a single shipment can create the obligation. This surprises smaller merchants who assume there is a grace amount.

The change that made this urgent is not a new duty on sellers but a new duty on platforms. Marketplaces are increasingly obliged to verify that third-party sellers hold valid EPR registrations before allowing them to sell into a country, and to act when they do not.

That shifts EPR from a paperwork risk to a trading risk: the consequence is no longer a hypothetical fine but a suspended listing. If you sell through a marketplace as well as your own shop, keep the registration numbers current and to hand.

EPR fees are calculated from the weight and material of the packaging you place on the market. Shipping a small product in an oversized box therefore costs you three times over: more cardboard, higher volumetric shipping charges, and a larger EPR bill.

Reducing empty space to satisfy the packaging regulation lowers all three at once. Measure your worst box-and-product combinations first, since a handful of them usually account for most of your shipments.