Customs
EPR and the EU Packaging Rules: What Changed on 12 August 2026
Quick answer: Extended producer responsibility makes you pay for the disposal of the packaging you put on a market. It is not new, but on 12 August 2026 the EU's Packaging and Packaging Waste Regulation began to apply, and from that date marketplaces are obliged to verify that their sellers are compliant. That changed the consequence from a theoretical fine to a suspended listing. There is no single EU registration: you register country by country, and if you have no EU entity you need an authorised representative in each one.
EPR has been on the books for years and quietly ignored by a large number of cross-border sellers, for a simple reason. Nobody was checking.
That has changed, and it changed in the way these things usually do. Not with enforcement officers, but with Amazon asking for a registration number before your listing stays up.
Strip away the acronyms and it is one idea: whoever puts packaged goods on a market pays for dealing with that packaging at the end of its life.
You are not paying for the cardboard. You are paying into the system that collects, sorts and recycles it after your customer has finished with it.
Mechanically, that means four things. You register in a national producer register. You contract with a compliance scheme. You report the weight of packaging you placed on that market, broken down by material. You pay a fee based on those tonnages.
The obligation attaches to the person placing goods on the market. For distance selling into the EU, that is you, not your customer and not your carrier.
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force in February 2025 and began to apply on 12 August 2026.
Two consequences matter commercially.
Marketplaces now have to check. From that date, online marketplace providers carry expanded legal obligations to verify that their sellers are EPR compliant. That is the change that actually bites. A regulation nobody enforces is a risk you can rationally defer. A regulation Amazon enforces on your listings is not.
Germany replaced its packaging law. The Packaging Act, VerpackG, was replaced by the Packaging Law Implementation Act, VerpackDG, on the same date. The LUCID register and the dual system structure remain, but obligations expanded to cover B2B packaging that had previously been exempt. If you sell into Germany and set up your compliance around the old scope, that scope has widened.
This is the part sellers get wrong most often, usually by assuming the single market works the way the name suggests.
Each member state runs its own producer register. You register separately in every country where you place goods on the market, with its own process, reporting format and fee schedule.
| Country | Register or scheme |
|---|---|
| Germany | LUCID, plus a dual system contract |
| France | Citeo |
| Italy | CONAI |
| Spain | Ecoembes |
Selling into five EU countries means five registrations, five reports and five sets of fees. There is no shortcut, and a registration in one country does you no good in another.
Published figures vary enormously, and anyone giving you a single number is guessing.
Registration itself is often free. LUCID registration in Germany costs nothing. What costs money is everything registration then obliges you to have: a compliance scheme contract, and an authorised representative if you are not established in that country.
The scheme fees are charged per tonne of packaging by material, and the reported ranges are wide. For Germany, sources put dual system fees anywhere from roughly €80 to €400 per tonne for general packaging, while plastic packaging figures of €1,600 to €2,100 per tonne appear in other reporting depending on recyclability. France's Citeo fees are commonly cited in the €100 to €700 per tonne range.
Those ranges do not reconcile, and we are not going to pretend otherwise. What they tell you is directional rather than precise: the fee depends heavily on material and on how recyclable that material is, and the gap between a well-chosen material and a poorly-chosen one is large.
France makes that explicit. Its eco-modulation system was enhanced on 1 January 2026, with bonuses reportedly reaching up to €1,000 per tonne for recyclate derived from difficult-to-recycle waste streams, and penalties running the other way.
Get a quote for your actual material mix and volumes. Treat any single headline figure, including these, as an indication.
If you have no legal entity in the country you are selling into, you generally need an authorised representative established there, to handle registration, reporting and fee payment on your behalf.
This applies to non-EU sellers, marketplace vendors shipping from outside the EU, and cross-border distance sellers. It is a paid service, priced separately from the scheme fees, and prices vary widely.
It is also per country, like everything else here.
While you are dealing with packaging, there is a second EU obligation that lands on the same sellers and is frequently overlooked.
The General Product Safety Regulation requires a responsible person established in the EU before products can be placed on the EU market. The point is that there is always an EU entity accountable for a product, able to provide market surveillance authorities with documentation demonstrating conformity.
Enforcement here has broadened through 2026. Platform checks have reportedly expanded from simply holding a responsible person's contact details to examining labelling, the presence of safety and warning information on the listing itself, and in some categories the underlying risk assessments and technical files.
If you set up EU compliance in 2024 and have not revisited it, that setup is probably no longer sufficient. Our guide to product compliance when importing from China covers the CE, UKCA and testing side of the same problem.
The commercial consequence arrives before the regulatory one.
Marketplaces obliged to verify compliance enforce it the way marketplaces always do: listing suspension and withheld payouts. Both stop revenue the same day. Regulatory fines and exclusion from the market are also possible, but most sellers will meet this as deactivated listings rather than a letter from an authority.
Which is worth understanding for what it implies about timing. You will not get a warning shot from a regulator. You will get an email from a platform.
We are a fulfilment provider. We are not an authorised representative, we cannot register you with LUCID, Citeo, CONAI or Ecoembes, and we cannot act as your EU responsible person. Those are regulated roles requiring establishment in the relevant country, and anyone offering them as a bolt-on to warehousing is describing something else.
What we can genuinely contribute is the thing most sellers cannot produce when they sit down to file: accurate packaging data.
An EPR report is built on the weight of packaging you placed on a market, by material. Cartons, void fill, poly bags, tape, inserts, labels. Per SKU, multiplied by units shipped to that country. That data is generated at the packing bench, and if nobody recorded it at the time, reconstructing it later is guesswork that you are then certifying as accurate.
We record materials and weights at intake and keep them consistent across shipments, which is the same discipline that underpins classification and customs documentation. It also connects directly to packaging and dimensional weight decisions, where reducing material has a second benefit you now get paid for twice: lower shipping cost and lower EPR fees.
For registration itself, use a specialist EPR service or an authorised representative.
EPR was always the rule. August 2026 is when the marketplaces started checking, and that is what makes it urgent rather than theoretical.
Register in each country you sell into, not once for the EU. Budget for an authorised representative if you have no EU entity. Expect fees that vary substantially by material, and treat that as a reason to look at what you are packing things in. And get your packaging weights recorded properly now, because every report you file from here rests on them.
If you want help pulling together packaging material and weight data for your SKUs, that part we can do.
Positions and figures here are current as at October 2026 and vary by member state. Confirm requirements for your specific markets before relying on them.
$0.99 per order pick and pack. DHL/FedEx/UPS to 200+ countries. Tracking auto-syncs to Shopify. DDP so your customers never see a duty charge. 30 days free storage.
See eCommerce Fulfillment →Extended producer responsibility makes whoever places packaged goods on a market financially responsible for the end-of-life cost of that packaging. In practice you register in a national producer register, contract with a compliance scheme, report the weight of packaging you put on that market by material type, and pay a fee based on those tonnages.
The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, began to apply. It entered into force in February 2025 with an application date of 12 August 2026. From that date online marketplaces carry expanded legal obligations to verify that their sellers are EPR compliant, which is what turned an under-enforced rule into a live commercial risk. In Germany the Packaging Act was replaced by the Packaging Law Implementation Act on the same date.
No. There is no single EU-wide EPR registry. Each member state runs its own national producer register and you register separately in every country where you place goods on the market. Germany uses LUCID, France uses Citeo, Italy uses CONAI and Spain uses Ecoembes. Each has its own registration, reporting format and fee schedule.
A seller without a legal entity in the relevant EU country generally has to appoint an authorised representative established in that country to handle registration, reporting and fee payment on their behalf. This applies to non-EU sellers, marketplace vendors shipping from outside the EU and cross-border distance sellers. It is a paid service and it is separate from the compliance scheme fees themselves.
The realistic consequence is commercial before it is legal. Marketplaces that are now obliged to verify compliance respond by suspending listings and withholding payouts, which stops revenue immediately. Regulatory fines and exclusion from the market are also possible. The practical risk for most sellers is waking up to deactivated listings rather than receiving a letter from a regulator.