Safe in the EU trade operations
Extended Producer Responsibility (EPR) sets out the legal framework for the placing of goods on the market within the European Union. It requires manufacturers, importers and distributors to take responsibility for the entire life cycle of their products – in particular for take-back and recycling.
Dieser Ansatz folgt dem Verursacherprinzip (polluter pays principle): Da Unternehmen die Kosten für die Entsorgung tragen, entsteht ein wirtschaftlicher Anreiz für die Entwicklung unweltfreundlicherer und recyclingfähigerer Produkte. Die Umsetzung erfolgt national durch spezifische Gesetze, wie in Deutschland durch das VerpackG, ElektroG und BattG.
Many distributors are often unsure whether and to what extent they are affected by specific EU regulations. These directives are implemented at the national level through specific laws.
Who is responsible?
In principle, an EPR obligation applies to anyone who commercially makes goods available in an EU member state.
- Distributor: This includes manufacturing, importing, and distribution (including via dropshipping). Simply advertising a product in an online store triggers the registration requirement.
- White Label / OEM: If you sell products under your own name, you are legally considered the manufacturer, even if the actual production is carried out by a third party (provided that the actual manufacturer cannot be identified).
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Scope: In addition to packaging, batteries, and electrical and electronic equipment (WEEE) , textiles, furniture, cosmetics, shoes, and chemicals are also covered by EPR, depending on the country.
Key EPR Obligations and Processes
Since there is no central EU body, EPR registration is handled separately for each sector and member state through national authorities and take-back systems.
Authorization by CERTIFY
Direct mailers without a national branch office are usually required to appoint a local authorized representative (AR) who is responsible for compliance. As part of its full-service offering, CERTIFY can provide this AR on your behalf and handle all communication with regulatory authorities.
Quantity Reports and De minimis Thresholds
In most countries, volume reports must be submitted based on the kilograms exported, which is used to calculate the disposal fees. In a few exceptional cases, there are de minimis thresholds (e.g., for packaging) that apply only once certain sales volumes are reached. These vary greatly by country, and in some cases exempt businesses only from the fees, not from the registration requirement.
Labeling and Information Requirements
- Packaging Subject to This Requirement: In general, all packaging must be labeled. The only exceptions are very small packages that, for technical reasons, cannot meet the statutory minimum size requirements for symbols.
- Placement: Symbols must generally be affixed directly to the product or its packaging. Stickers are permitted only in exceptional cases and under strict conditions.
- Deadlines: When laws change, national transition periods and production dates determine whether existing inventory can continue to be used.
- Review: Many government agencies offer image file reviews, but these can take several months.
- Voluntary labels: In addition to the mandatory symbols, there are voluntary labels—particularly in Scandinavia—that promote environmental commitment.
Registration Process and Checklist: The Timeline for Achieving Compliance
The EPR registration process consists of the review of product categories, the conclusion of contracts with take-back systems, and the final official confirmation. Due to varying processing times at national agencies, please allow several weeks before you receive your registration numbers. Since a legal ban on distribution is in effect until the process is complete, it is essential to act early.
Download Now: To speed up your process, use our EPR checklist for the initial consultation. It will help you gather all the necessary information for a smooth market entry.
International Complexity: The Case of France
Risk Management: Penalties for Non-Compliance
Violations of EPR requirements (failure to register, incomplete reports, or incorrect labeling) will be strictly penalized.
- Fines: Penalties ranging from €1,000 to €10,000 may be imposed for each violation . These fines can total as much as €20,000 for just two products from the same manufacturer and are sometimes imposed retroactively.
- Platform Bans: Marketplaces are legally required to permanently ban non-compliant sellers.
3 Steps to a Strategic Compliance Solution with CERTIFY
We transform complex regulatory requirements into structured processes so that you can focus fully on your day-to-day business. With our expertise, you gain legal certainty both domestically and internationally, with maximum transparency.
1. Assessment and clarification
2. Strategic Consulting:
3. Full-Service Support
We’ll assign you a personal contact who will keep you informed of relevant updates and changes in the law.
Secure your market access through professional EPR compliance.
We support you in your duties
Do you need advice or support in fulfilling your obligations according to producer responsibility? We take care of your international and national environmental compliance and proactively provide you with the latest info on laws!
FAQ: Technical Answers on EPR Implementation
Selling products without registration constitutes an administrative offence. The ear Foundation (electrical appliances), the Central Agency for Packaging Registration (packaging) and the Federal Environment Agency (batteries) may impose fines of up to €100,000 per offence. In addition, there are sales bans, warnings from competitors under the Unfair Competition Act (UWG) and – in the case of marketplace sales – immediate listing suspensions by Amazon, Otto, Kaufland and eBay.
In practice, failure to register is usually uncovered following reports from competitors, customs authorities or online marketplaces. Anyone who registers retrospectively must report all quantities placed on the market to date with retroactive effect – including licence fees.
Three sets of regulations operate independently of one another; a company may be subject to all three at the same time:
- ElektroG (WEEE): Anyone who manufactures, imports or sells electrical or electronic equipment under their own brand – including battery-powered products and many textiles containing electronic components.
- VerpackG: Any person who places filled packaging on the market for the first time on a commercial basis in Germany, which is typically generated by private end consumers (B2C). The VerpackDG is expected to come into force as its successor from August 2026.
- BattG: Anyone who places batteries or battery-powered devices on the market in Germany for the first time.
- EWKFondsG: Manufacturers, distributors and online retailers who sell single-use plastic products in Germany are obliged to participate in the national waste disposal and cleaning scheme.
Even a single imported product containing a plug, a battery and a shipping box can trigger all three obligations.
There are three main cost categories: one-off registration fees, ongoing licence fees and service charges.
- WEEE registration: from at least €144.50 in ear fees (in accordance with the ElektroGBattGGebVO) plus VAT.
- Packaging licence (LUCID + dual system): typically €200–2,500 per annum for small to medium quantities, depending on the material and tonnage.
- Battery registration: from at least €31.60 in ear fees (in accordance with the ElektroGBattGGebVO) plus VAT.
- Authorised representative (for foreign companies only): depends on the system
Total costs for a small importer without a registered office in Germany: realistically €3,000–8,000 per annum, including service charges.
Experience shows that in-house compliance makes economic sense for companies that operate in a single country, deal with only one EPR category and have in-house staff with the relevant language skills.
As soon as two or more countries, several EPR areas or marketplace sales are added, the internal workload (managing deadlines for representatives and absences, multilingual communication with authorities, annual tariff changes, consulting specialists and experts) exceeds the service costs. A business rule of thumb: outsourcing becomes more cost-effective once internal effort reaches 50 hours per year.
Yes. Each country where you actively sell requires its own EPR registration. Anyone selling via Amazon’s Pan-EU FBA or CEE programmes stores stock in several countries and needs EPR registration in all countries where stock is held – currently these are Germany, France, Italy, Spain, Poland and the Czech Republic.
France also requires UIN numbers (Unique Identifier Numbers) for each EPR sector, which must be stated on every invoice issued to French customers.