Understanding EPR and EU packaging rules

As sustainability regulations tighten across Europe, e-commerce sellers must prepare for sweeping changes under Regulation (EU) 2025/40 and Extended Producer Responsibility (EPR) schemes. This guide breaks down what you need to know, how to comply, and what’s at stake if you don’t. 

What is Extended Producer Responsibility (EPR)? 

As part of the wider effort to establish a fully circular economy, EPR is an environmental policy that makes producers financially and physically responsible for the entire lifecycle of their products, including design, packaging, recycling, and disposal.  Our EPR FAQs guide takes a more detailed look at what EPR is and why it matters, and we also took a deep dive into the four key components of the regulation.

If you manufacture, import, or sell products in countries with EPR legislation, you’re likely considered a “producer” and must comply. 

Who’s affected by the regulation? 

In short, you are responsible if you: 

• Manufacture and sell products domestically 

• Import products into an EPR-regulated country 

• Sell products in a country with EPR rules (including via online marketplaces) 

This includes sellers on platforms like Amazon and eBay, which increasingly require proof of compliance. 

🛒 Which EU top EU marketplaces require EPR compliance – and why? 

As part of a broader effort to ensure accountability and legal conformity across digital platforms, under EU and national laws, marketplaces are increasingly legally responsible for ensuring that sellers on their platforms are EPR-compliant. If a seller fails to register, the platform itself may be held liable, prompting stricter enforcement. 

Amazon 

• Amazon’s guidance outlines the requirements, such as uploading valid EPR registration numbers for packaging, WEEE (electrical and electronic equipment), and batteries. 

• In countries like France and Germany, Amazon may block listings or withhold payments if sellers fail to comply.  

eBay 

• eBay enforces compliance in France, Germany, and Spain. 

• Sellers must provide registration numbers or risk having their listings removed.  

Etsy 

• Etsy has begun implementing checks, particularly for sellers shipping to France and Germany. 

• Sellers may be required to confirm compliance or provide documentation in line with the marketplace guidance.

Kaufland.de 

• This German marketplace mandates EPR registration for packaging and electronics. 

• Sellers must be registered with the LUCID Packaging Register and other relevant schemes.  

Cdiscount (France) 

• Enforces EPR compliance for packaging, electronics, and batteries. Sellers must join an approved eco-organisation and provide registration numbers to avoid penalties.
• Requires proof of registration for packaging, electronics, and batteries. 

• Non-compliant sellers may be delisted or fined  

ManoMano 

• Sellers must comply with French EPR laws, especially for packaging and electrical goods. 

• ManoMano may act as a proxy for EPR obligations if sellers fail to register.  

What does Regulation (EU) 2025/40 require of sellers, and by when?

Effective 12 August 2026, this EU regulation introduces harmonised packaging rules across the EU. Key requirements include: 

• Recyclable packaging: all packaging must be recyclable by design 

• No over-packaging: packaging must be proportionate to the product 

• Recycled content: minimum thresholds for recycled plastic content 

• Clear labelling: packaging must indicate recyclability and material composition 

• Reusable options: sellers are encouraged to offer reusable packaging 

• EPR: you must register with national schemes and pay eco-contributions 

⚠️ What are the country-specific penalties?

Each EU country enforces its own penalties for non-compliance: 

EPR registration process: 4 steps 

To comply, you’ll need to: 

1. Register with local authorities or Producer Responsibility Organisations (PROs) 
2. Submit product data, including packaging weights and materials 
3. Appoint an Authorised Representative (AR) if you’re not based in the country 
4. Report annually and pay eco-contributions based on actual sales 

What documents are needed for EPR registration? 

To register, you’ll typically need: 

• Company registration certificate 

• Director’s ID or passport 

• Forecasted packaging data 

• Local Authorised Representative (if applicable) 

Upcoming EPR deadlines to note

• Battery registration: 18 August 2025 

• Full packaging compliance: 12 August 2026 

✅ At a glance: your EPR compliance checklist 

• Use recyclable and minimal packaging 

• Meet recycled content thresholds 

• Label packaging clearly 

• Register with national EPR schemes 

• Appoint an Authorised Representative if needed 

• Submit annual reports and pay fees 

• Monitor updates in each country you sell to 

Your key takeaways 

Selling internationally means complying with EPR in each destination country.  Many online marketplaces (e.g., Amazon, eBay) increasingly require sellers to prove compliance, so understand which EPR categories apply to your products in each country you sell.   

Determine if you are considered a producer, and sign up with the appropriate schemes. You’ll also need to budget for EPR fees in your pricing and business model, and stay informed on EPR legislation updates in relevant markets, such as Spain and Germany. 

EPR and EU packaging regulations are reshaping businesses’ operations as they continue to evolve. By preparing early, you can avoid penalties, maintain marketplace access, and build a more sustainable brand.