The EPR Compliance Checklist for Online Sellers

EPR compliance runs in eight steps, repeated for every EU country you ship to: confirm you are the obligated producer, appoint an authorised representative if required, register with the national authority and join a PRO, collect packaging weights by material, file on the local schedule, pay the eco-modulated fees, keep an audit trail, and monitor new market thresholds. Skipping them is expensive – Germany fines unregistered packaging up to 200,000 euros, plus a marketing ban.

Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026.

If you ship physical products to EU customers, you are legally responsible for the packaging waste you generate – and marketplaces will block your listings if you are not registered. The table below summarises the sequence, and each step is expanded underneath.

Key takeaways

• Registering for compliance is a national obligation for every country you ship to.
• You need to separate packaging weights by material type and intended use.
• Reporting schedules vary from monthly to annually based on your sales volume.

Step 1: Check where you count as an obligated producer

Your first task is to confirm whether you count as an obligated producer. In the context of EU packaging law, a producer is usually the entity that places a packaged product on a national market for the first time. If you operate an e-commerce store in Sweden and ship a packaged order directly to a private consumer in Germany, you act as the producer in Germany. You must comply with the local packaging laws of the destination country regardless of where your business is headquartered.

Step 2: Appoint an authorised representative if crossing borders

The authorised representative requirement is no longer a country-by-country quirk. Since 12 August 2026, Article 45(3) of Regulation (EU) 2025/40 requires a producer that first makes packaging available in a Member State without being established there – the distance-selling case – to appoint an authorised representative for EPR in that Member State. The representative takes on your administrative duties in that territory. Several countries already worked this way: registering on the Spanish MITECO electronic product producers registry requires an authorised representative if your business address is outside of Spain.

Step 3: Register with the national authority and join a PRO

You must register with the national packaging authority in each target market to get your EPR registration number and obtain your unique identifier. In France, this means registering on the French ADEME SYDEREP registration portal to receive your Unique Identification Number (IDU). Once registered with the authority, you must enter into a contract with an approved Producer Responsibility Organisation (PRO). The PRO is the entity that physically finances the recycling of your packaging.

In Germany, failing to register packaging or report packaging volumes in the LUCID registry constitutes an administrative offence punishable by fines of up to 200,000 euros and subsequent marketing bans.

Step 4: Collect your packaging weights by material

You cannot submit rough estimates. You must collect your packaging data by extracting the exact weight in kilograms for every material type you ship. This includes primary product packaging, secondary shipping boxes, and tertiary materials like tape and void fill. Many countries also require you to classify the end user. As an example, the Swedish Environmental Protection Agency reporting divisions force producers to report packaging volumes separated by private household use versus commercial business use.

Calculate your exact material weights and let Gramta turn your real orders into the reports each scheme asks for automatically.

Step 5: File your reports on the correct local schedule

Once you have your data, you must declare it to your chosen PRO. Reporting cadences depend entirely on the country and your specific sales volume. In Sweden, the NPA packaging fee reporting deadlines require companies with packaging fees under 120,000 SEK per year to report quarterly. Companies exceeding that threshold must report their figures every month. In Germany, you must submit a declaration of your planned quantities at the start of the year and confirm your actual shipped quantities in an annual report by 15 May.

Step 6: Pay your eco-modulated fees

After you file your data, your PRO will invoice you. These fees fund the national recycling infrastructure and are calculated using eco-modulation, and you can see exactly how these packaging fees are calculated if you want the full formula. Eco-modulation is a pricing mechanism that penalises hard-to-recycle materials and rewards sustainable design. In Sweden, reporting red plastic costs you roughly 65 percent more per kilogram than green plastic. Paying these fees on time keeps your registration active and your marketplace listings secure.

Step 7: Keep your records audit ready

Regulators and PROs perform audits to catch companies that underreport their weights. You must maintain a clear, timestamped paper trail connecting your raw e-commerce orders to the final kilograms you declared. If you face an audit, you need to provide evidence that your material classifications and weight calculations are accurate.

Step 8: Renew and monitor new market thresholds

Compliance requires ongoing maintenance – but read national thresholds carefully, because what they buy you changed on 12 August 2026.

Since that date the PPWR applies directly in all 27 Member States, and Article 45(1) attaches extended producer responsibility to the packaging you first make available in a Member State with no turnover or volume de-minimis. Under 10 tonnes in a calendar year you file the reduced data set of Article 44(8) – simplified reporting, not an exemption – and a Member State may set that bar lower, never higher.

National reliefs still matter for how much paperwork and fee you face. The Verpact packaging administration 50,000 kg threshold in the Netherlands exempts small producers from waste management fees on standard packaging, and it remains in force – Verpact and the Dutch government's own planning expect it to lapse only in 2027/2028, once the PPWR's own harmonised producer register exists there. Single-use plastics and deposit-bearing containers always carry a zero-kilogram threshold. Treat a national relief as a possible discount on the fee, never as proof you are outside the registration obligation once it actually applies.

One duty sits outside this list entirely. The PPWR's conformity side – the Annex VII technical documentation and the Annex VIII EU declaration of conformity, under Articles 15 and 38–39 – is live now for the requirements that already apply, and it lands on the manufacturer role, which for own-brand or imported packaging can be you (Article 21). That is a different hat from the producer role Articles 44–45 put the registration duty on; you can easily wear both.

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Sources:

• Regulation (EU) 2025/40 (PPWR), full text
• Spanish MITECO electronic product producers registry
• French ADEME SYDEREP registration portal
• German ZSVR LUCID packaging register guidelines
• Swedish Environmental Protection Agency reporting divisions
• NPA packaging fee reporting deadlines
• Verpact packaging administration 50,000 kg threshold