Do I need a separate EPR registration in every EU country I sell to?

Yes, you must register for Extended Producer Responsibility (EPR) in every EU country where you sell. There is no single EU-wide registration because compliance remains strictly national, and failing to hold a French ADEME unique identifier rules can result in administrative fines of up to €30,000 under the French Environmental Code.

Why EPR compliance is strictly national

While European Union directives set general environmental targets, they do not establish a centralised compliance system. Instead, each individual EU Member State transposes these directives into national legislation. Consequently, every country operates its own registries, system operators, packaging definitions, and fee structures.

If you are an online seller placing packaging on the market for the first time, you are legally considered the "producer" in those jurisdictions. To avoid costly non-compliance penalties, you must assess your sales footprint on a market-by-market basis to determine who needs to register for epr across your active sales channels.

Key national registers and requirements

To illustrate the deep administrative fragmentation of the European market, online brands should look closely at how Germany, France, and Italy manage their separate packaging compliance requirements.

Germany: LUCID and the Verpackungsgesetz

In Germany, online merchants must register with the the LUCID producer register operated by the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register - ZSVR). Under the German Packaging Act (VerpackG), registration is free of charge, but you must complete it before placing any commercial packaging on the market. There are no de minimis thresholds.

However, if your annual packaging volumes exceed specific high-volume limits, you are subject to the strict VerpackG audit rules. If you place more than 80,000 kg of glass, 50,000 kg of paper and cardboard, or 30,000 kg of plastics and lightweight packaging on the German market in a calendar year, you must submit an audited LUCID declaration of completeness by 15 May of the following year.

France: ADEME, Citeo, and the unique identifier

France applies some of the most rigorous EPR rules in the EU, enforcing mandatory registration from your very first packaging unit. To comply, you must join a state-approved producer responsibility organisation (PRO) like Citeo or Adelphe.

For small businesses placing fewer than 10,000 Consumer Sales Units (CSUs) on the French market annually, Citeo household packaging rates allow you to declare your status in a few clicks and pay a simplified minimum annual flat rate of €80 excl. tax. If you place 500,000 CSUs or more on the market annually, you must submit a detailed declaration detailing exact packaging materials and weights. Regardless of your sales volume, you must obtain a unique identifier (IDU) generated by the French agency for ecological transition (ADEME) and display it in your terms and conditions.

Italy: CONAI and the RENAP portal

Italy operates a dual-layered compliance model. Sellers must first register with CONAI (Consorzio Nazionale Imballaggi) to manage their basic environmental contributions. Additionally, under Ministerial Decree No. 144 of 15 April 2024, the Ministry of the Environment and Energy Security (MASE) established the RENAP National Register of Producers, which officially went live on 7 May 2025.

EPR fees in Italy are heavily modulated to incentivize eco-design. For plastic packaging, fees are split across nine distinct bands based on recyclability. For example, under the CONAI modulated plastic fees updated on 1 July 2025, rates range from €40.00 per tonne for Band A1.1 (highly recyclable industrial packaging) up to €790.00 per tonne for Band C (non-recyclable or disruptive plastics).

Keeping track of separate deadlines, reporting formats, and fee structures in multiple EU countries can quickly become overwhelming. Get started with Gramta to automate your multi-country transaction processing and generate filing-ready reports.

"Extended Producer Responsibility is entirely national. There is no single EU-wide EPR register, meaning online merchants must comply with the distinct regulations, reporting frequencies, and fee bands of every Member State they sell to."

How marketplaces enforce compliance

If you sell your products through third-party e-commerce channels, compliance is no longer optional. Under French and German law, online marketplaces have a legal obligation to verify that all third-party sellers are properly registered.

If a seller cannot provide their unique identifier, the marketplace operator must step in, declare the volumes, and pay the corresponding fees on the seller's behalf. To cover these administrative costs, marketplaces can apply their own penalty pricing structures to each of your transactions. Failing to provide your registration details can also lead to your product listings being blocked or your merchant account being suspended.

To safeguard your storefront from sudden disruptions, brands must map out their compliance requirements well in advance. Setting up these processes early is vital before the upcoming EPR registration rules in the EU for 2026 take full effect across all Member States.

Do not let national compliance barriers slow down your European growth. Gramta handles the heavy lifting of mapping your e-commerce transactions directly to the required material categories and packaging weights, keeping your business compliant across Germany, France, Italy, and beyond. Get started with Gramta today to organize your multi-market reporting and protect your business from costly administrative fines.

Sources:

• ADEME unique identifier rules
• the LUCID producer register
• LUCID declaration of completeness
• Citeo household packaging rates
• RENAP National Register of Producers
• CONAI modulated plastic fees