How Many EPR Registrations Do I Actually Need?

To comply with EU packaging laws, you need a separate Extended Producer Responsibility registration for every country you ship physical goods to, and often more than one sign-up per country. The stakes are national too: Estonia, for example, makes breaching the producer responsibility obligation punishable by a fine of up to 200,000 euros.

Key takeaways

• No single EU registration: there is no "EU-wide" EPR number; compliance is managed country by country.
• The dual-step trap: a single country often requires registering with both a national state register and a Producer Responsibility Organisation (PRO).
• Significant penalties: failing to obtain the correct registrations before shipping can lead to blocked listings, sales bans, and major fines.

Why one country often means multiple registrations

Many merchants assume that completing one registration form per country is enough. However, in the world of Extended Producer Responsibility (EPR), "one country" rarely equals "one quick registration." In most jurisdictions, you must register with both a government-run monitoring register and a collective scheme or Producer Responsibility Organisation (PRO) that physically handles the recycling.

Before you can legally place packaging on the market, you must understand who needs to register. You can check the criteria to see if your brand is liable by reading who needs to register for EPR.

Italy: a worked example of multiple registrations

Italy is a prime example of a multi-tiered system. To place packaging on the Italian market, a foreign distance seller must work through more than one body:

1. The national register (RENAP): you must first register with the RENAP national producers register, the portal the Italian Environment Ministry (MASE) opened in May 2025 to record EPR-obligated producers, to obtain your official producer status.
2. The CONAI packaging consortium: you must then join the CONAI packaging consortium to declare your packaging quantities and pay the environmental contribution (Contributo Ambientale CONAI). CONAI then routes each material to its dedicated consortium (Corepla for plastic, Comieco for paper and board, and five others), so a single CONAI membership already covers those material streams rather than a separate sign-up for each.

Selling legally in Italy therefore means clearing at least two distinct systems, RENAP and CONAI, before a single order ships.

"Producers shall not make available packaging or packaged products on the territory of a Member State for the first time ... if they or, where applicable ... their authorised representatives for the extended producer responsibility are not registered in that Member State." — Article 44(4), Regulation (EU) 2025/40

Ireland: why major producers must now join Repak

Ireland shows how national rules can tighten over time. Under the European Union (Packaging) Regulations 2014, S.I. No. 282/2014, your business counts as a "major producer" if it has an annual turnover above 1 million euros and supplies over 10 tonnes of packaging material in Ireland. Major producers once chose between two compliance routes, but that choice has since been removed.

Originally, a major producer could either self-comply, registering directly with every individual local authority where it supplied products, or join Repak, Ireland's approved compliance scheme to discharge those obligations collectively. The 2022 amendment to the Packaging Regulations, S.I. No. 659/2022 then abolished the self-compliance option, so every major producer must now register with Repak. There is no longer a do-it-yourself alternative.

Managing these separate systems across multiple countries is incredibly time-consuming. You can get started with Gramta to automate your reporting data across all your markets and skip the administrative headache.

The upcoming PPWR harmonisation and national registers

With the transition to the new EU Packaging and Packaging Waste Regulation (PPWR), some aspects of EPR will become more harmonised. For instance, the exact data fields you submit will be standardised. However, the PPWR does not create a single, unified European database.

Under Regulation (EU) 2025/40's register of producers provisions, every EU Member State is required to establish its own national register. You must still register individually with the competent authority of each specific country where you sell, following their national registration timelines.

To ensure your brand does not fall behind these national rules, you can review the upcoming dates in the EPR registration rules and deadlines for 2026.

Simplify your multi-country compliance with Gramta

If you sell your products in Germany, France, Italy, and Sweden, you are looking at managing at least eight different national databases, PRO portals, and local reporting formats. Doing this manually via spreadsheets is an invitation for compliance errors, audit failures, and marketplace suspensions.

Gramta takes the pain out of multi-country compliance. You set up your packaging spec once — materials, weights, recyclability grades — and Gramta combines it with your daily Shopify or Amazon sales to produce clean packaging reports tailored to the exact requirements of every European register.

Protect your business from delisting and focus on growing your brand. Get started with Gramta today to automate your EPR compliance across the EU.

Sources:

• Estonian Ministry of Climate on EPR obligations and fines
• RENAP, Italy's national producers register
• CONAI packaging consortium membership and contributions
• European Union (Packaging) Regulations 2014, S.I. No. 282/2014
• 2022 amendment to the Irish Packaging Regulations, S.I. No. 659/2022
• Repak, Ireland's approved packaging compliance scheme
• Regulation (EU) 2025/40 on packaging and packaging waste