Extended Producer Responsibility (EPR) shifts the cost of dealing with packaging waste from taxpayers and municipalities to the businesses that put the packaging on the market. If you are the first to place packaging filled with goods on a national market, you are typically the "producer" for EPR purposes — and that includes non-domestic sellers acting through an importer or a representative.
How it works in practice
Register in the national packaging producer register (each country runs its own).
Join a producer responsibility organisation (PRO) — often called a compliance scheme or, in Germany, a dual system — which organises collection and recycling on members' behalf.
Report the weights and material types of packaging you place on the market for each reporting period.
Pay fees based on those quantities. Fees are increasingly modulated — cheaper for recyclable, well-designed packaging and dearer for hard-to-recycle formats.
Why it is country-by-country
EPR is national. Selling into five EU countries usually means five registrations, five sets of reports and five sets of fees, each with its own register, PRO, deadlines and thresholds. A single EU registration does not exist for packaging EPR. This is the single biggest source of hidden work for cross-border sellers.
This explains the general model; the specific duties, thresholds and deadlines are set by each country's law.
