EPR: Extended producer responsibility in cross-border e-commerce – Guide 2025

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is an environmental policy concept that requires producers to manage the full life cycle of their products, with an emphasis on collection, recycling and safe disposal. The aim of this system is to minimise the negative impact ofwaste on the environment and promotesustainable resource management.

In the context of online retailers operating in the European market, EPR implies the need to ensure that the products on offer are properly recycled or disposed of at the end of their life cycle.

These regulations cover a broad spectrum of product categories, divided into 3 categories: electrical and electronic equipment (WEEE), batteries (EPR for batteries) and packaging (EPR for packaging). Within Europe, EPR schemes are also gradually being introduced for textiles. In some countries, they also cover furniture, toys, mattresses, tyres and other products.France is an example of such a country. . In short: anyone who puts electrical appliances or batteries on the market is obliged to ensure that they are recycled in accordance with EU regulations.

The EPR scheme requires producers to register with the relevant schemes, pay the relevant fees and submit detailed reports on the volume and type of products placed on the market. These actions support a closed-loop economy and contribute significantly to reducing the environmental impact of manufacturing activities.

Importance and Objectives of EPR for E-Commerce in Europe

Online retailers must comply with relevant national EPR (Extended Producer Responsibility) legislation to avoid legal consequences and contribute to a more sustainable economy. This includes registering with national EPR schemes and paying fees that fund recycling and waste disposal programmes. By complying with EPR requirements, online retailers are helping to reduce waste and increase material recycling rates.

Tougher regulations are increasingly focusing on online retailers, especially those selling direct to consumer (D2C). For example, across Europe, shopping platforms will soon be required to verify that online sellers are registered in the countries they target. Amazon, for example, already requires its sellers to provide proof of EPR number registration.

In addition, sellers will be required to appoint an authorised representative responsible for extended producer responsibility in all Member States where they do not operate. As EPR and waste regulations are implemented at a national level across Europe, compliance can be particularly complicated for online shops sending products abroad.

Who is considered a 'producer' within the meaning of the EPR?

In the EPR, the term ‘producer’ does not refer to the manufacturer of the package, but to the companythat:

• markets products in a particular country (e.g. by sellingonline)
• packages products or has them packaged
• imports or sells packaged products

Example:
A Polish online shop that sells its products to customers in Spain introduces its products to the Spanish market for the first time and is treated as a ‘manufacturer’ there within the meaning of the EPR.

How can online retailers become EPR compliant?

Online retailers must comply with certain extended producer responsibility requirements in each country where they sell their products. This means joining the national EPR programme in each Member State. These obligations include registration with the relevant authorities and participation in recycling programmes for the proper disposal of packaging, electronic devices and, in the future, textiles and other products.

Examples of EPR legal requirements in different European countries

In Europe, the legal basis and requirements for EPR (Extended Producer Responsibility) vary from country to country. We have compiled extensive country-specific information on our blog to help you effectively navigate these differences.
Implementing EPR is crucial for companies operating across borders, as non-compliance with local regulations can result in serious sanctions. Understanding the requirements in each country allows you to better plan logistics and operational costs.

EPR in Germany
In Germany, the Packaging Act (VerpackG) regulates the requirements for EPR. Manufacturers are obliged to register in the LUCID Register (Zentrale Stelle Verpackungsregister) and to participate in the dual system.
Similarly, the Electrical and Electronic Equipment Act (ElektroG) and the Battery Act (BattG) regulate the EPR for electronic products and batteries.

See how to register WEEE in Germany: ElectroG, the WEEE Directive in Germany

EPR in France
In France, the law on the circular economy and waste reduction establishes strict requirements for EPR. Companies must register with the relevant authorities and contribute to the financing of waste management programmes.
In addition to EPRs for packaging, WEEE (Waste Electrical and Electronic Equipment) and batteries, France has long had an EPR scheme for textiles. There are also EPR obligations for other product categories such as toys, furniture, DIY products, tyres and many others.

See how to register for EPR in France: EPR numbers – parcel packaging registration in France

EPR in Italy
In Italy, the Waste Framework Directive law requires producers to register with CONAI, the National Packaging Consortium.
For WEEE and batteries, producers must appoint an authorised representative to manage extended producer responsibility. There are also currently plans to introduce an EPR scheme for textiles in Italy.

EPR in Spain
In Spain, online retailers marketing products must register with the Register of Manufacturers and pay the required fees and contributions to one of the approved national collection systems in Spain.
Compliance with these regulations is crucial to avoid penalties and legal consequences.

See how to register for ERP in Spain: Registration of packaging/waste in Spain – changes

EPR in the Netherlands
In the Netherlands, EPR obligations are enforced for various product groups, including packaging, electronics, batteries and tyres. Producers must report the quantities of products they introduce to the relevant organisations, such as Afvalfonds Verpakkingen for packaging.
The Dutch system places a strong emphasis on transparency and accurate reporting, as well as on achieving certain recycling levels.

EPR in Sweden
Sweden has some of the most developed EPR systems in Europe, covering a wide range of products from packaging to furniture.
Companies must register with recovery organisations and meet strict reporting and recycling standards. The Swedish authorities actively monitor compliance, resulting in a high level of compliance.

EPR in Poland
In Poland, EPR obligations are set out in the Packaging and Packaging Waste Management Act. Producers must ensure waste recycling and pay product fees or cooperate with recovery organisations.
In addition, registration in the Waste Database (BDO) and regular reporting is mandatory for products such as electronic equipment and batteries.

Meeting Extended Producer Responsibility Requirements throughout Europe

Each EU Member State has specific requirements for EPR (Extended Producer Responsibility). These regulations aim to increase recycling rates and reduce environmental impact. As an online retailer, it is important to understand and comply with each country’s specific EPR rules.

The impact of EPR on cross-border e-commerce
Extended Producer Responsibility (EPR) has significant implications for online sellers selling internationally. The EPR requires manufacturers and importers to be responsible for the entire life cycle of their products, including disposal and recycling. For online retailers operating in a direct-to-consumer (D2C) model, this means ensuring that their products meet the legal requirements of the destination countries.

This requires careful planning and management, as each country has its own set of regulations. Vendors may be required to register in multiple countries and pay associated fees. Additionally, EPR compliance can generate additional costs that must be factored into business operations.

However, complying with EPR requirements allows online retailers to make a positive contribution to environmental protection and improve brand image. The key is to understand the specific requirements of the target markets and take appropriate measures to avoid legal consequences.

Extended Producer Responsibility (EPR) for online sales

The EPR for online sales was introduced relatively recently (in 2022). Under this regulation, online platforms are required to verify their sellers’ compliance with the EPR regulations. In some countries, such as France, Spain and the UK, online marketplaces can – or even have to – take over the EPR obligations for sellers if the sellers are not self-registered.

For this reason, platforms such as Amazon have started to require their sellers to provide EPR numbers to ensure compliance. This is crucial for platforms, as they can otherwise be held liable and face severe financial penalties or bans on sales in the EU.

New EU Packaging Regulation 2025/40 PPWR: what does it mean for e-commerce?

The current EU Packaging Directive will be replaced by the new EU Packaging and Packaging Waste Regulation (PPWR). The new legislation came into force as Regulation (EU) 2025/40 in February 2025.

Most of the provisions of the new law will only take effect after 18 months, but it is already clear that the PPWR will have a major impact on e-commerce across the European Union. This is particularly true for small businesses sending goods to various European countries, but the new regulations will also cover logistics operators, sales platforms (marketplaces) and even individual customers.

Fromaroundmid-2026, online retailers will only be able to sell on online marketplaces in their own country or in countrieswhere they comply with EPR obligations. Under the EU Digital Services Act, this applies to all online marketplaces that are not classified as micro or small businesses. The aim of this legislation is to prevent online retailers from circumventing the extended producer responsibility rules.

Key change from 2026 affecting all ecommerce sellers!

Extended Producer Responsibility (EPR) for online marketplaces was introduced relatively recently. Under this regulation, online platforms are obliged to verify sellers’ compliance with EPR requirements. In some countries, such as France, Spain and the UK, online platforms can – or even have to – take over EPR obligations for sellers if the sellers are not registered.

As a result, marketplaces such as Amazon require their sellers to submit EPR numbers to ensure compliance. This is essential for platforms, as they can otherwise be held liable and face severe financial penalties or bans on sales within the European Union.

The Packaging and Packaging Waste Regulation (PPWR) will extend the EPR obligations of online platforms to all EU member states. From around mid-2026, online retailers will only be able to sell their products in markets in their own country or in countries where they comply with the EPR. Under the EU’s Digital Services Act (DSA), the rules apply to all online marketplaces that are not classified as micro or small businesses. The aim is to prevent online sellers from circumventing the extended producer responsibility rules.

Summary

Registration obligations under EPRO, WEEE or Extended Producer Responsibility (EPR) schemes already extend to all EU countries. Each country has its own regulations and procedures to ensure producer responsibility for packaging, electronic equipment or batteries placed on the market.

In some countries – such as Germany or France – the process is relatively straightforward and well organised. However, there are also markets, such as Spain, Italy or Portugal, where regulations are more complicated and inspections and penalties for non-compliance are more frequent and severe.

For this reason, an increasing number of companies are choosing to work with specialised partners who handle the complete handling and registration in the required EPR systems in the different EU countries.

And if you are planning to expand abroad or are already selling outside of Poland, as Global24 we can help you with returns and international shipments for your online shop. Together, we will select a logistics solution that will increase your competitiveness and support the growth of your sales in foreign markets.