Extended Producer Responsibility under the PPWR
Under PPWR Article 45, if you first make packaging available in a member state you are a "producer" for extended producer responsibility (EPR) and must register and pay fees in that state — separately for each market you sell into. Fees are eco-modulated (adjusted by how recyclable the packaging is), and a producer with no establishment in a given member state must appoint an authorised representative for EPR there.
This is general information about Regulation (EU) 2025/40, not legal advice. Confirm anything you act on with qualified counsel or an accredited body.
What EPR means
Extended producer responsibility makes the producer financially (and sometimes operationally) responsible for the end-of-life management of the packaging they put on the market — collection, sorting and recycling. Regulation (EU) 2025/40, Art. 45, sets the PPWR framework for packaging EPR, building on the existing national producer-responsibility systems.
Register per market — not once for the EU
EPR is administered nationally. You register with the packaging producer register in each member state where you make packaging available, and meet that state's reporting and fee obligations, within the framework Art. 45 sets. There is no single EU-wide registration today; the EU is working toward more consolidated arrangements, but for now a business selling into, say, Germany, France and Spain registers in each.
| Member state | Register / system |
|---|---|
| Germany | LUCID register (Zentrale Stelle Verpackungsregister) plus a dual system |
| France | Producer register plus an approved PRO (e.g. Citeo) |
| Spain | Producer register plus a packaging scheme (e.g. Ecoembes) |
| Italy | CONAI consortium (or a recognised alternative) |
| Ireland | Repak |
| Poland | BDO national database |
These bodies are named as public information; the operative body, deadlines and fees are set nationally, so confirm the current register for each market before you rely on it.
Eco-modulated fees
Under Art. 45, EPR fees are eco-modulated — adjusted according to the packaging's environmental performance, in particular its recyclability. Better-designed, more recyclable packaging attracts lower fees; poorly recyclable packaging attracts higher ones. This is the financial link between your recyclability grade (Art. 6) and your ongoing EPR cost, and a direct reason to design up the grade scale.
Non-EU sellers: the authorised representative
If you place packaging on the EU market but have no legal establishment in a member state, you must appoint an authorised representative for EPR in that member state to carry out your producer obligations there (Art. 45). This is a distinct role from any product-safety representative and is essential for online sellers and marketplaces shipping into the EU. Online marketplaces also have duties to check that the third-party producers selling through them are properly registered.
What to do
- List every member state you place packaging in — that is your registration map.
- Register with each national system and set up reporting; registration typically takes time, so start early.
- If you are non-EU, appoint an authorised representative per market.
- Track your recyclability grade — it drives your eco-modulated fee.
Get this mapped to your own packaging
The report screens your packaging profile against Regulation (EU) 2025/40 and returns only the obligations that apply to you — each with its threshold, deadline and article, plus supplier letters ready to send.
Get my PPWR obligations report →Frequently asked questions
Do I have to register for EPR in every EU country I sell into?
Yes. Packaging EPR under Article 45 of Regulation (EU) 2025/40 is administered nationally, so you register and meet fee and reporting obligations in each member state where you make packaging available. There is no single EU-wide registration at present.
What are eco-modulated EPR fees?
EPR fees adjusted by the environmental performance of the packaging, especially its recyclability (Article 45). More recyclable packaging attracts lower fees; less recyclable packaging attracts higher fees — linking your Article 6 recyclability grade to your EPR cost.
I sell into the EU from outside it. What do I need?
If you have no establishment in a member state, you must appoint an authorised representative for EPR in that member state to carry out your producer obligations there (Article 45). Online marketplaces also have duties to check the producers selling through them are registered.
Who counts as the "producer" for EPR?
For EPR purposes the producer is generally the party that first makes the packaging available on the market within a given member state — the one responsible for registering and paying fees there. Confirm your specific position, as it varies by role and market.
Sources
- Regulation (EU) 2025/40 (PPWR) — Art. 45 extended producer responsibility: registration per member state, eco-modulated fees, authorised representative for non-EU producers — https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- National packaging producer registers / PROs (e.g. LUCID/Germany, Citeo/France, Ecoembes/Spain, CONAI/Italy, Repak/Ireland, BDO/Poland) — public information; confirm the current body per market — https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en