EU Packaging EPR Compliance in 2026
Packaging Extended Producer Responsibility (EPR) is the EU-wide policy approach that makes the “producer” of packaging financially (and sometimes operationally) responsible for the collection, sorting, and recycling of packaging waste. In practice, it means you usually must register in each country where you place packaged goods on the market, join a Producer Responsibility Organisation (PRO), report packaging volumes, and pay EPR fees.
First: EPR is not GPSR (people mix these up)
GPSR is product safety. It is about safe products, documentation, traceability, warnings, and market surveillance.
Packaging EPR is environmental compliance. It is about financing national recycling systems and reporting packaging placed on the market.
You can be GPSR-compliant and still be non-compliant on packaging EPR, and vice versa. If you are unsure how GPSR fits into your overall EU strategy, see our EU compliance guide for selling consumer products and our complete guide for non-EU sellers.
Key definitions (plain English)
Producer (for packaging EPR)
The entity legally obligated to register, contract, report, and pay for packaging waste management. This is often the brand or online seller placing packaged goods on the market, but it can shift based on import and distribution structure.
PRO (Producer Responsibility Organisation)
The compliance organisation that runs (or finances) the system on behalf of producers. You contract with a PRO to meet your obligations.
Household packaging vs commercial/industrial packaging
Many countries focus primarily on household packaging; some also regulate commercial or industrial packaging. The boundary matters for scope and fees.
Eco-modulation
Fee adjustments (bonus or penalty) based on recyclability, recycled content, problematic components, and other criteria. The goal is to incentivise better packaging design.
DRS (Deposit Return System)
A separate (often parallel) system for beverage containers, usually with deposits. It can affect what is considered in scope for packaging EPR fees and how reporting works.
What is harmonised at EU level vs what is national
The EU baseline
The EU framework sets common objectives and minimum requirements, but registration, PRO contracting, reporting formats, and labelling are still largely national. Practically, you still need to comply country by country.
The PPWR shift (timing matters)
The EU Packaging and Packaging Waste Regulation (PPWR) is designed to reduce fragmentation over time, including around labelling, but it phases in. Plan for country-by-country compliance today while preparing for convergence as PPWR requirements apply. Learn more about our PPWR Compliance Service and read our PPWR compliance guide.
What you must do in any EU country (minimum viable compliance)
Step 1: Map where you “place packaging on the market”
This is usually where your customer receives the packaged goods (destination-based), not where you ship from.
Step 2: Identify who is the obligated “producer” in your chain
Common cases include:
- Brand selling direct-to-consumer into the EU
- Non-EU brand selling via marketplaces into the EU (see also Amazon EU sales and compliance)
- EU importer of record placing goods onto the national market
- Local distributor relabelling or repacking goods
Step 3: Break down packaging types you use (don’t miss the hidden ones)
- Primary product packaging
- Secondary packaging (multipacks, sleeves)
- Shipping packaging (e-commerce boxes, mailers)
- Filler (paper, air pillows), tape, labels, inserts
Step 4: Build a data model before you register
At minimum:
- SKU-level packaging bill of materials (BOM) with weights by material
- Country allocation logic (sales by destination)
- A process for changes (new SKUs, new suppliers, packaging redesign)
Step 5: Register and contract (country-specific)
Many countries require registration first, then joining a PRO or compliance scheme, then periodic reporting and payment.
Step 6: Label if the country requires it
France is the most operationally impactful example today because it has strict consumer sorting information rules.
Step 7: Report, pay, and keep evidence
Keep contracts, confirmations, volume calculations, and any label artwork approvals.
Germany packaging EPR: what to do (LUCID + dual system licensing)
What applies
Germany uses the LUCID register operated by the Central Agency Packaging Register (ZSVR) and a competitive “dual system” model for household packaging licensing.
Who must comply
If you commercially distribute packaged goods in Germany, you typically must register in LUCID and license household packaging with a dual system.
What to do
- Register in LUCID (ZSVR)
- Contract with an approved dual system (PRO) for household packaging
- Submit required data reports and keep them consistent across declarations
- Maintain evidence for audits and marketplace checks
How EaseCert helps for Germany
France packaging EPR: what to do (PRO + Triman/Info-tri labelling)
What applies
France requires packaging EPR participation via an approved PRO and has strong eco-modulation. France also requires consumer sorting information using the Triman symbol and Info-tri sorting instructions for many products.
Who must comply
If you place household packaged goods on the French market, you generally must join an approved PRO and report packaging placed on the market.
Labelling: Triman + Info-tri
Treat this as a packaging artwork and supply chain project: determine which components need what sorting instruction, update packaging artwork, and plan lead times for old stock run-down and new print runs. For broader EU labelling context, see our labelling requirements guide.
What to do
- Confirm scope (household packaging and any additional EPR streams)
- Contract with an approved packaging PRO
- Implement Triman/Info-tri labelling workflow
- Report volumes and pay fees (eco-modulation can affect costs)
How EaseCert helps for France
Eco-modulation: why design is now a compliance lever
Even where eco-modulation is limited today, you should build “fee readiness” into packaging design decisions because modulation criteria are expanding and are likely to become more consequential over time.
Practical actions
- Avoid hard-to-recycle composites where alternatives exist
- Avoid disruptive additives (for example, difficult labels/adhesives)
- Increase recycled content where feasible
- Document packaging specs so you can respond quickly to evolving fee criteria
Single PRO vs competing PRO systems: what changes for you
In single-PRO style systems
- More standardised onboarding
- Fewer provider choices
- Often clearer national rules and processes
In competing PRO systems
Compare providers on:
- Fee methodology (by material, by unit, recyclability criteria)
- Services (data tools, customer support, labelling guidance)
- Audit and evidence expectations
DRS and packaging EPR: avoid double counting and scope mistakes
Deposit Return Systems are usually targeted at beverage containers and can be separate from packaging EPR. Validate, per country, how DRS interacts with EPR reporting and fees so you do not under-report or double count.
The operational checklist (copy/paste)
- Countries in scope (destination-based)
- Producer decision (brand vs importer vs distributor vs marketplace)
- Packaging inventory (product + shipping components)
- Packaging BOM weights by material
- Registration and PRO contracting by country
- Labelling requirements (notably France today)
- Reporting and payment calendar
- Design and eco-modulation readiness
PPWR roadmap: why you should start now
PPWR aims to reduce fragmentation, but it does not remove immediate national EPR obligations. Build compliance now and plan for packaging design and labelling convergence as PPWR requirements phase in.
EaseCert PPWR support
What we need from you (to make this country-specific)
- Selling countries (which EU member states you ship to)
- Sales model (own site, marketplaces, distributors, B2B only)
- Packaging types you use (product + shipping components)
- Who is the “producer” in your chain
- Estimated annual packaging volumes by material (if available)
Frequently Asked Questions
Is packaging EPR the same as GPSR?
No. GPSR is about product safety, technical documentation, traceability, and market surveillance. Packaging EPR is about financing the collection and recycling of packaging waste in each EU country.
If you fail to comply with GPSR, products can be stopped at customs, withdrawn, or recalled. If you fail to comply with packaging EPR, the usual consequence is a request to register and regularise your participation, and marketplaces may suspend listings.
Do I need packaging EPR in every EU country I sell to?
Yes, in principle. Packaging EPR is country-specific. If you place packaged goods on the market in multiple EU member states, you generally need to register and participate in each national system separately.
Who is considered the “producer” for packaging EPR?
The obligated “producer” is usually the company that first places the packaged goods on the national market. This can be:
- The brand selling directly to consumers
- The EU importer of record
- A local distributor
- In some cases, a marketplace seller
The correct allocation depends on your supply chain and sales model. If you are unsure, contact us for a structure review.
What is a PRO?
A PRO (Producer Responsibility Organisation) is the entity that manages or finances the packaging waste system on behalf of producers. In most EU countries, you must sign a contract with an approved PRO and report your packaging volumes periodically.
Do I need to register in Germany before selling?
Yes. If you place packaged goods on the German market, you must register in LUCID and license your household packaging with a dual system.
See our LUCID registration guide or use our LUCID Registration Service.
What is special about France packaging EPR?
France combines EPR participation with mandatory consumer sorting information (Triman and Info-tri labelling). This affects your packaging artwork and supply chain.
Learn more in our France Triman and Info-tri guide or use our France EPR Packaging Compliance service.
What is eco-modulation?
Eco-modulation means your EPR fees can increase or decrease depending on recyclability, recycled content, or other design features. This makes packaging design a compliance and cost lever, not just a sustainability topic.
Does Deposit Return System (DRS) replace packaging EPR?
No. DRS usually applies to specific beverage containers and operates alongside packaging EPR. You must check country-by-country how DRS interacts with EPR reporting to avoid double counting or under-reporting.
Is packaging EPR required if I already completed WEEE registration?
Yes. WEEE and packaging EPR are separate legal regimes. If you sell electronics, you may need both.
See our WEEE registration guide for details.
Do I need an EU Responsible Person for packaging EPR?
Not usually for packaging EPR itself. However, under GPSR and other product legislation, non-EU manufacturers often need to appoint an EU Responsible Person.
Read more about the roles and requirements.
What happens if I do not comply with EU product safety rules?
Non-compliance with GPSR can lead to fines, product withdrawal, recalls, and marketplace suspension.
Learn more about what happens if you don’t comply and how to manage product recalls under GPSR.
Where can I get full support for EU compliance?
EaseCert provides integrated support across packaging EPR, GPSR, Responsible Person services, WEEE, chemical compliance, technical documentation, and market access.
Visit What We Offer, check our FAQ, or contact us to discuss your specific setup.
Official References and Legal Sources
EU-Level Legislation and Policy
Packaging and Packaging Waste Regulation (PPWR)
Regulation (EU) 2025/40 on packaging and packaging waste.
Official Journal of the European Union (EUR-Lex):
https://eur-lex.europa.eu/eli/reg/2025/40/oj
Packaging and Packaging Waste Directive (legacy framework)
Directive 94/62/EC on packaging and packaging waste (as amended).
EUR-Lex consolidated version:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0062-20180704
Waste Framework Directive (EPR minimum requirements)
Directive 2008/98/EC on waste, including Article 8 and 8a on Extended Producer Responsibility.
EUR-Lex consolidated version:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0098-20180705
European Commission – Packaging Waste Policy
European Commission overview of packaging waste legislation and policy developments.
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
Germany – Official Sources
Verpackungsgesetz (Packaging Act)
German Packaging Act (VerpackG).
Federal Ministry for the Environment (BMUV):
https://www.bmuv.de/en/topics/water-resources-waste-soil/waste-management/packaging-waste
Zentrale Stelle Verpackungsregister (ZSVR) – LUCID Register
Official register for producer registration in Germany.
https://www.verpackungsregister.org/en/
France – Official Sources
French Environmental Code – Packaging EPR
Legal basis for French EPR obligations under the Code de l’environnement.
Légifrance (official legal portal):
https://www.legifrance.gouv.fr/codes/texte_lc/LEGITEXT000006074220/
Ademe – EPR and Sorting Information (Triman / Info-tri)
French Environment and Energy Management Agency (ADEME) guidance on Triman marking and sorting instructions.
Deposit Return Systems (DRS)
Overview of national DRS developments and implementation across EU Member States.
European Environment Agency (EEA):
https://www.eea.europa.eu/en/analysis/indicators/waste-recycling-in-europe
Related Product Safety (GPSR) – For Comparison
General Product Safety Regulation (EU) 2023/988
Regulation (EU) 2023/988 on general product safety.
EUR-Lex official text:
https://eur-lex.europa.eu/eli/reg/2023/988/oj
These are official EU and national government sources. Always verify current obligations directly with the relevant national authority or register before placing packaging on the market.