EPR abroad in the EU: what online retailers must check

EPR abroad in the EU: every sales constellation counts

Extended producer responsibility (EPR) assigns the obligations for collecting, recovering and documenting a product to whoever first makes it available in a given market as the producer. These obligations include registration, participation in take-back or licensing schemes, volume reports and documentation. They apply per country, not EU-wide.

The EU single market is a market for goods. EPR registration remains organised nationally: each member state runs its own registers, its own schemes and its own rules for authorised representatives. A German registration does not replace a foreign one.

For German online retailers this is not a footnote but the starting point. As soon as a webshop delivers to another member state, a separate sales constellation arises there, with its own assessment. What matters are the target market, the product stream and your own role as the first party to place the goods on the market.

• Packaging: Regulation (EU) 2025/40 (PPWR) entered into force on 11 February 2025 and has applied generally since 12 August 2026.^[1][2] The Verpackungsrecht-Durchführungsgesetz (VerpackDG) of 13 July 2026 implements it in Germany and entered into force on 12 August 2026.^[3][4]
• Electrical equipment: the WEEE Directive 2012/19/EU governs producer responsibility and the registration framework in each member state.^[5]
• Batteries: Regulation (EU) 2023/1542 on batteries governs extended producer responsibility for batteries on its own terms.^[6]

Legal status: September 2026. The following sections set out which checks apply per target market and product stream, and which proofs are valid only within Germany.

Which countries and product areas are affected?

The answer is not a country list, but a matrix. Each combination of target market and product stream is a separate assessment with its own result. The following overview maps the main streams; it does not replace the case-by-case check.

Every cell in this matrix is a separate assessment. An electrical appliance with a built-in battery in packaging triggers three separate tracks in the same target country, with separate registers and separate evidence. Textiles, by contrast, are not a standard case: whether a target country has its own textile EPR scheme is a national scope check, not an operational checklist that can simply be worked through. That gap is closing: Directive (EU) 2025/1892 amending the Waste Framework Directive entered into force on 16 October 2025 and requires every member state to set up an EPR scheme for textiles and footwear within 30 months of that date, so plan for textile obligations in every target market from 2028.^[16]

Which evidence applies only to the German market?

The LUCID registration number applies exclusively to the packaging register LUCID and therefore to the packaging registration obligations in Germany.^[9][7] It is neither a French IDU nor proof of an authorised representative arrangement in Austria. The VerpackDG expressly governs the placing of packaging on the market within Germany; for placing packaging on the market in other countries you receive no registration number from the ZSVR or LUCID, and every EU member state runs its own national packaging register.^[3]

Four separate checks per market

• Registration: entry in the national register of the target country, in Germany in the packaging register LUCID.
• System participation: a contract for licensing or take-back in the respective market, to be assessed separately from registration.
• Data reporting: volumes and periods per register and per system, not once EU-wide.
• Representation: an authorised representative wherever the law of the target country requires one, for example in Austria for foreign distance sellers.

When the role lies with the buyer

Direct sale to end consumers in the target country establishes your own producer role there. Delivery to an independent reseller in the target country can shift the role to that reseller. This allocation does not follow from the invoice. It follows from who actually first places the product on the market in the target country, and it must be clarified before the first delivery, not after.

Four criteria can be checked directly on the transaction:

• The agreed delivery term, e.g. DDP, DAP or EXW.
• The party named as consignee or importer on the customs declaration.
• The time and place at which title passes.
• The location where the goods are stored before they are placed on the market.

If a required registration is missing, the distribution of the affected products in the respective market is regularly restricted: For Germany, § 13 VerpackDG prohibits certain activities relating to packaging when the registration obligations are not met.^[3] Registered producers are also searchable via the public registers of the ZSVR.^[10][11] Whether your constellation triggers a producer role of your own depends on precisely these factors. How your roles are distributed across channels and countries is shown by a structured analysis; for cross-border online retail this is the rule, not the exception. General checklists cannot reliably perform this case-by-case assessment.

How to prioritise your next foreign market

This is an operational recommendation, not a legal duty: Keep an evidence file per target market and product stream. It makes your position verifiable and speeds up every registration that is due.

• Type of buyer: end consumer or independent reseller in the target country.
• Sales channel: own shop, marketplace, or trade via an intermediary.
• Contracts and delivery terms, including the agreed Incoterms.
• Product and material data per product stream, including packaging types.
• Existing registrations and their numbers per register.
• Authorised representative mandate, where the target country requires one.
• The person responsible for reporting in the company, with deadlines per register.

Prioritise by the first relevant delivery and by volume relevance, not by a country list. The market with the next planned revenue comes first, not the one with the longest country profile.

Two markets merit a closer look in their own right: In France, every producer has been required to hold its own identification number (IDU) per EPR scheme since 1 January 2022, issued by the ADEME.^[12][13] In Austria, foreign distance sellers delivering to private end consumers without a seat or establishment have been required to appoint an authorised representative since 1 January 2023.^[8][14] Dedicated in-depth articles follow on both markets.

Outlook: What the PPWR harmonises

Regulation (EU) 2025/40 (PPWR) has been in force since 11 February 2025 and applies generally since 12 August 2026; the VerpackDG implements it in Germany.^[1][4][15] It harmonises requirements for packaging and for producer responsibility EU-wide, replacing the former Packaging Directive as the legal basis.

It does not create a single EU registration. Articles 44 and 45 of the PPWR provide for national producer registers and authorised representatives with their own conditions and deadlines.^[15] Later implementing measures are still outstanding; their conditions and deadlines are open and provisional. Whether and how contributions will change in the future is likewise not yet quantified.

What applies in your case is decided by your own role and supply chain: who delivers where, to whom, under which delivery terms and in which product stream. These distinctions cannot reliably be resolved through a general checklist alone. To clarify which obligations apply to your constellation, request a consultation with ClearoSystems. Bring the relevant product and supply chain data with you: sales countries, product streams, buyer types and existing registrations.

Frequently asked questions about EPR in EU sales

Does my LUCID registration also apply in other EU countries?

No, its scope ends at the German border. It also covers packaging law only: for other German registers, such as the Elektro-Altgeräte Register (EAR) or the single-use plastics fund platform DIVID, a separate registration is required in each case, which does not take place via the ZSVR.

Which product areas must I check per target country?

Packaging, electrical equipment and batteries, each assessed separately. Each stream has its own registers, its own reporting formats and its own representation rules in the target country. Check textiles additionally where a national textile EPR scheme already exists; Directive (EU) 2025/1892 makes such a scheme mandatory in every member state within 30 months of 16 October 2025, so that scope check per country will shortly become a standing obligation.

Does a foreign buyer as the acquirer change my EPR role?

It can. What matters is who actually places the product on the market in the target country for the first time. If your webshop delivers directly to end consumers, you hold the role yourself. If you deliver to an independent reseller, the role can pass to them. Check the delivery terms, the named acquirer, the transfer of ownership and the storage location, and never derive responsibility from an invoice alone.