EPR – extended producer responsibility: which obligations, registrations and numbers you need

At a glance

What does EPR mean?

Under EU law, extended producer responsibility is a set of measures taken by the state. It ensures that producers bear the financial, or also the organisational, responsibility for their products in the waste stage^[1]. This page is therefore about waste law, not the reactor type of the same name or a medical term.

Under Art. 8a of the Waste Framework Directive, producers' contributions cover the separate collection, transport and treatment of waste, consumer information and data gathering^[1]. Where obligations are fulfilled collectively, contributions are to be modulated according to properties such as durability, reparability, recyclability and hazardous substances; this is called eco-modulation^[1].

In most EU EPR schemes, compliance comprises three core elements:

• Registration: entry in the national producer register before the product is first made available^[2][3][4].
• Financing: participation in a compliance scheme or a producer responsibility organisation that organises collection and recovery, or an approved individual solution^[9][21].
• Reporting: regular statements of the volumes you have made available in the country^[10][17].

Which products fall under EPR?

EPR does not apply to all goods, only to defined product streams. The following matrix shows the four main streams for Germany and the markets Austria, the Netherlands and Switzerland; it is a selection, not an overview of all EU countries.

In Germany, the single-use plastics fund (Einwegkunststofffonds) applies in addition to certain single-use plastic products: producers register on the Federal Environment Agency's DIVID platform and pay an annual levy^[25]. A plastic packaging item alone does not trigger this obligation; the product list of the Single-Use Plastics Fund Act is decisive.

The details for each stream are in separate guides: PPWR, German Packaging Act and VerpackDG, LUCID packaging register, ElektroG and WEEE number.

Who is a producer under EPR?

EPR obligations apply to the producer as defined by the relevant law. This is often not the company that makes the product, but whoever first makes a product available in a country^[2][14]. Each legal act has its own definitions. The PPWR distinguishes the manufacturer, who makes a packaging item or has it made under its own name or trademark, from the producer, who bears the EPR obligations in a specific country^[2]. The ElektroG explicitly counts importers and foreign online sellers as producers^[14].

Which case applies to you?

• Own brand or own production: you are the producer, for the equipment under § 3 No. 9 ElektroG and for the packaging insofar as you first make it available in the country^[2][14].
• Import from a third country or another EU country: whoever first offers the goods in Germany is the producer of electrical equipment^[14]. For packaging, what matters is who first makes it available in Germany^[2].
• Direct sales from abroad to end customers: you are the producer in the destination country and usually need an authorised representative there^[7][16][22].
• Resale of registered goods: if your supplier has already placed the equipment on the market in Germany as producer, you are its distributor, not its producer^[14]. For shipping boxes and filling material that you fill yourself, you may still have your own packaging obligations^[2].
• Marketplace and fulfilment: these service providers are not automatically producers. However, they must not act for producers that are not registered^[11][15][19].

Delivery terms, invoice or storage location are indications, not a decision. Document your role with supply contracts, brand details and customs documents.

EPR obligations in Germany at a glance

Sales, outer and service packaging is subject to system participation, as is packaging that typically becomes waste in private households or comparable places of generation such as restaurants, offices or craft businesses^[47]. What matters is therefore the typical place where waste arises, not whether your customer is a business. Registration and system participation are two different steps. Having a contract with a compliance scheme for packaging does not mean you are registered in LUCID, and vice versa^[8][9]. The guide packaging licence explains what the colloquial term means.

EPR number: which numbers exist per country and stream

"EPR number" is not a legal term. It refers to the registration number issued by the relevant national register. Under the PPWR, the register authority issues the number no later than twelve weeks after a complete application, and the list of registered producers must be public, free of charge and searchable^[2].

Marketplaces ask for these numbers because the law requires them to. Under Art. 45(4) PPWR, online platforms must obtain the registration number in the consumer's country and a self-certification before activating an offer^[2]. For Germany, the ZSVR provides an automated data match for this^[11]. If EPR data is missing or invalid, Amazon may restrict or remove listings^[31].

Depending on the area, resellers submit the number of their registered supplier instead of applying for their own. Our article Which EPR proof do I need for Amazon.de? shows which proof Amazon.de requires in detail.

Authorised representative: when you need a representative in the destination country

An authorised representative for extended producer responsibility is a person or company established in the destination country. It fulfils the EPR obligations of a foreign producer in its own name^[7][22]. In Germany, each producer may appoint only one authorised representative per area, in writing and in German^[7][16][22]. For packaging, the LUCID registration nevertheless remains with the producer itself^[27].

The obligation follows from EU law and national law. The PPWR requires an authorised representative from producers that deliver directly to end users in another member state; for third-country producers, member states may require one^[2]. Germany has implemented both^[7]. The Batteries Regulation requires one from distance sellers in every member state^[3]. In Austria, foreign distance sellers must appoint an authorised representative for packaging and electrical equipment^[33][34].

A proposal, not law in force: on 10 December 2025 the Commission proposed a postponement. Under it, the authorised representative obligation under Art. 45(3) PPWR and Art. 56(3) of the Batteries Regulation would be suspended for producers established in the EU until 1 January 2035^[45]. The responsible committee of the European Parliament voted on 5 October 2026; as of 15 October 2026 the proposal has not been adopted^[44]. Until it is adopted, the obligation applies. Whether Germany will then amend § 5 VerpackDG and § 40 BattDG is open. The appointment of an authorised representative under § 8 ElektroG is not covered by the proposal^[45].

The article EPR authorised representative: costs per EU country explains what the costs of an authorised representative depend on. EPR obligations in other EU countries shows which checks are due per destination country.

What does EPR cost?

EPR costs consist of three layers, which you plan separately:

• Official fees: LUCID registration is free of charge^[26], as is EDM registration in Austria including the GLN^[35]. For electrical equipment, stiftung ear charges €9.50 per brand and equipment type and €32.80 per quarter^[30]. For batteries, it is €16.40 per brand and category and €3.80 per quarter^[30].
• Contributions to compliance schemes and organisations: for packaging, they depend on material type and mass^[9]. EU law requires contributions to be modulated, where possible, according to the environmental properties of the products^[1]. For packaging, under the PPWR they additionally cover the labelling of collection containers and waste composition surveys^[2]. In the Netherlands, the Afvalbeheersbijdrage is charged via Verpact^[37]; in Switzerland, the advance recycling fee is included in the purchase price^[41].
• Services: authorised representative, reporting service and data maintenance are charged according to quotation; internal effort comes on top.

The providers set the level of compliance scheme fees; there is no official uniform price. The guide packaging licence shows how to compare quotations for packaging.

Deadlines and timeline

In Austria, the single-use deposit belongs to the deposit system, not to licensing; details in the guide Austria's deposit return scheme.

Consequences of missing registration

Without registration, producers may not sell in Germany. Depending on the area, the ban also covers distributors, marketplaces and fulfilment service providers^[11][15][19]. For packaging, the following also applies: packaging subject to system participation may not be made available without system participation^[11].

Missing registration, missing system participation and making products available despite a ban are administrative offences under § 66 VerpackDG, § 45 ElektroG and § 60 BattDG^[12][18][23]. In practice, a gap usually shows up first on the marketplace, when the number is missing or does not match the goods^[31].

Common mistakes

• Assuming home registration is enough: each country keeps its own registers; register wherever you are a producer^[2].
• Checking only the packaging: for devices with a rechargeable battery, electrical and battery registration are added^[15][20].
• Confusing registration with a compliance scheme contract: in Germany, the LUCID entry and system participation are two obligations^[8][9].
• Using someone else's number despite your own brand: whoever offers equipment under their own brand is the producer^[14].
• Overlooking the authorised representative obligation: since 12 August 2026, companies without a German establishment that deliver directly to end users also need an authorised representative for packaging^[27].
• Treating a proposal as law in force: the planned suspension of the authorised representative obligation has not been adopted^[44].

For companies from the Netherlands, Austria and Switzerland

Your registrations in your home country do not apply to Germany. Verpact and Stichting OPEN cover products first placed on the market in the Netherlands^[37][39]; for Germany, the German registers apply. If you deliver directly to end customers in Germany, you are the producer there: you register in LUCID, participate in a German compliance scheme and appoint an authorised representative^[8][9][27]. For electrical equipment and batteries, the authorised representative registers with stiftung ear on your behalf^[16][22].

• Netherlands: also check the UPV Textiel if you sell clothing or household textiles^[40].
• Austria: for your home market, registration and reports run via the EDM portal^[35]; for beverages, the single-use deposit applies^[36]. The article Selling to Austria answers whether the German licence is sufficient for Austria.
• Switzerland: as a producer from a third country, you must appoint an authorised representative in Germany before first making packaging available^[7]. The suspension proposal leaves the rules for third-country producers unchanged^[45]. At home, the industry solutions of Swico and SENS apply^[41].

Status and changes

As of 16 October 2026. We checked the Waste Framework Directive, PPWR, Batteries Regulation, WEEE Directive and Textiles Amending Directive on EUR-Lex, and the VerpackDG, ElektroG, BattDG and fee ordinance on gesetze-im-internet.de. We also checked the pages of the ZSVR, stiftung ear, UBA, BMLUK, Unternehmensserviceportal, Verpact, Stichting OPEN, Rijkswaterstaat and BAFU, and the procedural status of omnibus proposal 2025/0395(COD). We will review the page again after the plenary vote on this proposal and as soon as Germany presents a draft law on textile EPR. Changes: 15 October 2026, first version; 16 October 2026, technical clarifications after expert review (obligation areas, authorised representative for batteries in Austria). In the digital needs analysis, ClearoSystems checks every combination of product, role, channel and country and then takes over registration, reports and the appointment of an authorised representative. Translated from the German version of 16 October 2026.

Frequently asked questions

Where can I find my EPR number?

In the confirmation from the relevant register: the ZSVR shows the LUCID number directly after registration is completed, and the WEEE and battery registration numbers are in the notice from stiftung ear. Registered producers can also be looked up in the public registers. You have a separate number for each country and each product area, not one EU-wide number.

Does EPR also apply to small businesses?

Yes. In Germany, there is no minimum quantity for registering packaging, electrical equipment and batteries. Relief applies to individual steps: below 10 tonnes of packaging subject to system participation in the previous year, an annual data report is sufficient, and stiftung ear can reduce individual fees on application. Textile EPR applies to micro-enterprises one year later, from 17 April 2029.

How are the PPWR and EPR related?

The PPWR contains the EPR rules for packaging: producer register, financing, authorised representatives and the verification duties of marketplaces. It also sets requirements for the packaging itself, such as recyclability and labelling. The registers remain national; in Germany, the VerpackDG enforces the PPWR.

Do I need a separate registration in every EU country?

In every country in which you count as a producer, which is usually where you deliver directly to end customers. If you sell to a retailer in the destination country who first makes the goods available there, the obligation may lie with that retailer. There is no single EU registration; the national registers only link to one another.

What applies if I only sell to businesses?

Registration remains mandatory. For packaging, system participation does not depend on the buyer but on where packaging of the same type typically becomes waste; restaurants, offices and craft businesses are treated like private households. For packaging outside system participation, take-back obligations apply and, from 1 January 2028, approval by the ZSVR or transfer to an approved organisation. For electrical equipment, credible demonstration and a take-back concept replace the guarantee.

My supplier is registered. Do I still have to do anything?

Yes, you document its registration number for the goods you purchase and submit it to marketplaces. For shipping boxes, filling material and labels that you use yourself, check your own packaging obligations. If you sell goods under your own brand, you are usually the producer yourself.