Was ist EPR? Die erweiterte Herstellerverantwortung (EPR) in Europa

What Is Epr?

We have already talked about waste laws in Europe. In the article about the VerpackG and ElektroG, the focus was mainly on Germany. You sell in Germany but don’t remember exactly how it was? Read articles Then go through them again carefully. We also cover the mandatory EPR registration you need on Amazon in these articles.

But did you know that every EU member state actually has its own EPR system? And what exactly is EPR? We will delve into the EPR with you using a few key questions.

Where does the EPR come from?

Extended producer responsibility (EPR) is not a new concept. It has its origins in EU legislation, namely the Packaging and Packaging Waste Directive (PPWD). This Directive creates a legal framework for the management of waste in the European Union. It is designed to protect the environment and human health . Since the Directive does not specify how the EPR should be implemented by Member States, there are different practices in allocating responsibilities and costs for the collection and sorting of packaging waste between the actors involved.

What exactly is EPR?

The EPR is a policy tool that makes manufacturers responsible for the entire life cycle of their products. They are responsible not only for the design and production, but also for the take-back , recycling and final disposal of the products. The end goal is a system of economic incentives that encourages manufacturers to develop products that are easier to reuse or recycle.

Why is this relevant now?

With recent developments in legislation, important requirements have been introduced to ensure greater harmonisation and better enforcement of EPR schemes across the EU. While currently most, but not all, Member States have EPR schemes in place, the Packaging and Packaging Waste Directive requires all Member States to introduce EPR schemes for packaging by 2024. So these specific developments already apply to sellers who use packaging for their products, making them relevant for e-commerce sellers like you!

What type of waste is it?

The EPR categories cover a wide range of products including batteries, end of life vehicles (ELV), graphic papers, oils, packaging and electronic waste (WEEE).

But what should I do with it as an e-commerce seller?

As an e-commerce vendor, you must register with the relevant government agency and/or an approved program, fund the collection, recycling and recovery of waste, and submit reports on the volumes of product/material you market. These obligations vary around the world, so it is important that you research the EPR laws for each country in which you do business. .

What is my explanation based on?

The fees declared and paid by manufacturers/importers are based on the weight (per tonne) of packaging material placed on the market . Again, EPR schemes should help promote packaging that is designed, manufactured and marketed in a way that encourages the reuse of packaging or high-quality recycling and minimises the impact of packaging and packaging waste on the environment.

What about all the different member states in Europe?

Since the PPWD does not prescribe how the EPR should be implemented, practices vary from one Member State to another. This means that the responsibilities and costs for collecting and sorting packaging waste vary depending on the structure of each country’s EPR system. We would like to give you some examples of different EPR practices:

  • In France, all producers must register for packaging waste if they generate waste in France. You will need a UIN number, which you must apply for from ADEME. Registration is usually done through a producer organization (PRO), which is responsible for obtaining the UIN number on your behalf. However, to do this, you must first provide all the information about the company with supporting documents and the amount of packaging used in the year.
  • In Germany, you must register with the Central Packaging Register (ZSVR) and depending on the type of EPR products. You must also register with the competent authority to obtain a registration number. This is because there are several category-specific laws such as the VerpackG, the ElektroG and the BatterieG. There is also a special register for packaging, the LUCID Packaging Register. All manufacturers and retailers are obliged to comply with the provisions of the new German Packaging Act. The regulations therefore apply to everyone who supplies packaging to Germany.
  • In Spain manufacturers are held responsible for the packaging, then you must go through the following steps:
    • 1. Apply for a Spanish NIF tax number if the company does not already have one.
    • 2. Register with one of the approved Producer Responsibility Organisations (PRO) and receive a membership certificate.
    • 3. The PRO chosen by the company helps manufacturers register with the Spanish Ministry of Environmental Transition and Demographic Challenges (MITECO), which then issues the EPR number.
    • 4. Regular payments to the eco-operator based on its tariffs and waste volumes (license fee).
    • 5. Submission of reports on the quantity of packaging placed on the market for each year of production.
  • In Slovakia , the Packaging Act applies to manufacturers and distributors who import and package or fill products. Here, as a manufacturer, you must register in the national register of obligated parties with the help of the Ministry of the Environment in order to receive the registration number (EPR). Manufacturers or distributors must have take-back system contracts and a minimum contract term of 2 years with eco-operators. Manufacturers are obliged to pay eco-contributions in the amount set by the government. In addition, a quarterly report must be submitted, including a zero report with the packaging quantities.

And what will it look like in the future?

As sustainability and the circular economy become more and more of a focus, it is expected that the EPR regulations will be expanded and tightened. This will likely result in more categories (read: products) falling under the EPR. There is also the possibility that higher recycling targets and stricter product design requirements will apply in the near future. And since each Member State is allowed to set up its own system for this, it will be interesting to see how we as entrepreneurs will soon get involved!


Do you need help with this or do you simply not have the time to sort everything out country by country? Then do not hesitate to contact Staxxer and get personalized advice. Our experts will help you navigate the complex laws and regulations so that you can focus on growing your e-commerce business.

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