Extended Producer Responsibility (EPR) in Europe


We’ve previously discussed waste legislation in Europe, focusing mainly on Germany with articles about VerpackG and ElektroG. If you sell in Germany and need a refresher on the regulations, we recommend revisiting those pieces. They also cover the mandatory EPR registration needed for Amazon. But did you know that each EU member state has its own EPR system? Together, we’ll explore the world of EPR with several guiding questions.

Where did EPR come from?

Extended Producer Responsibility (EPR) is not a new concept. It originates from EU legislation, specifically the Packaging and Packaging Waste Directive (PPWD). This directive establishes a legal framework for waste management within the European Union, aiming to protect the environment and human health. Since the Directive does not specify how EPR should be implemented by member states, practices differ in the allocation of responsibilities and costs for the collection and sorting of packaging waste among the concerned parties.


What exactly is EPR?

EPR is a policy instrument making producers responsible for their products’ entire lifecycle. This responsibility extends beyond design and production to include the collection, recycling, and final disposal of products. One of the ultimate goals is an economic incentive system encouraging producers to design products easier to reuse or recycle.


Why is this relevant now?

Recent legislative developments have introduced significant requirements to ensure more harmonization and better enforcement of EPR systems throughout the EU. While most, but not all, member states have implemented EPR systems, the PPWD requires all member states to establish EPR systems for packaging by 2024. These developments are particularly pertinent for e-commerce sellers using packaging for their products (in other words: all of us).


What is my declaration based on?

The fees declared and paid by producers/importers are based on the weight (per ton) of packaging material introduced to the market. Again, EPR systems should promote packaging designed, produced, and marketed in a way that supports packaging reuse or high-quality recycling and minimizes environmental impact.


What type of waste are we talking about?

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


What does this mean for me as an e-commerce seller?

E-commerce sellers must register with the appropriate government agency and/or authorized scheme/program, finance the collection, recycling, and recovery of waste. Moreover, you have to provide reports on the quantities of products/materials you introduce to the market. These obligations vary globally, so it’s crucial to investigate the EPR legislation for each country you operate in.


What about the various member states in Europe?

Since the PPWD doesn’t dictate how EPR should be implemented, practices vary by member state. This means responsibilities and costs for collecting and sorting packaging waste differ based on each country’s EPR system. We’re happy to provide a few examples of different EPR practices:


  • In France, all producers creating waste in France must register for packaging waste. You must obtain a UIN number by registering with ADEME. This can be done through a Producer Responsibility Organization (PRO) wh  can be responsible for acquiring the UIN on your behalf. However, you must first provide all company information with supporting documents and the volume of packaging used for the year.
  • In Germany, you’re required to register with the Central Packaging Registry (ZSVR) and, depending on the type of EPR products, register with the appropriate authority to obtain a registration number. There are several category-specific laws like the VerpackG, ElektroG, and BatterieG. There’s also a special register for packaging, the LUCID Packaging Register. All manufacturers and retailers must comply with the new German Packaging Act’s provisions. This makes the regulations applicable to anyone supplying packaging to Germany.
  • In Spain, producers are accountable for packaging. You’re expected to follow these steps:
    • Register for a Spanish NIF tax number if your company doesn’t have one.
    • Join one of the approved Producer Responsibility Organizations (PRO) and obtain a membership certificate.
    • The PRO chosen by your company will assist in registering manufacturers with Spain’s Ministry of Ecological Transition and Demographic Challenge (MITECO), which then issues the EPR number.
    • Make periodic payments to the eco-operator based on their rates and waste volumes (license fee).
    • Submit reports on the amount of packaging introduced to the market each production year.
  • In Slovakia, the packaging law applies to manufacturers and distributors, for importing and packaging or filling products. Here, as a producer, you need to register with the National Register of Mandatory Parties with the help of the Ministry of Environment to receive the registration number (EPR). Producers or distributors must have contracts for take-back schemes and a minimum contract period of two years with Eco-operators. Producers are obliged to provide eco-contributions for the amount determined by the government. Also, a quarterly report must be submitted, including zero reports with the quantities of packaging.

What does the future look like?

With a growing focus on sustainability and a circular economy, EPR schemes are expected to expand and become stricter. This will likely lead to more categories (i.e., products) falling under EPR, higher recycling targets, and more stringent product design requirements in the near future. And since each member state can set up its own system, it will be interesting to see how we, as entrepreneurs, will fare in the future!


Need help?

If you require assistance or simply don’t have the time to research all of this for each country, don’t hesitate to contact Staxxer for tailored advice. Our experts are ready to help you navigate the complex laws and regulations, allowing you to focus on growing your e-commerce business.

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