EPR has been around for a while, but for many e-commerce entrepreneurs it was long an unfamiliar concept. That is changing. Platforms like Amazon are increasingly making it mandatory, legislation is becoming stricter, and the categories it applies to are expanding. But what is the current status of EPR in the e-commerce world? What is changing, and what should you as an entrepreneur be aware of? To answer these questions, we spoke with our own EPR specialist Juul Meijerink, and hear from her what the current state of EPR in the e-commerce world looks like.
EPR is here to stay
Everyone knows VAT. The fact that you need a VAT number as an entrepreneur is so self-evident that it hardly needs explaining. With EPR, that is not yet the case. While the rules have existed for years, many entrepreneurs still do not know exactly what EPR entails, let alone whether it applies to them.
Juul sees this every day. “VAT is a standard, everyone knows it is a thing. EPR does not seem to be there yet, even though you will inevitably come into contact with it.”
Because virtually every product you sell as an e-commerce entrepreneur falls under it. Packaging certainly, but also electronics, batteries and textiles. Anyone placing products on the European market can no longer avoid EPR. But the fact that it cannot be avoided does not mean it is straightforward. Legislation differs per country, and that complexity is a stumbling block for many entrepreneurs.
Where the complexity really lies
Anyone selling across Europe quickly encounters differences between countries. Germany always stands out. With WEEE, the registration for electrical and electronic equipment, it is the only country that requires registration per brand. This brings more work and more costs, and regularly causes confusion among entrepreneurs.
Anyone who does not comply with the rules risks substantial fines. In Germany, these can amount to €100,000. Not a figure to take lightly.
But Germany is not the only country where EPR complexity is high. France has nineteen EPR categories. Juul gives an example: an entrepreneur selling sporting goods, DIY products and textiles can, in France alone, need many different EPR registrations in a single country due to all those categories. That is a significant administrative burden, especially if you are also active in other countries.
Read more about EPR obligations per country on this EPR page.
A common misconception: the supplier is responsible
Alongside the different rules per country, there is another misconception Juul regularly encounters, and it concerns liability. Entrepreneurs who import products sometimes think their supplier bears EPR responsibility. That is not always correct.
The rule is: whoever first places a product on the European market aimed at an end consumer is EPR-liable. If you import products from China and sell them through your own webshop or via Amazon in an EU country, you are the liable party, regardless of where the product originates. It is a mistake that is easily made, but one that can have serious consequences.
New developments: PPWR
Alongside existing rules, new obligations are on the way. The most important development is the PPWR: the Packaging and Packaging Waste Regulation. This European regulation, adopted on 12 February 2025, partially comes into force on 12 August 2026. The PPWR sets concrete requirements for how packaging must look: which materials are permitted, how recyclable it must be, and how it must be labelled.
One of the newer obligations is the declaration of conformity: for every piece of packaging you produce or place on the market, you need one. How this should be arranged in practice is not yet clear. Juul is open about the situation: “the rules are coming, but how to comply with them in practice is still unclear for many parties.” She supports the intention behind the legislation, but the implementation currently lags behind expectations.
Read more about the PPWR and what it means for e-commerce entrepreneurs in this article.
What this means for Amazon Pay on Behalf
The PPWR also has direct consequences for how Amazon handles EPR within its platform. For a long time, sellers could make use of EPR Pay on Behalf, whereby Amazon covered EPR costs for sales made through their platform. Legally, this was a grey area: it was never really intended, but it was tolerated.
Under the PPWR, that is changing. Sellers are now required to have an EPR registration in their own name. Paying via Amazon remains possible, but the registration itself must be in your name. Pay on Behalf thereby ceases to function as a solution for those without their own registration. It is a direct consequence of stricter European rules that prioritise transparency and accountability.
For more on how Amazon Pay on Behalf is changing due to the arrival of the PPWR, read everything in this article.
Europe is not a guaranteed success story
All of this regulation plays out in a market that looks promising but in practice proves more challenging than expected. Anyone successfully selling in the Netherlands quickly thinks: Germany is the logical next step. Same continent, large market, and through Amazon it seems technically straightforward.
Juul regularly sees it play out differently. “Many clients see Europe as: I will just start selling there too. But it still seems that it is not as easy as it sounds. Many people who go to Germany stop after a year.” The market is large and continues to grow, but how different the rules, the administration and the EPR obligations are in another country is something many entrepreneurs underestimate.
Her advice is therefore clear: do your research before you start. Make sure EPR registrations, VAT numbers and other obligations are in order before you make your first sale. Solving problems afterwards is always harder than preventing them.
Do you have questions about EPR for your situation? Juul is happy to think along with you.
