Understanding Extended Producer Responsibility (EPR)
Under Extended Producer Responsibility (EPR), responsibility for a product extends beyond the point of sale to the end-of-life stage. It includes obligations relating to the collection, recycling and reporting of waste streams such as packaging, electrical and electronic equipment, and batteries. These obligations arise from EU and national legislation, including the Packaging and Packaging Waste Regulation (PPWR), and are becoming an increasingly important condition for accessing European markets.
If you place products or packaging on the EU or UK market, EPR may be one of the fundamental compliance requirements for your business, particularly if you operate in e-commerce.
EFF helps your company manage its EPR obligations alongside VAT compliance, ensuring a coordinated approach to regulatory requirements across different markets.
Our experts help you determine when EPR obligations apply, which products and packaging are covered in each country, and what action you need to take to meet registration, reporting, collection and recycling requirements. This helps you maintain compliance, reduce the risk of administrative penalties and sales restrictions, and expand your operations with confidence—without environmental requirements becoming an obstacle to business growth.
EPR in e-commerce and international sales
If you sell online or operate across several markets, EPR obligations can quickly become complex. National rules differ, definitions of a “producer” vary, and online marketplaces may impose their own verification requirements. This can result in compliance errors and delays to your sales.
We help you manage this complexity by identifying the countries in which registration is required, explaining how to meet marketplace requirements, and supporting EPR compliance for cross-border sales in both B2B and B2C models.
You gain greater control over compliance without having to monitor every local regulatory framework yourself, allowing you to focus on growing your business rather than dealing with administrative formalities.
What does this mean for online sellers?
Depending on the product category, waste stream and applicable national rules, countries including Germany, France, Spain, Italy, Austria, Poland and Sweden—as well as the United Kingdom under its separate regulatory framework—may require EPR registration before products can be sold.
In many cases, the seller may be treated as the producer for EPR purposes. Online marketplaces are therefore increasingly verifying sellers’ compliance and may block product listings or suspend accounts where the applicable requirements have not been met.
Businesses selling into an EU Member State in which they are not established may also be required to appoint an authorised representative for EPR in that country. The precise requirement depends on the applicable legislation, EPR scheme and product category.
At EU level, Regulation (EU) 2025/40 on packaging and packaging waste, known as the Packaging and Packaging Waste Regulation (PPWR), introduces new obligations for producers, sellers and importers. These include more stringent requirements relating to registration, packaging design and reporting in cross-border sales.
As an EU regulation, the PPWR will apply directly across the European Union and will be enforced by the relevant national authorities.
Learn more: PPWR 2026: what obligations will e-commerce companies face from 12 August?
