EU EPR registration and compliance for non-EU brands
Packaging, WEEE and battery obligations fall on whoever places your goods on each EU market. When EuroSOR is your importer and seller of record, EPR runs inside the same setup: registrations, authorised representatives and reporting across the markets you sell into.
In force since 12 August 2026: under the EU Packaging Regulation (PPWR), a producer not established in a member state must appoint an authorised representative for packaging EPR in that state.
- Packaging, WEEE, batteriesEvery stream you ship
- Authorised representativesAppointed where required
- Registration and reportingPer market, on schedule
- One contractAlongside SoR, IOR and VAT
EuroSOR is operated by WareIQ Europe B.V. (KvK 99490536), part of Y Combinator-backed WareIQ.
EPR follows whoever places your goods on the market
The first EPR question is not which number to get. It is who the producer is in each market. That answer decides whose name is on every registration, who needs a local representative and who files the reports.
Selling direct to EU customers (brand ships from outside the EU)
You are the producer in every market.Each registration, representative appointment and report sits in your name, repeated per market and per stream: packaging, WEEE and batteries.
Selling through EuroSOR (EuroSOR is your importer and seller of record)
EuroSOR takes the producer role.Registrations, representative appointments and reports run through EuroSOR's setup. You supply product and packaging data.
What is EU EPR compliance?
Extended Producer Responsibility (EPR) makes the producer of a product pay for, and report on, the waste it creates. The EU sets the framework through the Waste Framework Directive and stream-specific rules for packaging, electrical and electronic equipment and batteries.
For a seller, compliance means four things in every market where it is the producer: register, join the required schemes, report what it placed on the market, and pay the fees.
Official sources: European Commission, Waste Framework Directive; Regulation (EU) 2025/40 (PPWR).
There isn't one EPR registration for all of Europe
EU law sets the rules, but registers and schemes are national, and each stream is registered separately. France alone issues a separate identifier for every stream. This is where the work multiplies.
| Market | Packaging | Electrical and electronic (WEEE) | Batteries |
|---|---|---|---|
| Netherlands | Verpactformerly Afvalfonds Verpakkingen | Stichting OPEN | Stichting OPENvehicle batteries through ARN |
| Germany | LUCID registerplus a dual-system contract | stiftung ear | stiftung earplus a producer responsibility organisation |
| France | IDU via SYDEREP (ADEME)through Citeo, Léko or Adelphe | IDU via SYDEREP (ADEME)through ecosystem or Ecologic | IDU via SYDEREP (ADEME)through Corepile or Screlec |
| Spain | RPP, packaging section (MITECO)plus a collective scheme | RII-AEEquarterly reporting | RII-PyA |
| Italy | CONAI | Registro Nazionale AEE | Registro Pile |
Registers as of September 2026. Producers not established in a market generally act through a local authorised representative; France issues a separate IDU for each stream. These five markets are examples; the same mapping applies in every market you sell into.
What PPWR changes for non-EU sellers
The EU Packaging Regulation replaced the Packaging Directive and applies directly in all 27 member states. For brands selling from outside the EU, three changes matter most.
- Representatives are mandatory
- Since 12 August 2026, Article 45 requires a producer not established in a member state to appoint an authorised representative for EPR in that state. Self-registration from abroad is no longer enough for packaging.
- Germany already enforces it
- Germany now requires foreign companies selling packaged goods directly to German consumers to appoint an authorised representative, on top of the existing LUCID registration. It already required one for electrical equipment and batteries.
- Proof is checked at the listing
- Marketplaces such as Amazon verify EPR registration numbers for the markets you list in. A missing or mismatched number can block sales there until it is fixed.
What does EPR compliance actually involve?
The same five steps repeat in every market. EuroSOR runs them as one sequence across all of your markets rather than as separate projects.
-
Assess
Map markets, channels and products, and establish who places the goods on each market.
Output: producer map per market
-
Classify
Identify the packaging, WEEE and battery streams and the categories each register uses.
Output: stream and category list
-
Register
File registrations, join the required schemes and put representative mandates in place.
Output: registration numbers and mandates
-
Report
Turn sales and packaging data into each market's declarations and settle the fees.
Output: declarations filed, fees paid
-
Maintain
Track renewals, scope changes and marketplace evidence requests as you add markets.
Output: live status per market
What do you need for EPR compliance?
The work is only as good as the data behind it. You provide one dataset; it is mapped to each market's declaration format.
- Product list and categoriesWhat you sell, including any electrical products and batteries.
- Packaging materials and weightsPer product, including shipping packaging you add.
- Sales volumes by marketUnits or weights per country and reporting period.
- Sales channelsOwn store, marketplaces, retail or distributors, per market.
- Existing registrationsAny EPR numbers, scheme memberships or past declarations.
- One data ownerA named contact on your side, so reporting never stalls.
Where businesses get EU EPR compliance wrong
Most problems start before the first form is filed.
Registering before settling who the producer is
Register the wrong entity and you pay fees and file reports for a company that is not the producer, while the real producer stays unregistered.
Treating EPR as one registration
Each market and each stream has its own register, scheme and deadline. Five markets and three streams can mean fifteen registrations.
Leaving representatives until a listing is blocked
Under PPWR, packaging now needs an authorised representative in every market where you are not established. Appointing one after a marketplace suspension costs weeks of sales.
Reading a marketplace check as full compliance
A marketplace confirms that a registration number exists. It does not confirm that every stream you sell is covered in every market.
Underestimating the reporting data
Declarations need packaging weights by material and sales by market and period. Without a clean source dataset, each deadline becomes a scramble.
EU EPR compliance with vs. without EuroSOR
The local obligations exist either way. The difference is whose name is on them and how many providers you manage.
| Area | Selling direct | Through EuroSOR |
|---|---|---|
| Producer in each market | Your company, in every market | EuroSOR, as importer and seller of record |
| Authorised representatives | Appointed and managed by you, one per market | Arranged inside your EuroSOR setup |
| Registrations | Filed per market and per stream in your name | Run through EuroSOR's setup and tracked in one place |
| Reporting | Different formats and deadlines per market | One dataset from you, mapped to each market |
| Marketplace evidence | Found when a listing gets blocked | Registration numbers kept current and on file |
| Adding a market | Another compliance project | An extension of the same setup |
| VAT, customs, product safety | Separate providers for each | Same entity: seller of record, importer of record and responsible person |
EPR is one part of selling in Europe
EPR runs inside the same setup that imports and sells your goods, so customs, VAT, product safety and EPR sit with one provider instead of four.
EU EPR compliance FAQs
What is EU EPR compliance?
Extended Producer Responsibility (EPR) makes the producer of a product pay for, and report on, the waste it creates. In the EU the framework comes from the Waste Framework Directive and stream-specific rules for packaging, electrical and electronic equipment and batteries. In practice, compliance means registering in each market where you are the producer, joining the required schemes, reporting what you place on the market and paying the fees.
Does one EPR registration cover all EU countries?
No. Registers and schemes are run at national level, and each stream is registered separately. A brand selling packaged electronics with batteries into five markets can need up to fifteen registrations, each with its own portal, format and deadline.
Do non-EU sellers need an authorised representative for EPR?
In most cases, yes. Since 12 August 2026 the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40, Article 45) requires a producer that is not established in a member state to appoint an authorised representative for EPR in that state. Germany, France, Spain and Italy already apply the same requirement to electrical equipment and batteries.
Who is the producer when EuroSOR is my importer and seller of record?
The producer is the business that places the goods on each national market. When EuroSOR imports your goods and sells them to your EU customers, EuroSOR takes that role, and the registrations, representative appointments and reports run through EuroSOR's setup. You supply the product, packaging and sales data they are built on.
Which products trigger EPR obligations in Europe?
The main streams are packaging, electrical and electronic equipment (WEEE) and batteries, which covers almost every physical product sold online because almost everything ships in packaging. Some countries add further streams such as textiles, furniture or toys.
Is marketplace EPR compliance the same as legal EPR compliance?
No. Amazon, Bol and other marketplaces ask for registration numbers to meet their own verification duties. Passing that check shows a number exists; it does not confirm that the right entity is registered for every stream and market you sell into.
What information do I need to provide?
A product list with categories, packaging materials and weights per product, sales volumes by market and period, your sales channels and any registrations you already hold. That dataset is mapped to each market's declaration format.
How do I start?
Book an intro meeting and bring your target markets, product list and current registrations. EuroSOR maps the streams and markets that apply and sets out the registrations and representative appointments needed before your next shipment.
Official example of national duties for electrical equipment: Your Europe, WEEE responsibilities for producers. This page describes EuroSOR's service; it is not legal advice for a specific product or market.
Get your EPR setup mapped before your next shipment
A 30-minute intro meeting. Bring your target markets, product list and any registrations you already hold.
- Which streams and markets apply to you
- Where an authorised representative is required
- How EPR fits with your import, VAT and seller of record setup