EU packaging EPR: 5 questions compliance teams should be able to answer

By Daniel Vaknine

Packaging extended producer responsibility (EPR) is often treated as a sustainability, waste, or finance issue. For companies selling physical products across the EU, it is also a compliance process: the business needs to know where it has obligations, who owns them, what data supports its reports, and whether the required registrations and EPR arrangements are actually in place.

That matters even more now that the EU’s Packaging and Packaging Waste Regulation (PPWR) generally applies from 12 August 2026. PPWR creates a more harmonised framework for packaging, but it does not create one EU-wide EPR registration or make the practical compliance process identical in every Member State.

For compliance professionals, the useful question is therefore not simply “Who handles packaging?” It is more complex, but can be boiled down to whether the company can answer five basic questions consistently.

1. In which countries are we a packaging producer?

Under PPWR, “producer” does not simply mean the company that manufactured the empty bottle, box, or tray. For EPR purposes, responsibility is connected to the economic operator that first makes the packaging or packaged product available in a Member State.

The European Commission’s PPWR guidance makes an important distinction between the manufacturer of packaging and the producer responsible for EPR. A company can therefore have producer obligations even though somebody else manufactured the packaging itself.

That becomes particularly relevant in cross-border trade. A business established in one EU country that sells packaged products directly to end users in another can become the producer in the destination country. PPWR also requires producers making those cross-border sales to appoint an authorised representative for EPR in the other Member State.

The first control is therefore geographical: Compliance should know where the company sells packaged products, through which legal entity and sales channel, and who has been identified as the producer in each market.

That information should also be part of market-entry decisions. “We sell in the EU” is not sufficiently precise for EPR purposes. Germany, France, and Spain, for example, are three separate markets in which the company may need to establish and document its compliance position, as well as continuously report in different formats.

2. Are registration and EPR arrangements both covered?

PPWR requires producers to register in each Member State where they first make packaging or packaged products available. Producers then fulfil EPR obligations “collectively” through a producer responsibility organisation, or PRO.

The two concepts (registration and PROs) are related, but they are not the same thing. You most likely need both.

A national register identifies producers subject to the rules and provides evidence of registration. A PRO can carry out EPR obligations on behalf of producers, including helping finance or organise collection, sorting, recycling, and other waste-management activities covered by the national system.

The practical arrangements vary. Some markets have a limited number of routes, while others have competing PROs with different packaging scopes, fee structures, and administrative processes. Compliance teams should therefore avoid treating a PRO contract or a registration number as automatic evidence that every applicable obligation has been completed.

Where several PROs are available, it can also be useful to check the published fee structures before selecting one. At Gramta, we maintain a free EU packaging EPR fee calculator and source-linked fee comparison database covering 3,074 published fee records across 123 PROs and schemes in all 27 EU Member States. Used as a research tool, it can help teams understand which schemes exist and how published tariffs differ, as well as which PRO should be chosen in each market.

Ultimately, for each market, compliance should be able to identify the responsible entity, registration number, applicable PRO or compliance route, reporting frequency and internal owner.

3. Can we reproduce the data behind our declarations?

Registration is only the beginning. EPR quickly becomes a recurring data process.

Most packaging declarations ultimately depend on a relatively simple question: how much relevant packaging did the company place on that market during the reporting period?

Answering it reliably can be harder.

A single product may include a glass bottle, plastic closure, paper label, and cardboard sleeve. An e-commerce shipment may add another box, filler, tape, and shipping label. Those packaging components then need to be connected to the number of products sold into each relevant country, and be structured in the format of that specific country.

The source information often sits across several functions. Product or procurement teams may know the material and weight of each packaging component. Sales and finance know how many units were sold and where. Logistics may control additional shipping packaging. Compliance or sustainability may then translate those inputs into the categories required by the local system.

The goal should be one reliable internal packaging dataset rather than rebuilding the numbers shortly before every filing deadline.

A defensible process should also work backwards. If a regulator, PRO, or auditor asks how a reported figure was calculated, the company should be able to trace it back to product specifications, packaging weights, and sales records rather than relying on the memory of the employee who filed the declaration. I have personally seen companies that break EPR regulation by not reporting correctly after a colleague left the company, taking the EPR expertise with them.

4. What happens when the business changes?

One of the easiest ways to miss an EPR obligation is through an ordinary commercial decision. A business opens another country in its online store. A marketplace is added. A new distributor begins selling products. Fulfilment moves to another location. Packaging is redesigned. A new product launches.

Any of these changes can affect the EPR position.

Germany provides a particularly clear example of why EPR should be checked before market entry. Its Central Agency Packaging Register states that commercial online retailers must register with the LUCID Packaging Register regardless of packaging volume. There is no de minimis registration exemption simply because a business is testing the market with a very small number of orders.

The compliance issue therefore arises before the market becomes financially important.

A better control is to connect EPR to processes that already exist. Opening in a new country, changing packaging, or adding a sales channel should trigger an EPR review just as other regulatory requirements would.

That is considerably easier than discovering several months later that products have already been sold into a country without the necessary registration or compliance arrangement.

5. Are marketplaces checking us, or actually acting for us?

Online marketplaces are becoming another EPR control point.

Under PPWR, relevant online platforms must obtain information about producer registration and a self-certification of EPR compliance before allowing producers to offer packaged goods to consumers in the EU. They must also make efforts to assess whether that information is complete and reliable.

For sellers, that means a marketplace asking for an EPR number is increasingly normal. It does not necessarily mean the marketplace has taken over the underlying obligation.

PPWR allows certain obligations to be handled by an online marketplace on the producer’s behalf through a written mandate. The important words are on the producer’s behalf and written mandate.

Compliance teams should therefore distinguish between a platform that verifies evidence of compliance and one that has actually been authorised to fulfil a particular obligation. The same applies when marketplaces offer pay-on-behalf or compliance services: the company needs to know exactly which country, packaging stream, and obligation the service covers.

“Amazon handles it” or “the marketplace asked for our number” is not a sufficient control description.

Make EPR a controlled process, not somebody else’s packaging task

Packaging EPR does not need to become a new legal specialty for every compliance officer. The governance is familiar: identify where obligations arise, assign ownership, maintain reliable data, document the process, and keep evidence that required actions were completed.

The bigger risk is fragmentation inside the company.

Legal assumes sustainability owns it. Sustainability assumes finance pays it. Finance assumes the PRO handles it. Operations opens a new market without knowing any of them needed to be involved.

A simple EPR register can prevent much of that. For each country, record the producer, registration number, PRO or compliance route, authorised representative where required, reporting deadlines, internal owner, and location of supporting evidence.

For teams putting that process together for the first time, a practical EU packaging EPR compliance checklist can help turn the same steps into a repeatable workflow rather than a one-off registration exercise.

Then connect that process to market entry and product changes.

PPWR is making parts of EU packaging regulation more consistent. Packaging EPR still operates through obligations tied to individual national markets. For compliance teams, the job is therefore less about memorising every national rule and more about making sure the company has a repeatable process for identifying those obligations, collecting the right data and proving that they have been handled.

About the author

Daniel Vaknine is Co-Founder of Gramta EPR software and works with businesses managing packaging EPR and PPWR compliance across EU markets.