Do you need an EPR number to sell on TikTok Shop in 2026?

Oskar Mortensen Oskar Mortensen
10 min read

TikTok Shop asks you for an EPR registration number in thirteen EU markets, and it does two very different things when you have not got one. Below is what the platform asks for market by market, where each number comes from, what its Pay on Behalf fee covers, and what stays yours whatever you pay.

A hand holding a phone with the TikTok Shop logo on its screen

Yes. Sell into the EU on TikTok Shop and you need an EPR number for the country your buyer is in, and TikTok asks you for it by name.

What makes TikTok different from the other marketplaces is what happens when you have not got one. In France, Spain and Italy it starts paying your eco-contribution for you and takes a percentage of every in-scope order. In its other ten markets the listing simply comes down.

What has to line up before TikTok will accept a number

TikTok validates every number you submit, and one mismatch is enough to leave it sitting there unaccepted. Five things are worth getting straight first.

  1. Your legal entity name, exactly as TikTok holds it. TikTok repeats the same condition on every market page, that the EPR registration legal entity must match the company name used on its platform before the number can be validated. Register in the name your shop trades under on TikTok, not a holding company.
  2. The countries your orders actually reach. Not the countries you advertise in. Anywhere an order has shipped counts, because the duty attaches to the country the buyer is in.
  3. What your products are and what is inside them. A lip balm, a phone case and a battery-powered ring light fall into different categories, and each category is a separate registration.
  4. Your packaging weights, split by material. The mailer, the box, the tissue and the tape are all packaging you put on the market, whatever was inside them.
  5. Your supplier's legal name, VAT number and registration number, if you resell someone else's brand rather than your own. TikTok asks for all three.

The two things TikTok does when a number is missing

TikTok publishes EPR requirements for thirteen EU markets, which is more than any other marketplace we have looked at. What it does about a missing number is not the same in all thirteen, and that is the part worth understanding before you start.

In ten of them a listing without a number comes down, and the delisting is logged in your violation records until you supply one. In France, Spain and Italy nothing comes down. TikTok enrols the listing in its own Pay on Behalf service instead and starts charging you for it.

The thirteen are not the whole EU, though, and the gap matters. There are twenty-seven member states, so fourteen of them get no EPR section from TikTok at all. Your duty in those fourteen is exactly the same as anywhere else.

Where your buyer is What it asks about If you have no number
France, Spain and Italy Packaging, batteries, and eight more in France Your listings go into Pay on Behalf and a fee comes off each in-scope order
Germany Packaging, batteries, electronics, single-use plastics The listing is delisted and it lands in your violation records
Austria, Belgium, the Czech Republic, Greece, Hungary, Ireland, the Netherlands, Poland and Portugal Packaging and batteries, plus electronics in Belgium The same delisting, reversed once a valid number is approved
The other fourteen EU countries Nothing, TikTok publishes no EPR section for them Nobody asks you for a number, and Article 44(4) still bars you from selling there without one

Pay on Behalf is TikTok's own service, and enrolment into it is automatic rather than something you sign up for. TikTok's wording is that a seller who lists an in-scope item is enrolled unless they provide information showing they already comply.

Once you are in it, TikTok reports your sales to the scheme and pays the eco-contribution, and it deducts a percentage of each completed order from your selling account.

None of that is TikTok being unusually pushy. Since 12 August 2026 the EU packaging regulation has required this of platforms.

Article 45(4) says a platform must collect a producer's registration number for the country the consumer is in, plus a self-certification, before letting that producer use its services.

The same article lets a platform take on the producer's financial contributions under a written mandate. That is exactly what Pay on Behalf is, and it stops there.

How to get your own numbers accepted step by step

The work goes one market at a time, and the order matters, because a number you cannot get validated is worth no more than no number at all.

Step 1. Work out which markets and categories put you in scope

Open your order history for the last full calendar year and write down every country an order has shipped to. Under Article 44(2) the duty lands in each member state where you make packaging available for the first time, so the shipment is the trigger and not the listing.

Then count categories rather than countries. TikTok asks about ten in France, four in Germany and two in most of the rest, so the same catalogue produces a very different number of registrations depending on where it sells.

How many EPR categories TikTok asks about per market, ten in France, four in Germany and two in eleven other markets

One caveat that TikTok itself prints on every market page, and it matters. These are the categories TikTok asks about, not the full legal scope of the market.

A category TikTok never raises is still a category you can owe. Work from the market's own register rather than treating the platform's list as the boundary.

Step 2. Decide whether you are the producer or the reseller

TikTok documents two routes to filling the same field, and they need different paperwork. You count as the producer in any of four cases.

  1. You sell under your own name or trademark.
  2. You resell without the manufacturer's name on the product.
  3. You are the first to supply the product in that market.
  4. You sell into the market by distance contract from outside it.

If none of that describes you, TikTok lets you lean on your supplier instead. You collect their registration number, their legal name and their VAT number, upload all three, and tick the declaration saying you are not the producer.

The producer route submits your own registration number, the reseller route submits a supplier number with their legal name and VAT number plus a self-declaration

Read TikTok's own warning on that second route before you take it. It says that distance sellers increasingly become responsible in the country where the product is sold, so a supplier's number may not always be enough to show that you comply.

Step 3. Register in each market and collect the number

Work down your market and category grid one cell at a time, because each cell is its own application. Some markets register you through a government body, some through a scheme, and some through both.

Give it real time. Under Article 44(11) the authority has up to twelve weeks to grant the registration and issue the number, and the clock only starts once your file is complete.

Who issues the number, and whether you need someone local to carry the duty with you, changes from market to market.

Market Who issues the number Representative needed
Germany LUCID, run by the ZSVR Only for some categories
France ADEME, issued through SYDEREP Possibly, TikTok says it can be
Spain MITECO Yes
Italy CONAI or your scheme Yes
Ireland Repak, with batteries verified through PRL Yes
Poland BDO Yes

The other seven markets follow the same pattern through their own bodies, and our directory of national EPR registers covers them. TikTok words the representative as a firm requirement in all seven.

Where one is needed, sort it before you apply rather than after. Article 45(3) requires the appointment to be made by written mandate, and our guide to appointing an EU authorised representative covers what that mandate has to say.

What comes back is not the same shape everywhere, which is worth knowing before you paste it into a form. Germany issues a code beginning DE, France one in two halves, and Spain one that opens with ENV and the year. Ireland and Italy hand over a plain scheme membership number instead.

Belgium is the outlier. No code is issued there at all, so your company name and VAT number is what goes in the field, and a producer of both household and professional packaging registers twice.

Step 4. Submit it under the same legal entity and wait for validation

The numbers go into the Qualification Center, and TikTok publishes the path itself. Go to My Account, then Account settings, then Qualification Center, then Extended Producer Responsibility. Battery numbers have their own tool there, the Qualification Center for Batteries.

Submitted is not the same as accepted. TikTok holds the submission in a Submitted state until it validates, and says that because authorities typically refresh their registers weekly, validation takes five working days or longer.

Two paper records side by side, each with its name line marked, joined by a tick, showing that the shop and the registration must name one legal entity

The legal entity match is what fails most often, and it is worth checking twice rather than waiting a week to find out. If a number is rejected, TikTok's instruction is to edit it in place in Seller Center rather than start again.

Weekends do not count towards that wait either, so a number submitted late in the week is a number you are still waiting on the following week.

A week of day cells with the five weekdays filled and the weekend left empty, showing the five working days TikTok takes at least

Step 5. Choose between Pay on Behalf and your own registration

Pay on Behalf is only available in France, Italy and Spain, and TikTok charges for it as a percentage of the order rather than as a fee per filing.

Its published 2025 rates run from 0.49% for French packaging and paper up to 1.65% for Italian batteries, with a minimum of one cent per in-scope order.

The 2025 Pay on Behalf rates TikTok Shop publishes, charged as a percentage of each in-scope order

Leaving the service is where sellers get caught. TikTok says you can opt out at any time, but that opting out requires you to either submit a valid registration number or delist every in-scope item, and that it keeps providing and charging for the service until you do one of the two.

There is no third option in two of those markets. TikTok states plainly that a seller who tells it they do not want Pay on Behalf and has no registration number of their own will not be able to sell in-scope products on TikTok Shop France or Spain.

Step 6. Keep the numbers valid as your catalogue changes

A registration is a live record, not a certificate. Article 44(12) requires you to tell the register about any change to it without undue delay, and a change to your catalogue can quietly put you outside what you registered for.

Three changes that turn a valid registration into an invalid one, a new category, a new brand and a change of legal entity

Adding one battery-powered product to a German shop is the clearest example. It pulls you into two categories you may never have registered for, and German battery registration runs per brand, so a second brand of the same product needs its own entry.

Nothing in Seller Center tells you when your own catalogue has crossed that line.

Where Repax fits for a TikTok Shop seller

Step 3 is where this stops being form filling. Every register wants the weight of each packaging material you placed on its market over its own reporting year, grouped its own way, and that calculation comes back every year for every market you registered in.

Repax Core is built for that part. It reads your product and order data, holds materials and weights once so a change updates every product built from them, and produces the figures each market asks for from one dataset.

Each shipped order locks in the specification that was current at the time, so a filing can be reproduced years later.

Explore Repax Core See how your product and order data becomes the figures each register asks for

Core prepares the data behind a filing. It does not submit to a register, it does not obtain your registration number, and it does not type anything into the Qualification Center. Repax Comply will cover the filing itself and is not live yet.

What Pay on Behalf does not cover

The service is narrower than its name suggests, and TikTok is clear about the edges. These are the six things it leaves with you.

  1. The registration itself. Article 45(4) lets a platform meet the producer's financial contributions under written mandate. Registration sits in Article 44, which is not covered, and Article 44(4) says you must not make packaging available in a market where you are not registered.
  2. Labelling and marking. TikTok lists both as outside the service.
  3. Take-back and the other organisational duties, including prevention and eco-design work. Also outside it.
  4. The Spanish invoice line. TikTok says the seller is responsible for showing the packaging EPR number on the invoice to Spanish consumers, and that an enrolled seller has to ask TikTok for the number to do it.
  5. Everywhere except France, Italy and Spain. In TikTok's other ten markets there is no fee route, so a missing number is a delisting rather than a charge.
  6. A fixed price. TikTok reserves the right to change both the rate and the fee structure at any time, effective immediately on posting, and to apply changes retrospectively.

Frequently asked questions about EPR numbers on TikTok Shop

Short answers to what TikTok Shop sellers ask most often.

How long does it take to get an EPR number?

Article 44(11) gives the authority up to twelve weeks to grant the registration and issue your number, counted from when you have supplied everything it asked for. TikTok then takes five working days or longer to validate it.

Does TikTok Shop register on your behalf?

No. Pay on Behalf reports your sales to the scheme and pays the eco-contribution, which the regulation allows a platform to do under a written mandate. The registration itself stays personally yours in every market.

Am I too small to need a registration?

Probably not. Under ten tonnes of packaging a year gives you a reduced reporting set under Article 44(8) rather than an exemption from registering, and a member state is allowed to set that threshold lower.

Is this the same as Amazon's EPR checks?

The starting point is the same, since both platforms have to collect a number for the country the buyer is in. TikTok adds the automatic fee route in three markets, which Amazon does not.

What happens if the number I submit is rejected?

Edit it in place in Seller Center rather than submitting a second one. The usual cause is that the company name on the registration is not the company name on your shop, which TikTok will not validate around.

Written by

Content specialist at Repax.io

I translate sustainability regulations by day, chase golf balls by evening. Both involve more rules than anyone admits.