EPR probably landed on your desk without you asking for it. If you are the operations or finance person now responsible for it, this guide is for you.
By the end you will know what getting started with Extended Producer Responsibility (EPR) involves in Europe: the six steps from "we think this applies to us" to a registration that holds up.
There is no single EU-wide sign-up. EPR is set at EU level but run by each country, so you register, report and pay separately in every market you sell into.
The shape of the work is the same everywhere. The exact registers, thresholds and deadlines differ by country. This guide is Europe-first, and where a detail is country-specific we point you to the country guides.
What you need before you start
You do not need much to begin, but three things make every later step faster. Gather them first.
- Your markets and products. The countries you sell into and the product types you sell in each. That is what decides your obligations.
- Your product data. What each product and its packaging is made of, and what it weighs. Every scheme bills and reports on weight and material.
- Your company details. Legal name, address, and tax or VAT number. Every national register asks for these.
If your product data is scattered across spreadsheets and suppliers, pulling it together is the slowest part. Start there.
1. Work out where EPR applies to you
List two things: the countries you sell into, and what your products are made of or contain.
EPR is triggered when you place certain product types on a national market, under EU rules like the Waste Framework Directive. Sell packaged goods in Germany and France, and you have a packaging obligation in both. Sell electronics into Spain, and you pick up an electronics obligation there too.
Do this even for markets where you sell only a little. Most schemes have a low threshold or none, and online sales count.
You are done when you have a simple grid: each country against each product type that might carry a duty. The country guides show what each market expects.
2. Identify your waste streams
A waste stream is the category the rules sort your product into. It decides which scheme you join and what you report.
The common ones in Europe are packaging, electrical and electronic equipment (WEEE), and batteries. Textiles is being added across the EU, with schemes due by 2028. Others include single-use plastics and tyres.
One product can sit in several streams at once. A cordless drill in a printed box is packaging, electronics and batteries: three obligations from one item.
You are done when every product is mapped to its stream or streams, in every market.
3. Register in every market you sell into
Registration puts you on the authorities' books, and in most countries it happens before your first sale, not after.
Each country runs its own producer register. In Germany, packaging goes in LUCID, run by the Zentrale Stelle Verpackungsregister, while electricals and batteries go through stiftung ear. In France you apply to the agency ADEME for a unique identifier, one per stream.
The names change per country. The idea does not. Register per stream, per country, so selling packaged electronics into two countries can mean four or five registrations.
You are done when you hold a valid registration, and any number the country issues, for every stream in every market, dated before you sell there.
4. Appoint an authorised representative where the country asks for one
If your company is not established in a country you sell into, that country may require an authorised representative based there to carry your EPR duties.
This mainly affects online and cross-border sellers. Germany, for example, does not let a foreign company register itself for electricals or batteries. From 12 August 2026, the new EU packaging rules extend the same idea to packaging.
You are done when, for each market where you are a foreign seller, you have confirmed no representative is needed or appointed one.
5. Join a scheme and report what you place on the market
In almost every country you meet the obligation by joining a producer responsibility organisation (a PRO), the collective scheme that handles collection and recycling for you.
You sign up with the PRO for each stream, then report what you place on the market, by weight and material. For packaging, that is the tonnes of paper, plastic, glass and so on you put out.
Reporting is periodic, often yearly, and it has to match what you actually sold.
This is where clean product data pays off. Know what each product weighs and is made of, and the report is arithmetic. Guess, and it is guesswork.
You are done when you are a member of the right scheme in each market and have filed your first volume report.
6. Pay your fees and keep the registration current
EPR fees are what you pay the scheme to handle your waste, and they are increasingly tied to how recyclable your product is.
Under EU rules those fees are eco-modulated: easy-to-recycle products cost less than hard-to-recycle ones, so better packaging lowers the bill.
Getting started is not a one-off. Registrations stay current, volumes are reported each period, and the rules move. The biggest near-term change is the EU Packaging and Packaging Waste Regulation (PPWR), whose main obligations apply from 12 August 2026.
You are done with the setup when fees are paid and you have a calendar note for the next deadline in each market.
Common mistakes when getting started
A few traps catch almost everyone new to EPR.
- Assuming there is one EU registration. There isn't. Every country is its own sign-up.
- Registering after the first sale. Most countries want registration before you place a product on the market, and selling without it can mean fines and a ban. In Germany, packaging fines reach €200,000.
- Forgetting that online sales count. Selling in from abroad triggers the same duties, and marketplaces increasingly check you are registered.
- Mapping only the obvious stream. The box around an electronic product is its own packaging obligation, on top of the electronics one.
- Ignoring the eco-modulation discount. Easy-to-recycle packaging pays less, so a product nobody reviews can quietly cost more.
How Repax fits
Repax is a software platform built for EPR compliance. The work splits in two, knowing your products and filing in each market, and Repax covers both halves.
By hand, that is a sprawling materials spreadsheet on one side, and a separate login and deadline per country on the other.
- Repax Core, for the data half. Spec each product once (materials, weights, components), and Core turns it into whatever report a scheme asks for. That is the clean data step 5 runs on.
- Repax Comply, for the filing half. Registering and submitting across markets. On the way, with a waitlist open.
- Repax Declare, for the EU packaging Declaration of Conformity specifically.
Repax does not make you compliant on its own. It does the data and filing work that otherwise owns your calendar.
Pricing is public: a free tier at €0 a month, paid plans from €29 a month, and a custom tier for high volume (as of July 2026). If you are weighing tools, our best EPR software rundown compares the main options, Repax included.
Common questions about getting started with EPR
Short, self-contained answers to the questions producers ask most.
How long does it take to get started with EPR?
It varies. A single country and one stream can be quick once your data is ready. Several markets and streams take longer, because each registration is separate. The slow part is usually gathering the product data.
Is there one EU-wide EPR registration?
No. EPR is set at EU level but run country by country. You register, report and pay separately in every country where you place products on the market.
Does the manufacturer or the seller register for EPR?
Whoever first places the product on a market. That can be the manufacturer, the importer, or a brand selling under its own name, and it includes selling in online from abroad.
Do I need EPR if I only sell online?
Yes. Selling into a country by distance counts as placing products there, so the same duties apply. Marketplaces increasingly check that sellers are registered before allowing listings.
What happens if I do not register?
It is enforced. Depending on the country you can face fines and a ban on selling until you register. In Germany, placing packaging on the market without registering can bring fines of up to €200,000.
