How to manage EPR in multiple countries in 2026

The first country is a task you can do by hand. To manage EPR in multiple countries you need a system, and this guide builds one.

By the end you will have a single sheet holding every extended producer responsibility duty you carry, country by country, plus a routine that keeps it true as you add markets.

It is written for whoever already handles EPR in one market and has just been handed the next three. The country rules themselves are not the hard part. Holding all of them at once is.

The footprint you are starting from

Pull these together before you start, because every step below reads from them.

1. Every country you sell into, and how the goods get there. Your own webshop, a marketplace, a local distributor and a local subsidiary are four different answers.
2. Your product data at component level. Each item broken into its parts, each part with a material and a weight.
3. Last year's volumes per country, in whatever shape you have them.
4. Every registration number you already hold, with the country and the waste stream it belongs to.
5. Where your company is legally established, and where it is not.

Why the work changes shape when you add a country

EPR is written at EU level and filed at national level. Under the Packaging and Packaging Waste Regulation (EU) 2025/40, which applies from 12 August 2026, each Member State runs its own producer register.

You register in every Member State where you first make packaging available, and until you are registered there, you may not sell there.

So the second country does not double your workload evenly. Your underlying numbers stay the same. What changes is the shape they have to be poured into, and the dates they are due.

That leaves three moving parts. A map of who owes what and where, one dataset that every country can be cut from, and one calendar that every deadline sits on. The six steps below build them in that order, and each one adds a column to a single country matrix.

Step 1. Draw the line between where you sell and where you owe

Selling into a country does not by itself create the duty. The duty attaches to whoever first makes the product available on that national market.

If a local distributor imports your goods and puts them on the shelf, they are usually the producer there. If you ship direct to a consumer from abroad, you are.

Go country by country and write one row per country and waste stream. Packaging, electricals, batteries and textiles are separate duties with separate registers, so a single country can give you four rows.

You know this column is finished when every country you sell into has either a duty written against it or a named reason it does not.

Step 2. Name the party that carries the duty in each country

Once a row has a duty, someone has to carry it. There are three answers and the right one is set locally.

1. You register yourself in that country's register, which is how most EPR registration still works.
2. You appoint an authorised representative for EPR, a person or company established in that country that carries your registration, reporting and fees there under a written mandate.
3. A producer responsibility organisation (PRO) you have joined does the register work on your behalf, where that country allows it.

The trap is assuming a country answers the same way for every stream. Germany is the clearest example. For electricals, a producer with no German establishment must appoint a representative in writing and in German.

For packaging, German law now requires a producer with no German establishment to appoint a representative for its duties, but it expressly excludes the LUCID registration, so that stays yours.

France runs one cross-stream rule instead. It also treats the duty as met for products where a France-based marketplace already ensures compliance, which is worth checking before you pay for a mandate you do not need.

Step 3. Build one product dataset every country can be cut from

Every market asks for a different slice of the same reality. That only becomes a problem if you collect the data at the level each market asks for, because then you hold five incompatible sets and no way to reconcile them.

Collect once, at the finest level anyone asks for. One record per item, split into components, each component carrying its material, its weight and what it does. A 300 gram carton with a plastic window and a paper label is three lines, not one.

From that base, a country filing is a filter rather than a fresh data-gathering exercise. Volumes attach the same way, per country and per period, so one component can be counted in three markets without being entered three times.

This column is done when you can produce last year's numbers for any market without opening a second spreadsheet.

Step 4. Translate that dataset into each country's own categories

The same box lands in a different bucket in every market, and the mapping between them has to be written down rather than remembered. Take one cardboard box with a plastic window and follow it into three systems.

1. The EU packaging register asks for weight against the packaging categories set out in Annex II of the Regulation.
2. Germany works in material fractions. Glass is counted on its own, paper and cardboard on their own, and metals, plastics, beverage cartons and composites together as lightweight packaging.
3. The United Kingdom wants material, plus whether the packaging is household, plus which UK nation it was sold in.

Write the mapping as a rule against the component rather than against the finished product. A new market then becomes one more column in the mapping table, and a packaging change updates every market at once.

The direction of travel helps here. Article 44 of the Regulation instructs the Commission to set a single format for registration and reporting, including which packaging types and material categories are covered, with a date of 12 February 2026 attached to it.

Until that format reaches the national systems, you are still filing into each country's own shape.

Step 5. Put every date from every country on one calendar

This is where multi-country actually bites, because the rhythms genuinely differ for the same material.

Two more dates belong on the same calendar. A register has up to twelve weeks to issue your registration number once your application is complete, so a market launch is planned a quarter ahead rather than a fortnight.

A Member State may also require quarterly submissions for budgetary reasons, which turns one country from an annual job into four.

Small volumes do not remove a date. Under ten tonnes in a calendar year you file a reduced data set, still by 1 June.

In the United Kingdom, size decides your rhythm rather than your exposure. The large producer band starts at £2 million turnover and more than 50 tonnes of packaging.

Step 6. Keep the proof and re-check the map when something moves

Each filing needs a file behind it holding what you sent, the numbers underneath it and who signed it off.

Some markets go further and require the register data to be audited and certified by independent auditors. Germany already does this above its thresholds, where the declaration of completeness has to be confirmed by an auditor registered in LUCID.

Then keep the matrix alive, because two things move it.

1. Your own footprint. A change to your registered information has to be notified to the competent authority without undue delay, and so does stopping altogether.
2. The rules. The EU battery producer responsibility rules have applied since 18 August 2025, the packaging ones from 12 August 2026, and textile schemes are due to be in place across the EU by 17 April 2028.

A quarterly re-read of the matrix catches both while they are still cheap to fix.

Where Repax fits when the country count goes up

Two of the six steps above are data work, and that is the part software actually removes.

• Repax Core holds the one dataset. One structured spec per product, broken into materials and components, with the report generated in the shape each filing wants. That is steps 3 and 4 without the reconciliation, and it starts free at €0 a month with paid plans from €29 a month.
• Repax Comply is the multi-market filing surface. One membership across EU markets: it registers you with the right PRO in each country, files on each deadline and arranges an authorised representative where one is required.
• What neither does is make you compliant. Core generates reports, and Comply does the registering and filing under a power of attorney, but the responsibility stays with you.

What breaks when you add the next country

These are the failures that only show up once the country count rises, so they rarely bite the first time.

1. Treating one registration as regional cover. Registration is per Member State, and selling before you are registered there is not allowed.
2. Assuming one representative covers the EU. A representative has to be established in the country you are selling into, so a Dutch one does not cover Spain.
3. Copying a country's answer across its own streams. Germany gives one answer for electricals and a different one for packaging.
4. Reusing the last market's category mapping. The same box sits in a different bucket, and a wrong bucket is a wrong fee.
5. Launching without the registration lead time. Up to twelve weeks for the number means the compliance work starts before the marketing plan does.
6. Reading a low volume as no duty. Under ten tonnes is a lighter report, not an exemption.

Frequently asked questions about managing EPR in multiple countries

Four questions come up almost every time a second market lands.

How long does this take?

Building the first matrix takes a few days if your product data already exists. Adding a new market takes a quarter, because a register has up to twelve weeks to issue your registration number once your application is complete.

Is there a single EU registration that covers every country?

No. Each Member State runs its own register and you register in each one where you first make packaging available. The EU is harmonising what those registers ask for rather than merging them into one.

Do I need a separate representative in every country?

Where you need one at all, yes, because a representative has to be established in the country you are selling into. Whether you need one depends on the waste stream and the country, so answer it market by market.

Can Repax file in every country for me?

Yes, with Comply. Core holds your product data and generates the report each market wants, and Comply, the multi-market filing surface, registers you and files it with each register or PRO across EU markets.