This guide is for anyone who puts physical products onto a European market and now has to register for Extended Producer Responsibility (EPR). That means manufacturers, importers, brands selling under their own name, and online sellers shipping in from abroad.
By the end you will know how to complete your EPR registration in Europe, in the right order, whether you sell in one country or a dozen. Registration is where EPR stops being a memo and becomes real, so it is worth getting right the first time.
What to have ready before you register
Registration itself is mostly form-filling. What slows it down is not having the details to hand, so gather three things first.
- Your company details. Legal name, address, and tax or VAT number. Every national register asks for these.
- Your product and packaging data. What each item is made of and what it weighs. You register per product category, then report on the same figures later.
- The list of countries you sell into. That is what decides where you have to register at all.
If your product data is spread across spreadsheets and suppliers, pulling it together is the slowest part of the job. Start there.
Why EPR registration works country by country
Before the steps, hold one picture in your head. There is no single European EPR register. EPR is set at EU level, under rules like the Waste Framework Directive, but each country runs its own system. So you register in every country where you place products on the market, and you do it separately each time.
Two things follow from that:
- The trigger is the market, not your address. Sell into a country, online or through a shop, and you register there even with no office in it.
- In most countries, registration is really two sign-ups. One is the national producer register run by the authorities. The other is a compliance scheme (a producer responsibility organisation, or PRO) that does the actual recycling for you.
The steps below cover both.
The steps to register for EPR
The sequence is the same in every country. You run it once for each country you sell into, and once for each waste stream you place on the market. A waste stream is the category the rules sort a product into, such as packaging, electronics (WEEE), or batteries.
1. Confirm you are the producer who has to register
EPR duties fall on the "producer", and in the rules that word has a specific meaning. It is whoever first places a product on a national market, which can be the manufacturer, the importer, a brand selling under its own name, or a distance seller shipping in from another country.
Being small or selling only online does not exempt you. Most schemes have a low registration threshold or none, and an online sale into a country counts as placing a product there.
Check each market, because the exact definition and any threshold vary. Once you are the producer for a given stream in a given country, the duty to register there is yours.
2. List the countries where you must register
Take your sales data and write down every country a customer can receive your goods in. Each one is a separate market with its own register, so that list is your registration to-do list.
Do this even for countries where you sell only a little, since thresholds are low and online sales count. The country guides show what each market expects, and the shape of the work does not change from one country to the next.
3. Register with each country's producer register
This is the core act. Each country runs its own producer register, and in most of them you have to be on it before your first sale, not after. You submit your company details and the product categories you place on the market, one registration per stream.
The names differ by country. In Germany, packaging goes in a register called LUCID, run by the Zentrale Stelle Verpackungsregister, while electricals and batteries go through a body called stiftung ear. In France you apply to the environment agency ADEME for a unique identifier (an identifiant unique), one per stream.
Register per stream, per country. Selling packaged electronics into two countries can already mean four registrations.
4. Appoint an authorised representative where a country requires one
If your company is not established in a country you sell into, that country may require an authorised representative based there to hold your EPR duties for you. This mainly catches non-EU and cross-border online sellers.
The requirement is stream-specific and set per country, so check it market by market. Germany, for example, does not let a foreign company register itself for electricals or batteries. It has to act through a representative in the country.
From 12 August 2026, when the EU Packaging and Packaging Waste Regulation (PPWR) takes effect, the same requirement reaches packaging.
5. Join the compliance scheme tied to your registration
In almost every country, being on the register is only half of it. You also join a producer responsibility organisation (a PRO), the collective scheme that actually collects and recycles your product waste. You sign a contract with the PRO for each stream.
The two are linked. In Germany, for instance, your LUCID registration and your contract with a dual system have to line up. Treat the state register and the scheme as one job with two parts, done together, or your registration is incomplete and can be flagged.
6. Record your registration numbers and keep them current
Registering earns you one or more registration numbers (in France that identifiant unique, in Germany a LUCID number). They are not just for the file. You put them on invoices, hand them to your PRO, and, if you sell through an online marketplace, enter them in the platform's compliance fields.
Marketplaces now check. In Germany a marketplace may not list your packaging unless you are in LUCID, and in France it must collect your unique identifier. Amazon, for one, asks for your numbers before it lets you sell. A missing or expired number gets listings pulled, so keep every registration live and renew on time.
How Repax handles registration across countries
Doing all of this by hand means a separate login, form, and deadline for every country and stream, sitting on top of a materials spreadsheet that has to feed each one. Repax is built to take that work off your calendar, and it splits the job the same way this guide does.
- Repax Core gets your data register-ready. Spec each product once (materials, weights, components) and Core turns it into the figures every register and report asks for. It is live now.
- Repax Comply is being built for the filing itself, registering and submitting across markets from one place. It is on the way, with a waitlist open.
- Repax Declare handles the EU packaging Declaration of Conformity, if your packaging needs one under the PPWR.
Repax does not make you compliant on its own, and it does not register for you today. It does the data work that every registration depends on, and the filing side is coming.
Pricing is public. There is a free tier at €0 a month, paid plans from €29 a month, and a custom tier for high volume (as of July 2026).
Still choosing a tool? Our best EPR software rundown compares the main options, Repax included.
Common mistakes when registering for EPR
A handful of traps catch almost everyone registering for the first time:
- Assuming one EU registration covers you. There is no single European register. Every country is a separate sign-up.
- Registering after your first sale. Most countries want you on the register before you place a product on the market. In Germany, selling packaging without registering can bring fines of up to €200,000.
- Stopping at the state register. The authorities' register and the compliance scheme are two different things, and in most countries you need both.
- Forgetting the packaging around the product. The box an electronic item ships in is its own packaging registration, on top of the electronics one.
- Letting a number lapse. An expired registration is exactly what makes a marketplace pull your listings, so renewals are not optional.
Common questions about registering for EPR
Short, self-contained answers to the questions producers ask most about registering.
How long does EPR registration take?
It depends on how many countries and streams you sell into, because each registration is separate. One country and one stream can be quick once your product data is ready. A cross-border catalogue takes longer. The slow part is almost always gathering the product data, not the sign-ups themselves.
Does the manufacturer or the seller have to register?
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 another country.
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.
Do I need to register 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 you are registered before they let you list.
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, and marketplaces will pull your listings. In Germany, placing packaging on the market without registering can bring fines of up to €200,000.
