Packaging and packaging waste (EPR)

• Directive 94/62/EC — Packaging and Packaging Waste
• Regulation (EU) 2025/40 — PPWR
• National EPR laws

Who has to appoint one

Anyone shipping packaged goods to consumers in a member state without being established there, including marketplace sellers and dropshippers.

Thresholds and exemptions

Most member states set the threshold at zero for distance sellers. France, Germany, Austria and Spain enforce it actively.

What must appear on the label

Material identification and sorting instructions, which are mandatory in France and Italy and becoming mandatory EU-wide under the PPWR.

Marketplace fields

Amazon requires an EPR number per country and blocks sellers who cannot supply one.

Documentation you must hold

Registration with the national register, contract with a compliance scheme, and annual declarations of packaging volumes by material.

Standards and testing

Not applicable.

Language requirements

Sorting instructions in the language of the country concerned.

When it applies

Registration before the first shipment into that country.

How long records are kept

Per national law, generally 5 to 10 years of declarations.

What happens if you do not comply

Sales bans, retroactive fees for undeclared volumes and marketplace suspension. Germany's LUCID and France's UIN are checked automatically.

Who enforces it

National packaging registers and environmental agencies.

Where the boundary lies

This is national, not EU-wide: an Article 27 or Article 16 appointment in Prague does not cover packaging EPR in Germany or France. Each country needs its own authorised representative and registration.

Questions we are asked

We only sell through Amazon — do they handle it?

No. Amazon checks that you have a number, it does not obtain one for you.