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FAQ

Who Pays for Packaging EPR When Selling Cross-Border?

PPWR

Under the Packaging and Packaging Waste Regulation (EU) 2025/40, Extended Producer Responsibility, or EPR, makes the producer of packaging pay towards its eventual collection and recycling. The awkward part for online sellers is that this obligation is national: you must register and pay EPR fees in each Member State where you place packaging on the market, not just in your home country.

Does shipping cross-border make me the producer?

Often, yes. When you sell directly to a customer in another EU country and ship your packaged product to them, you are typically the party placing that packaging on the market in the destination country. As a distance seller, that means the EPR obligation for the country you are shipping into commonly falls on you, rather than on the customer or the carrier.

What do I actually have to do?

  • Register with the packaging EPR scheme in each Member State you sell into.
  • Report the quantity and type of packaging you place on that national market.
  • Pay the fees that scheme sets, which vary by country and material.
  • Appoint an authorised representative where a country requires one for non-established sellers.

That last point matters. Several Member States require a seller based outside their territory to appoint an authorised representative established in the country to handle the EPR registration and reporting locally. Because this requirement is set per country, a business shipping across several markets can end up needing a representative in each of them.

Why it is easy to get wrong

Sellers often assume a single home-country registration covers the whole EU. It does not. EPR remains fragmented along national lines, so growing your cross-border sales quietly multiplies your compliance footprint. Mapping which countries you ship into, and confirming each one’s registration and representative rules, is the practical first step. You can read more on our PPWR law page and the complete PPWR guide.

This answer is educational and does not constitute legal advice.

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