EPR: ExtendedProducer Responsibility in Cross-Border E-Commerce – Guide 2025

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Extended ProducerResponsibility (EPR) has become one of the most important regulatory topics in the EuropeanUnion, directly affecting online sellers and platforms such as Amazon. Frompackaging to electronics, batteries and soon textiles, sellers must ensurecompliance with national and EU rules. Non-compliance can mean blockedlistings, financial penalties, or even bans from marketplaces.

In this guide, we explain what EPR means foronline retailers, provide country-specific examples, and highlight the upcoming2026 changes that will impact all cross-border e-commerce.

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What is Extended Producer Responsibility (EPR)?

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EPR is an environmental policy requiring producers to take responsibility for the entirelife cycle of their products – including collection, recycling and safedisposal. The system is designed to reduce waste, increase recycling rates andpromote sustainable resource use.

For onlinesellers, this means you must ensure that packaging, electronic devices,batteries and other regulated products placed on the market are correctlyregistered and reported under local rules.

Main productcategories covered by EPR in Europe:

·      Packaging (EPR for packaging)

·      Electrical and electronic equipment (WEEE)

·      Batteries

·      Textiles (already mandatory in some markets)

·      Additional categories in selected countries (e.g. furniture, toys,tyres, mattresses).

Compliancerequires registration, reporting, and payment of recyclingfees to national schemes.

Why EPR matters for e-commerce in Europe

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E-commercesellers must comply with national EPR laws in every market where theysell. This includes:

·      Registering with official EPR schemes,

·      Appointing authorised representatives (where required),

·      Paying fees that fund recycling and waste management.

Marketplaces suchas Amazon have already introduced EPR verification. Sellers must provideproof of registration before they can continue selling in certain countries. InFrance, Spain and Germany, failure to do so results in automatic listingsuspension.

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As regulationstighten, EPR is no longer just an environmental obligation — it is a marketaccess requirement.

Who is defined as a “producer” under EPR?

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Under EPR rules,a “producer” is not just a manufacturer. You may be classified as one if you:

·      Sell products online in a particular EU country,

·      Package products or have them packaged,

·      Import or place packaged goods on a foreign market.

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Example:
A retailer selling from abroad into Spain isconsidered a producer for the Spanish market and must register with theSpanish EPR scheme.

Examplesof EPR requirements across Europe

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EPR laws vary bycountry. Below are key examples:

·      Germany: Packaging Act(VerpackG) requires registration in the LUCID Packaging Register andparticipation in a dual system. WEEE and battery obligations fall under theElektroG and BattG.

·      France: Strict circulareconomy law. EPR applies to packaging, electronics, batteries, textiles,furniture, toys and more. Mandatory registration and contributions toeco-organisations.

·      Italy: Producers mustregister with CONAI (packaging). WEEE and batteries require appointingan authorised representative. A textile EPR scheme is also planned.

·      Spain: Sellers mustregister with the Register of Producers and pay fees to approvedsystems. Non-compliance brings significant penalties.

·      Netherlands: Obligations for packaging, electronics, batteries and tyres. Reportingis done to organisations like Afvalfonds Verpakkingen. High emphasis ontransparency and recycling targets.

·      Sweden: One of the mostdeveloped EPR systems. Covers packaging, electronics, furniture and more.Registration with recovery organisations and strict reporting required.

·      Poland: Producers mustregister with the BDO (Waste Database), ensure recycling and pay productfees. Applies to packaging, WEEE and batteries.

Howto stay compliant as a cross-border seller

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Cross-bordere-commerce sellers must:

·      Register in every targetcountry’s EPR scheme,

·      Appoint authorised representatives if they don’t have a local entity,

·      Submit reports on quantities of products and packaging placed on the market,

·      Pay recycling fees regularly.

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This can becomplex and costly, but non-compliance can result in listing suspensions,fines or sales bans.

New EU Packaging Regulation (PPWR) – Game-Changer

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The current EUPackaging Directive will be replaced by the EU Packaging and Packaging WasteRegulation (PPWR – Regulation (EU) 2025/40).

·      Entered into force: February 2025, full effect after 18 months.

·      Applies to: All sellers, marketplaces, and logistics operators.

·      Main change: From mid-2026, online sellers will only be able tosell in countries where they comply with EPR rules.

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Under the EUDigital Services Act (DSA), marketplaces must verify compliance and can beheld liable.

Keychange from 2026

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From mid-2026, alle-commerce sellers must prove EPR compliance in each EU market.Marketplaces such as Amazon, Zalando and eBay will enforce checks — and blocksellers who cannot provide valid EPR numbers.

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This is a majorshift: EPR becomes not just an environmental duty but a licence to operatein Europe.

Summary

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EPR obligations already apply across Europe, but from 2026 enforcement will tighten significantly. Each country has its own system, from Germany’s LUCID register to France’s textile obligations and Spain’s national collection schemes.

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Non-compliancemeans:

·      Lost market access,

·      Severe fines,

·      Damaged seller reputation.

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Working with specialistpartners like Shopreturns makes compliance easier. We helpe-commerce retailers:

·      Manage cross-border returns,

·      Consolidate logistics,

·      Build a competitive, compliant presence across Europe.

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