EPR registration requirements for EU marketplace sellers

The Packaging and Packaging Waste Regulation (EU) 2025/40 extends verified packaging EPR registration to every member state where goods are sold. Until now marketplaces checked a handful of countries; from that date the check applies across the EU and offers without a valid number are deactivated with no transition period. The same date makes an authorised representative mandatory for producers not established in the country of sale.

No. Extended producer responsibility is implemented per member state and there is no pan-EU number. You register with the national producer register or the scheme in each country where you place covered products, and each marketplace checks the number issued by its own country. A German LUCID number proves nothing in France or Poland.

No, and this is the most expensive misunderstanding in the whole area. Registering in LUCID with the Central Packaging Register is free and mandatory, but it licenses nothing. You must separately contract a dual system, which is the part you pay for, and declare the same volumes to both. A seller holding only a LUCID number has completed one of two obligations.

No. Where a seller has no valid number, some marketplaces enroll them automatically into a paid service that files on their behalf. That covers only the sales made on that marketplace and does not create a producer registration in your own name, so obligations for your other channels remain unmet and the underlying registration is still missing.

Often not. Several countries have no de minimis at all, so the obligation starts with the very first shipment. Where thresholds do exist they vary wildly in both size and unit — a weight per year in one country, a turnover figure in another, a quarterly figure by material in a third. The tool shows the threshold per country and says plainly where it has not been confirmed.

Because the tariff tables are not publicly available in a form that can be trusted. The French schedule is released only through a form requesting company details, the Italian guide is not directly downloadable and the Spanish rates are not published openly. Third-party summaries disagree with each other by close to twenty percent on the same material. Publishing a figure on that basis would be worse than publishing none, so this tool answers where you must register and leaves the amount to the official schedule.