Do you need to register for EPR? A decision guide for Shopify sellers

The short answer, and the myth to drop

The most common belief among small sellers is that there is a threshold, a revenue or volume line below which EPR does not apply. For packaging in most EU countries, there is not. There is no EU-wide de minimis, and Germany, France, and others expect you to register before your first sale regardless of size. A few countries set small thresholds for specific streams or for certain reporting duties, but the baseline is simple: if your packaged product reaches an EU consumer, assume you have to register.

Question 1: are you a 'producer'?

EPR attaches to the producer, which is not the factory that made your packaging. It is the company that first places the packaged product on a national market. For a direct-to-consumer seller that is almost always you. It does not matter where your business is incorporated: a US, UK, or Asian seller whose products reach EU consumers is a producer in each of those markets. See our EPR pillar guide for the full definition.

Question 2: does it apply if I only sell on my own store?

Yes. This trips up sellers who assume EPR is an Amazon problem. Marketplaces do carry their own verification duties, and from 12 August 2026 they must check seller EPR compliance more strictly under the new Packaging Regulation, but that does not move the obligation off you. If anything, selling only through your own Shopify store means there is no marketplace handling any of it for you, so the whole registration and reporting job is yours.

Question 3: which streams do you owe?

EPR is not one obligation but several, split by what you put on the market:

• Packaging. Almost every order ships in a box, a mailer, or with filler, so almost every seller owes packaging EPR somewhere. This is the near-universal one.
• Electrical and electronic equipment (WEEE). Anything with a plug, a battery, or a cable.
• Batteries. Sold on their own or built into a product.

France adds more streams still, over twenty under its AGEC law, including textiles and furniture. The EPR pillar guide explains how each stream works.

Question 4: which countries?

There is no single EU registration. You register in each member state where you place goods on the market, and each runs its own registry, scheme, deadlines, and fees. The countries most sellers hit first are Germany, with LUCID and a dual system, and France, with Citeo, ADEME, and Triman, because they are large and strictly enforced. The list grows with every market you open, including Spain, the Netherlands, Italy, and Sweden.

Question 5: roughly what will it cost?

There is no single figure, because the fee depends on the weight and materials you place on the market and the country. For a small seller, packaging EPR is often a few hundred euros a year per country, plus the time to register and report. It is the per-country multiplication, not any single fee, that adds up: three markets can mean three registrations, three schemes, and three sets of reports.

Question 6: what happens if you ignore it?

Selling packaging you have not registered is prohibited in strict markets. Germany's fines reach €200,000, France assesses labelling penalties per product, and marketplaces block unregistered sellers from listing. Even selling only through your own store, the practical risk is authority notices, and customs holding or returning shipments. The country guides have the specifics.

How to answer all six at once

The awkward part is not any single question. It is answering all six across a whole catalogue, and keeping the answer current as you add products and open markets. That is what Assuro is for: connect your Shopify store and it shows, product by product and country by country, which SKUs need packaging, WEEE, or battery registration, which markets you sell into but have not registered for, and which deadlines are coming. It organizes and flags. It does not register or file for you.

• Assume EPR applies unless you have confirmed otherwise for a specific country and stream
• Confirm you are the producer; for a direct-to-consumer seller, you usually are
• List every EU country you ship to, that list is your registration scope
• Work out which streams you owe: packaging first, then WEEE and batteries
• If you are outside the EU, line up an authorised representative and a GPSR Responsible Person
• Keep one live view of which SKUs and countries are covered, and which are not