EPR · Country comparison
EPR by country: EU registration, deadlines and cost for Shopify sellers
Packaging EPR is national, not EU-wide. There is no single registration that covers the EU: you register, join a compliance scheme, and report separately in each country you ship packaged goods into, and since 12 August 2026 you may also need a packaging authorised representative in some of them, depending on where you are established and what each country requires. This page puts the six countries most Shopify sellers reach, Germany, France, Spain, Italy, the Netherlands and Austria, side by side, so you can see who has to register, the deadline that actually binds, and the shape of the bill before you commit to a market.
Assuro connects to Shopify. The guidance below applies whatever platform you sell on.
GPSR, product safety
- Responsible Person
- Manufacturer ID
- Safety information
One EU-wide layer. A single Responsible Person can usually cover all 27 countries.
EPR, per country
- Packaging (LUCID / Citeo)
- WEEE
- Batteries
Registered and reported separately in each EU country you sell into.
The one rule that explains all the others
Every obligation below follows from a single fact: packaging EPR is a duty you owe to a country, not to the EU. Each member state runs its own producer register, approves its own compliance schemes, sets its own reporting deadline, and enforces with its own fines. Ship to three countries and you have three registrations, three schemes, and three sets of reports, with no volume discount for doing several at once. The EU Packaging Regulation (PPWR) that became applicable on 12 August 2026 harmonises the framework, but it does not merge the registers, so the work stays per country.
That is a nuisance when you are setting up and an advantage when you are catching up. Because the obligations are national and independent, you can cover the countries that matter first and work down, instead of facing all of them at once.
EPR by country at a glance
The six countries below are the ones this guide covers in depth. For each, the questions that decide whether you are in scope and by when: who has to register, the deadline that binds, and how the cost is shaped. Every country name links to the full step-by-step guide.
| Country and scheme | Who has to register | Key 2026 deadline | Rough cost shape |
|---|---|---|---|
| Germany, LUCID register plus a dual system | Anyone placing packaging on the market, from the first item. No minimum volume. | Declaration of Completeness by 15 May if you pass 80,000 kg glass, 50,000 kg paper and board, or 30,000 kg light packaging. | LUCID registration is free; small-volume dual-system licences advertised from around €39 a year, plus representation if you have no German entity. |
| France, Citeo or Leko | Anyone placing packaging on the market, from the first item. No minimum volume. | Annual declaration to your eco-organisation, filed in the first part of the year. | A weight rate per material plus a per-unit tariff, moved up or down by eco-modulation; a representative is required for a non-EU seller. |
| Spain, RPP / MITECO plus Ecoembes | Anyone placing packaging on the market, from the first sale. Under 15 tonnes a year is simplified reporting, not an exemption. | RPP report by 31 March; data to your scheme by 28 February. | Scheme fee per kg by material, around €0.52/kg for PET, plus a separate €0.45/kg tax on non-recycled plastic. |
| Italy, CONAI membership | Foreign sellers may join voluntarily; membership is the enrolment. RENAP has no packaging section yet. | 20 January for annual-class declarers; quarterly and monthly classes file more often. | The CONAI contribution (CAC) per tonne by material; your class is set by the CAC you declared last year. |
| Netherlands, Verpact | The fee and annual declaration start at 50,000 kg of packaging a year. A PPWR representative duty can apply below that. | Annual declaration by 31 March, a binding date under the Verpact agreement. | A waste-management fee on the quantities you place above the 50,000 kg threshold. |
| Austria, EDM / ZAReg plus a system such as ARA | Anyone placing packaging on the market; conclude a system contract within two months of your first Austrian shipment. | Report prior-year data to your system by 15 March. | Cadence and fees scale with volume: annual up to €1,500 in fees, quarterly to €20,000, monthly above. |
Two things to read carefully. First, a volume threshold (the Netherlands' 50,000 kg) sets when the fee starts, not always when the duty to register or appoint a representative starts, so you can owe paperwork below it. Second, watch the unit: Italy prices its contribution per tonne while France and Spain price per kilo, so a headline number is meaningless until you know which one it is.
PPWR added a representative rule, but it is not one blanket EU switch
This is the part that is easy to overstate. Since 12 August 2026, PPWR (Article 45) requires a producer established in one EU member state that sells into other member states, direct to consumers, to appoint a packaging authorised representative in each of those where it is not established. For a seller established outside the EU, PPWR lets each member state decide whether to require one, so whether you need an appointment is a country-by-country question, not an automatic rule in all 27.
In practice, several of these countries already require a foreign distance seller to be represented or registered locally under their own law, and have for years: France through the *mandataire*, Spain through the *representante autorizado*, and Austria, which requires an Austrian representative for distance sales to private consumers. Germany takes the other route, making the foreign seller directly responsible so you register in LUCID in your own name with a representative optional. So for the markets most Shopify sellers ship to, the honest planning assumption is that you will need to be represented or registered locally, while the exact instrument is national. Check each country rather than assuming one EU appointment covers you or that none is needed.
Do not confuse this with the GPSR Responsible Person
The GPSR Responsible Person covers product safety and one appointment can often cover the whole EU. The PPWR packaging representative covers packaging EPR and is never EU-wide: an EU-established seller needs one in each member state it is not established in, and a non-EU seller needs one wherever that country's own law requires it. A non-EU seller can owe both at once. The two are compared in Responsible Person vs authorised representative.
Which country to start with
Do not try to fix all six at once. Take your last twelve months of orders and list the countries you actually shipped packaged goods to, ranked by volume. Do not use your Shopify Markets settings for this: most stores have markets switched on that they barely sell into, and each idle market is a full set of obligations for a handful of orders. Register and appoint in the countries at the top of that list first, and work down.
A ranked list is sequencing, not compliance
Ordering the work by volume tells you where to start, nothing more. A country lower down the list is one you are non-compliant in until you cover it, however few parcels go there. For any market you are not going to register in soon, the practical move is to turn checkout off for it, which stops the obligation growing but does not erase what has already accrued.
What it all costs
Across a few countries, packaging EPR usually lands between a few hundred and a few thousand euros a year, and the number of countries drives the bill far more than the amount of packaging. Most of what you pay is the fixed cost of being registered and represented in each country separately; the weight-based fees on a few hundred kilos of cardboard and mailers are genuinely small. The full breakdown, with a worked example, is in how much EPR actually costs.
How Assuro helps
The hard part was never registering in one country. It is seeing, across a whole catalogue, which countries you genuinely ship packaging into, which you already cover, and which have been running uncovered while you assumed otherwise. Assuro connects to your Shopify store, totals your packaging by material, and flags where you ship into one of its six supported countries, Germany, France, the Netherlands, Austria, Italy and Spain, without a registration on record, then tracks each country's deadline. A destination outside those six stays yours to check by hand. It organizes and flags. It does not register you, act as your representative, or file anything, and it never certifies that you are compliant.
- List the EU countries you actually shipped packaged goods to in the last twelve months, by volume
- For each, check the register and scheme in the table above, not your assumption from another country
- Note the deadline that binds in each: 20 January in Italy, 15 March in Austria, 31 March in Spain and the Netherlands, 15 May in Germany
- Check each country's representative rule: PPWR requires one for EU-established sellers, while non-EU sellers follow each country's national law (most of these require local representation)
- Start with your largest market and work down; close checkout for markets you will not cover soon
- Keep one live view of which countries are covered and which are not
Frequently asked questions
Is there one EU-wide EPR registration?
No. Packaging EPR is national. You register, join a scheme, and report separately in each member state you place packaging on the market in. PPWR, applicable since 12 August 2026, harmonises the rules but does not create a single EU register or a single EU representative.
Which EU countries have a volume threshold before EPR applies?
Among the six here, the Netherlands is the clear one: its waste-management fee and annual declaration start at 50,000 kg of packaging a year. Germany, France, Spain, Italy and Austria expect registration from the first sale. Even where a fee threshold exists, a registration or representative duty can still apply below it.
Do I need EPR in a country if I only ship a few orders there?
In most of these countries, yes. Germany, France, Spain and Austria expect registration from the first sale, so a handful of orders still puts you in scope. What scales with volume is the cost, not usually the duty. If a market is genuinely tiny, the honest options are to budget for it or to stop shipping there.
What changed for EPR on 12 August 2026?
PPWR became generally applicable. Packaging EPR itself already existed in each country. What PPWR added is a harmonised representative rule: a producer established in one EU member state must now appoint a packaging authorised representative in the other member states where it is not established. For a seller established outside the EU, PPWR leaves it to each member state to decide whether to require one, and several already do under national law.
Does Assuro register me in these countries?
No. Assuro organizes and flags. It totals your packaging by material, shows which of its six supported countries you ship into without a registration on record, and tracks the deadlines. It does not register you, join a scheme, act as your representative, or file anything, and destinations outside those six stay yours to check.
Assuro is a Shopify app for EU compliance
It reads your catalogue and flags, product by product, which ones are missing GPSR data and which EPR registrations they pull in across 6 EU countries. Scanning and the full exposure report are free. Writing the fixes back into your Shopify products starts at $39 a month.
Scan your store freeWhich platform runs most of your EU sales?
One tap. It decides which platform we build for after Shopify.