EPR · the complete overview

EPR for ecommerce sellers: packaging, WEEE, and batteries

Updated 27 August 20268 min readShopify sellers shipping into the EU

Extended Producer Responsibility, or EPR, applies to any online seller who ships packaged goods, electronics, or batteries to EU consumers, whatever platform you sell on and wherever your business is based. There is no EU-wide revenue threshold and no single EU registration: you owe it country by country, usually from your first sale, and from 12 August 2026 PPWR adds a packaging representative rule on top. This guide covers what is true for every seller regardless of country, then where the country-by-country work actually differs.

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.

Who this actually catches

EPR is not an EU-only-business problem, a marketplace-only problem, or a large-seller problem. It attaches to the producer, defined the same way in every stream: whoever first places the packaging, equipment, or battery on a national market. For a direct-to-consumer store that is you, regardless of where you are incorporated or which platform the order came through. A US, UK, or Asia-based Shopify store shipping one parcel to a German consumer is a producer in Germany the same way a Berlin-based brand is. Selling only through your own store does not move the obligation onto a marketplace, and selling through a marketplace does not move it off you either; a marketplace's own checks sit alongside your duty, not instead of it. The full test, with edge cases, is in do you need to register for EPR.

There is no general small-seller exemption

There is no EU-wide de minimis for packaging EPR. Germany, France, and most other member states expect registration before your first sale, whatever your revenue. PPWR's own volume rule only simplifies reporting for a producer under 10 tonnes a year in a country; it does not exempt you from registering. Treat 'I'm too small' as false until a specific country's rule tells you otherwise.

The obligation streams

  • Packaging. The near-universal one. Almost every order ships in a box, a mailer, or with filler, so almost every seller owes packaging EPR somewhere.
  • Electrical and electronic equipment (WEEE). Anything with a plug, a battery, or a cable, from headphones to LED lights.
  • Batteries. Sold on their own or built into a product. Regulation (EU) 2023/1542 tightened these rules from 2023, and non-EU sellers have needed a battery authorised representative since 18 August 2025.

France runs more than 20 separate EPR streams under its AGEC law, including textiles and furniture, on top of packaging. Most Shopify sellers only ever meet the first three above; French sellers should check whether any of their other product lines fall under one of the rest.

  1. 1

    Register

    in the national registry

  2. 2

    License

    your volumes and pay fees

  3. 3

    Report

    those volumes each year

EPR follows the same shape in every country: register, license, report.

How EPR works, step by step

  1. Register in the national producer registry before your first sale.
  2. Declare the weight and material of what you place on the market.
  3. Pay a fee, usually through a national scheme or a compliance organisation.
  4. Report your volumes each year, and keep the evidence in case of an audit.

What is true in every country, before you even look at the map

Whichever country you are registering in, the mechanics repeat. These hold regardless of where you ship:

  • No EU-wide registration exists. You register, license, and report separately in each country you ship packaged, electrical, or battery-powered goods into, with no discount for doing several at once.
  • Registration is usually due before your first sale in a country, not once you notice you should have done it.
  • The obligation follows the parcel, not the platform. Your own Shopify store carries exactly the same duty as a marketplace listing.
  • Volume thresholds simplify paperwork more often than they remove the duty. PPWR's under-10-tonne rule (Article 44(8)) is a reporting shortcut, not an exemption; the same pattern shows up in national thresholds. See does PPWR apply to small businesses for the detail.
  • No local entity generally means you need a locally established representative before you can register at all, for packaging, WEEE, and batteries alike. The packaging version is covered in the PPWR packaging authorised representative guide.
  • EPR is separate from GPSR. Registering for EPR does not give you a GPSR Responsible Person, and appointing one does not cover EPR. See EPR vs GPSR.

It runs per country, and that is the trap

There is no single EU registration. Germany, France, the Netherlands, Spain, and the rest each run their own registry, their own scheme, and their own deadlines and fees. Germany is usually where sellers start, because it is the largest market and the most actively enforced. See our guide to EPR in Germany.

CountryPackaging registryWhat stands out
GermanyLUCID (ZSVR)Register before you sell, plus a dual-system license; heavily enforced.
FranceADEME, via CiteoYou need a unique identifier per stream before selling.
NetherlandsVerpact (formerly Afvalfonds Verpakkingen)Reporting with a weight threshold below which fees may not apply.

Those three are a sample. The full comparison across Germany, France, Spain, Italy, the Netherlands and Austria, with the deadline that actually binds and the shape of the cost in each, is in EPR by country.

Marketplaces check, and so do authorities

Germany's LUCID number is required by Amazon and eBay before you can list. Selling without registering is prohibited and can be fined, even if you only sell through your own Shopify store.

  1. 13 Dec 2024

    GPSR in force

  2. 12 Aug 2026

    PPWR packaging rules apply

  3. Every year

    EPR reports and fees

The EPR dates non-EU sellers should diarise.

12 August 2026

From 12 August 2026, PPWR requires an EU-established seller to appoint a packaging authorised representative in each member state it is not established in. For a non-EU seller it depends on the country: several require local representation, while Germany has you register yourself.

Roughly what it costs

There is no single figure, because the fee depends on the weight and materials you place on the market and the country. For a seller shipping into three or four countries, packaging EPR usually lands somewhere between a few hundred and a few thousand euros a year, and it is the number of countries, not the amount of packaging, that drives the bill: most of the cost is the fixed price of being registered and represented separately in each one. WEEE and battery registration add their own per-country fixed costs on top. The full breakdown by country and stream is in how much EPR actually costs and WEEE and battery registration for online sellers.

What happens if you do not register

EPR sits with environmental and waste authorities, not tax offices, and non-registration tends to be treated as a straightforward sales prohibition rather than a fine to negotiate. Germany fines a missing packaging registration up to €100,000, and failing to join a compliance scheme once you are registered up to €200,000; either way, Amazon and eBay are required to check your LUCID number before letting you list. France fines missing or incorrect Triman and Info-Tri labelling up to €15,000, a missing or inaccurate registration up to a further €30,000, and other packaging breaches up to €7,500 per product unit or tonne. Italy fines incorrect or missing environmental labelling €5,000 to €25,000. For a seller running purely on their own store, the more common first consequence is an authority notice or a held shipment rather than a headline fine, but the exposure is real either way. The country guides have the specifics.

How to stay on top of it

The hard part is not any single registration. It is keeping a live picture of which countries you owe, for which streams, and by when, as you add products and open new markets. That is what Assuro does: connect your Shopify store and it totals your packaging by material, flags where you ship into one of its six supported countries without a registration on record (Germany, France, the Netherlands, Austria, Italy and Spain), and tracks the deadlines for those six. Destinations outside that list stay yours to check. It does not register or file for you.

  • Confirm you are the producer: usually yes, if you ship packaged goods to EU consumers
  • List every EU country you ship to; that list is your registration scope
  • Start with packaging, the stream almost every seller owes
  • Check whether your products also trigger WEEE or battery registration
  • Register before your first sale in each country, not after
  • Line up a locally established representative wherever you have no legal entity
  • Diarise the 12 August 2026 packaging-representative deadline
  • Keep one live view of which countries and streams are covered

Frequently asked questions

Do I owe EPR if I only sell through my own Shopify store?

Yes. EPR applies to whoever first places packaging or products on a national market, including direct-to-consumer sellers on their own website. Selling only through your own store does not exempt you.

Does EPR apply if my business is not based in the EU?

Yes. EPR is destination-based: it attaches to whoever first places the product on a national market, not to where the business is incorporated. A US, UK, or Asia-based seller shipping to EU consumers is a producer in each country its products reach, exactly like an EU-based one, though as a non-EU seller you may also need a locally established representative before you can register.

Is there a small-business or revenue exemption?

For packaging, generally no. There is no EU-wide threshold, and Germany, France and most other countries expect registration from your first sale regardless of size. PPWR's under-10-tonne rule only simplifies reporting, it does not remove the duty to register. A few countries set narrower thresholds for specific fees or reporting tiers; see [EPR by country](/blog/epr-by-country-eu) for which ones.

Is EPR the same as GPSR?

No. EPR is about paying for the recycling of packaging, electronics, and batteries. GPSR is about product safety and the EU Responsible Person. You can owe both at the same time.

How much does packaging EPR cost a small seller?

It depends on the weight and materials you place on the market and the country, but it is the number of countries you are registered in, not the amount you ship, that mainly sets the bill. Real 2026 per-country rates and a worked example are in [how much EPR actually costs](/blog/epr-cost-ecommerce).

Which country should I register in first?

Usually Germany. It is the largest EU market, the most strictly enforced, and marketplaces require your LUCID number, so it is the one most likely to bite first.

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 free

Which platform runs most of your EU sales?

One tap. It decides which platform we build for after Shopify.

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