GPSR · EPR · Compared
EPR vs GPSR: two different rulebooks, and you probably need both
GPSR is about whether the product is safe and who inside the EU answers for it. EPR is about the packaging around it and who pays to collect and recycle that packaging. They come from different law, they are triggered by different things, and satisfying one does nothing for the other. If you ship physical goods to EU consumers, you almost certainly need both.
The difference in one line
GPSR asks who is answerable for this product's safety inside the EU. EPR asks who pays to collect and recycle what this product is wrapped in. One is a safety and information regime. The other is an environmental financing regime. They only look similar because both landed on the same sellers at roughly the same time.
| GPSR | EPR | |
|---|---|---|
| What it governs | Product safety, and the EU contact shown in your listing | Packaging, electricals and batteries as future waste |
| Legal basis | Regulation (EU) 2023/988 | PPWR (EU) 2025/40, the WEEE Directive, Regulation (EU) 2023/1542, plus national law |
| What triggers it | Placing a consumer product on the EU market | Making packaged goods available in a specific country |
| Who you appoint | An EU Responsible Person | An EPR authorised representative |
| How many | Usually one for all 27 member states | One per member state, often one per waste stream |
| Since when | 13 December 2024, one date for everyone | Rolling: WEEE for years, batteries since 18 August 2025, packaging from 12 August 2026 |
| What you pay | A service fee to your Responsible Person | Registration plus scheme fees based on the tonnage you put on each market |
| Who enforces | Market surveillance authorities | Environmental and waste authorities, and the national registers |
What triggers each one
This is the distinction that saves the most confusion. GPSR is triggered by what you sell. Sell a consumer product into the EU and the obligation exists, whether that is one order to Ireland or ten thousand across the Union. Scale does not change it.
EPR is triggered by where you ship. Each member state runs its own register, its own scheme and its own fee schedule, and you become an obligated producer in each country where you make packaging available. Ship to five countries and you have five separate EPR relationships, not one European one.
This is why sellers think they are done when they are not
Appointing a Responsible Person feels like completing EU compliance, because it is one appointment covering the whole Union and it visibly fixes the product page. EPR has no equivalent single action. It scales with your shipping map, and nothing about the GPSR appointment touches it.
One appointment versus many
A GPSR Responsible Person can normally cover all 27 member states from a single mandate. Nothing in the regulation requires one per country. An EPR authorised representative is the opposite: appointed per member state, and frequently per waste stream inside that state, so packaging in Germany, packaging in France and electricals in Germany can be three separate arrangements with three separate invoices.
Both roles get sold under the word representative, which is where most of the mis-buying happens. The four distinct roles hiding behind that word are pulled apart in Responsible Person vs authorised representative.
The timelines do not line up
GPSR was a single date. EPR is a sequence that is still unfolding, which is why compliance is not something you finish.
One date versus a rolling series
GPSR landed once. EPR keeps arriving.
- 16 July 2021In force
Article 4 economic operator for CE-marked goods
The first EU-established-contact requirement, covering toys, electricals, PPE and machinery.
- 13 December 2024In force
GPSR applies across the EU
Responsible Person required, and the contact details must appear in the online offer.
- 18 August 2025In force
Batteries authorised representative, per member state
- 12 August 2026Next up
PPWR packaging authorised representative, per member state
By written mandate, in each country where you first make packaging available.
- April 2028Upcoming
Textile EPR operational in every member state
The revised Waste Framework Directive makes it mandatory EU-wide.
Source: Regulation (EU) 2019/1020; GPSR (EU) 2023/988; Regulation (EU) 2023/1542; PPWR (EU) 2025/40; revised Waste Framework Directive, in force 16 October 2025.
| Date | What applies |
|---|---|
| 16 July 2021 | Article 4 economic operator for CE-marked goods |
| 13 December 2024 | GPSR applies across the EU |
| 18 August 2025 | Batteries authorised representative, per member state |
| 12 August 2026 | PPWR packaging authorised representative, per member state |
| April 2028 | Textile EPR operational in every member state |
What each one costs
A GPSR Responsible Person is a predictable annual service fee. It does not move with your sales volume, and one provider covers the whole Union, so it is the easier of the two to budget.
EPR is a registration fee plus scheme fees calculated on the weight and material of everything you put on that country's market, so it scales with how much you actually ship and with how recyclable your packaging is. Material choice moves the number materially: the 2026 Citeo schedule can apply a bonus of roughly 15 to 20% to a mono-material recyclable pack and a penalty of 50 to 100% to a non-recyclable multi-layer plastic. Real per-country figures are in how much EPR costs a small ecommerce seller.
Different penalties, different authorities
You are not dealing with one regulator wearing two hats. GPSR sits with market surveillance authorities, and its penalties are national: Germany's amended Product Safety Act, in force since 19 February 2026, sets out 32 administrative offences with fines from roughly €10,000 to €100,000. The practical consequence usually arrives as a removal order to a marketplace, acted on within two working days. That mechanism is covered in GPSR penalties.
EPR sits with environmental and waste authorities, and non-registration tends to be treated as a straightforward prohibition rather than a fine to negotiate. Germany's VerpackG fines reach €200,000 and selling unregistered packaging is a sales ban. France assesses Triman and Info-Tri labelling breaches at up to €15,000 per non-compliant product. Italy fines incorrect environmental labelling €5,200 to €40,000.
The shared symptom
Both regimes reach a distance seller through the same door: a marketplace blocking a listing, or a fulfilment partner refusing stock because a registration number is missing. The letter, if it comes at all, comes later.
So do you need both?
Work through it in this order. Each line is independent of the others.
- Selling any physical consumer product to EU consumers: GPSR applies, and you need an EU Responsible Person
- Shipping those goods in your own packaging: EPR packaging registration in every country you ship to, with an authorised representative from 12 August 2026
- Selling CE-marked goods such as toys, electricals, PPE or machinery: an Article 4 economic operator on top, which the same appointment can usually satisfy
- Selling electricals or batteries: WEEE and battery registration per country, separate from packaging
- Selling cosmetics: a Cosmetics Regulation Responsible Person and a CPNP notification per product, which GPSR does not replace
If you are still working out whether the EPR side applies to you at all, start with do you need to register for EPR, which walks the producer test rather than assuming the answer.
How Assuro helps
Assuro reads your Shopify catalogue and your sales countries and works out which of these apply to you, flags the products missing GPSR data, and tracks the EPR registrations and filing deadlines per country so nothing arrives as a surprise. We organize and flag. We are not a Responsible Person or an authorised representative, and we do not file on your behalf.
Frequently asked questions
What is the difference between EPR and GPSR?
GPSR is product safety law. It requires an EU Responsible Person and specific information in your listing, and one appointment covers all 27 member states. EPR is environmental law. It requires you to register and pay a national scheme for the packaging, electricals or batteries you place on each country's market, country by country. They are different obligations with different authorities.
Do I need both?
If you ship physical consumer goods to EU customers in your own packaging, almost certainly yes. GPSR is triggered by selling the product at all. EPR is triggered by shipping packaging into a given country. Neither exempts you from the other.
Can one provider handle both?
Commercially yes, and plenty bundle them. Legally they stay separate appointments under separate law. Check that the mandate you sign names the regulation and the member states you actually need, because a GPSR mandate does not register your packaging anywhere.
Is GPSR or EPR more urgent?
GPSR, because its deadline passed on 13 December 2024 and the enforcement route through marketplace removal orders is fast. EPR for packaging has a live deadline of 12 August 2026 for the authorised representative requirement, so it is close behind, and in strict markets like Germany packaging registration has been mandatory for years already.
I sell only through my own Shopify store, not a marketplace. Does EPR still apply?
Yes. EPR obligations attach to placing packaging on a national market, not to the channel you sell through. Selling direct means no marketplace is checking your registration number for you, which removes the early warning rather than the obligation.
See where your store actually stands
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