EPR in Europe: A Guide to EU Packaging Compliance

Extended Producer Responsibility (EPR) in Europe:
What Businesses Need to Know

Selling products in Europe provides businesses with access to the consumer market. But selling in European countries is not only about the opportunity to sell but also requires an awareness of product and packaging regulations as well as environment and taxation regulations.

There is one particular requirement for businesses to know about which is called Extended Producer Responsibility (EPR). EPR is an environmental regulation model that obliges businesses to collect, recycle and dispose of waste produced by their products and packages.

For businesses operating in the European Union (EU), it is crucial to know about EPR to be compliant and prevent any surprises from regulations. Below you can find more information about EPR, its meaning, businesses that can be affected by EPR, how it works in European countries and how it differs from VAT.

What Is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a system of waste management that obligates producers to be responsible for the waste produced by the products in their care.

In layman's language, the businesses that place products or packaging on the market should be liable for managing such waste after consumers have used the products. As an instance, a business marketing skin care products in Germany should be accountable for the packaging of these products including plastic bottles, cardboard boxes and other types of packaging.

The obligations for the businesses include, among others, registration at the concerned national authority or with a registered PRO, reporting the quantities and types of packaging that have been placed on the market and making the environmental contributions.

The general idea of EPR is waste minimization and better packaging practices.

Why Does EPR Matter for Businesses Selling in Europe?

EPR is especially significant for companies that are engaged in international e-commerce, retailing, manufacturing and distribution of products. A company which operates outside Europe may be obliged to follow EPR rules when selling its packaged products to individual consumers from EU countries.

Some of the main aspects why it is crucial for companies to know about EPR are:

1- Environment protection: Businesses play an important role in collecting, recycling and managing packaging waste.

2- Compliance with regulations: It is necessary to know about national registration and reporting rules.

3- Sales and distribution facilitation: Complying with EPR rules will help businesses to avoid possible interruptions of their sales and distribution operations.

4- Cost calculation: Contributions and reporting related to EPR need to be taken into account in order to calculate the cost of product selling in Europe.

Which Businesses Need to Comply with EPR?

EPR obligations can apply to different types of businesses depending on the products they sell, their role in the supply chain and the countries where they operate.

Businesses that may have EPR responsibilities include:

1. Manufacturers

Companies that manufacture products and introduce them into European markets may be responsible for the waste generated by their products and packaging.

2. Importers

Businesses importing packaged products into an EU country may have EPR obligations depending on their role and the applicable national rules.

3. Online Sellers and E-commerce Businesses

Businesses selling products through their own websites or online marketplaces may need to comply with EPR requirements in the countries where they sell.

4. Foreign Businesses Selling Directly to EU Customers

Companies established outside the EU are not automatically exempt. Depending on the country and applicable rules, they may need to register, report packaging quantities and appoint an authorised representative.

The exact responsibilities depend on the business model, product category and destination country.

What Products and Packaging Are Covered by EPR?

EPR covers several categories of products across countries in Europe. Among all the categories, packaging is the most significant category for businesses engaging in e-commerce or foreign business.

The following categories are common:

1- Packaging waste: Cardboard boxes, plastics for packaging, glass packaging, metals for packaging and any other form of material used to package products.

2- Electrical and Electronic Equipment (WEEE): Computers, cell phones, televisions, and domestic electronic equipment.

3- Batteries: Portable batteries, industrial batteries, and vehicle batteries.

4- Other categories: Depending on national regulation, there may also be some other categories like tyres, used oils, and textiles.

For companies selling goods over the internet, packaging is a very important area since even packaging and protective materials that are used for shipping the product could fall under EPR requirements.

How Does EPR Work Across EU Member States?

Although the European Union provides a common regulatory framework, EPR implementation has historically involved country-specific registration systems, reporting procedures, authorised representatives and financial contributions.

This means that registering in one European country does not automatically satisfy EPR requirements in every other country where a business sells.

Businesses may need to:

Identify the EU countries where their products and packaging are being sold.
Determine which EPR categories apply to their products.
Check the relevant national registration requirements.
Register with the appropriate national authority or Producer Responsibility Organisation.
Report the quantity and type of packaging or products placed on the market.
Pay the applicable EPR contributions.
Maintain accurate records and meet reporting deadlines.

The European Commission provides a country-by-country overview of packaging EPR obligations, including national registers and other relevant requirements.

Businesses should check the requirements of each destination country rather than assuming that one registration covers the entire European market.

Understanding the New EU Packaging and Packaging Waste Regulation (PPWR)

One of the most important legislative developments for companies operating in the European market is the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40.

The PPWR became applicable from 11 February 2025, with its primary effective date set for 12 August 2026.

The PPWR creates a more unified legislative basis for packaging and packaging waste in the EU Member States. It targets the reduction of packaging waste, improvement of recyclability, encouragement of reuse and promotion of the circular economy.

Some of the most important points included in the regulation are the following:

Improvement of recyclability of packaging.
Reduction of unnecessary packaging and void space.
Increase in recycled content of plastic packaging.
Encouragement of reusable and refillable packaging.
Improvement of packaging waste collection and recycling.
Introduction of more unified registration and reporting requirements.

In addition to changes in EPR-related requirements, including provisions regarding producer registration and authorised representative, the PPWR introduces some other changes.

Nevertheless, national implementation and existing registration requirements cannot be overlooked. Companies must continue monitoring all information provided by the European Commission and national competent authorities.

What Is the Difference Between EPR and VAT?

EPR and VAT are two separate compliance obligations that businesses may encounter when selling products in Europe. While both can affect the cost and administration of international sales, they serve different purposes.

VAT (Value Added Tax) is a consumption tax applied to goods and services under the relevant country's tax rules. Businesses may need to register for VAT, charge the appropriate rate, collect tax from customers and submit VAT returns.

EPR (Extended Producer Responsibility) is an environmental responsibility framework. It requires eligible businesses to contribute towards the collection, recycling and management of waste generated by the products or packaging they place on the market.

Here is a simple comparison:

VAT (Value Added Tax)	EPR (Extended Producer Responsibility)
A consumption tax	An environmental compliance obligation
Managed by tax authorities	Managed through relevant environmental authorities and compliance organisations
Involves VAT registration and returns	Involves EPR registration, reporting and applicable contributions
Applies according to VAT rules	Applies according to product, packaging and national EPR rules

For businesses selling internationally, managing VAT alone may not be sufficient. They should also assess whether environmental compliance requirements such as EPR apply to their operations.

How Can Businesses Stay EPR Compliant?

Managing EPR obligations across multiple European countries can become complicated, particularly for businesses selling through e-commerce platforms.

A structured compliance approach can make the process easier.

Here are some practical steps businesses should consider:

1. Review Your Sales Markets

Identify every EU country where your business sells or distributes products. EPR requirements can vary between countries.

2. Understand Your Product Categories

Determine whether your products fall under packaging, electronics, batteries or other regulated categories.

3. Complete the Necessary Registrations

Check whether your business needs to register with national authorities or an approved compliance organisation.

4. Maintain Accurate Packaging Records

Keep track of packaging materials, quantities and weights. Accurate information helps with reporting and calculating applicable contributions.

5. Monitor Regulatory Changes

European environmental regulations continue to develop. Regularly review official guidance and country-specific requirements to stay informed.

6. Review Your Overall Tax and Compliance Obligations

EPR should be considered alongside VAT registration, tax reporting and other regulatory responsibilities when planning European expansion.

Final Thoughts

In order to successfully enter the European markets, apart from selling goods and managing VAT, you need to know about the environmental regulations that apply to your products and their packaging. Extended producer responsibility is one of the key parts of the system, which allows making sure that you contribute to proper waste management and recycling.

Due to the implementation of PPWR and changes in national regulations, knowing about EPR requirements becomes crucial for businesses active in the European market. Here at TaxCart, we know that being an international company means dealing with many different taxes and compliance issues. Taking care of them will allow you to concentrate on growing your business while being ready for the challenges of international sales.

Are you planning to take your business to the next level and expand internationally? Contact TaxCart to learn about your international tax compliance requirements.