Packaging EPR in Europe: who can support a brand selling in several countries?

A French producer responsibility organisation (PRO, éco-organisme in French) covers France only. Since 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has set common rules on extended producer responsibility (EPR), but registration and contribution remain country by country. A brand that sells in France, Germany and Italy is therefore subject to 3 separate systems, each with its own register, its own organisation and its own marking rules.

In each country, 2 questions decide the workload: who holds what, and who can act in place of the brand.

1Is packaging EPR European or national?

It is both. The Regulation sets out who is a producer, where it registers and who represents it when it sells from another country. Collection, the organisations that fund it and their fee schedules remain organised by each Member State.

A registration in each country of sale

The producer registers in the register of each Member State where it first makes packaging available, and cannot sell there until it or its authorised representative is registered (Article 44). When a PRO acts on its behalf, the PRO in principle meets this obligation, unless the Member State decides otherwise. The common format of these registers is still awaiting its implementing act: according to the Commission FAQ, producers will report for the first time under these harmonised rules on 1 June 2030.

An authorised representative for direct sales in another country

A producer that sells directly to end users in another Member State appoints there, by written mandate, an authorised representative for EPR (Article 45). On 10 December 2025, the Commission proposed suspending this obligation until 1 January 2035 (COM(2025) 982). The European Parliament is expected to vote on the text in plenary on 20 October 2026, and the Council would still have to agree for it to apply. Until then, the obligation stands. France imposes it anyway under its own law, as our article on the authorised representative for EPR in France explains.

Online marketplaces and fulfilment providers

An online marketplace asks the seller for its registration number in the consumer's country, and for a self-certification of EPR compliance, before admitting it (Article 45). In France, that number is the unique identifier (identifiant unique, or IDU, also known as the unique identification number or UIN), issued by ADEME, the French Agency for Ecological Transition. An order fulfilment provider, which stores and ships for the brand, receives the same information when the contract is signed. If this information remains inaccurate or incomplete, the provider suspends its service for the sales concerned.

2How do packaging EPR rules differ between countries?

National rules differ on what matters most to a brand: who keeps the register, who collects the contribution and what the packaging must carry. The 3 major markets below show this, as at 17 October 2026.

France: unique identifier, PRO and Triman

The producer joins an approved PRO, which registers it in the register kept by ADEME: it receives a unique identifier (Article L. 541-10-13 of the French Environmental Code). Its household packaging carries the Triman logo and the Info-tri sorting information, which tell consumers where to dispose of each component, except glass beverage packaging (Article L. 541-9-3). Since 10 July 2026, a producer not established in France appoints an authorised representative there, who takes over its EPR obligations (Article L. 541-10-9-1). Finally, EPR for professional (B2B) packaging starts on 1 January 2027, according to the announcement of the Ministry of Ecological Transition on 28 July 2026.

Germany: the LUCID register and dual systems

Since 12 August 2026, the act implementing the Regulation (VerpackDG) has replaced the former Packaging Act. The producer registers in the LUCID register of the ZSVR foundation (Zentrale Stelle Verpackungsregister) before first making packaging available, and now also declares its transport and professional packaging there. Packaging that ends up with households takes part in a dual system (a German scheme for household packaging), chosen by the producer. Above thresholds set by material, 80 tonnes for glass for example, the producer files each year, before 15 May, a completeness declaration verified by an expert.

A brand with no establishment in Germany that sells to end users appoints, since 12 August 2026, a single authorised representative, by written power of attorney in German. LUCID registration nevertheless remains its own personal obligation, as the foundation that keeps the register points out, and the law prohibits entrusting its performance to a service provider (§ 5). Fines go up to €100,000 for failure to register and €200,000 for failure to take part in a system (§ 66). No national marking is required: material codes remain optional (§ 4).

Italy: CONAI and the environmental label

Packaging producers and users join the national consortium CONAI (Article 221 of Legislative Decree 152/2006), unless a recognised independent system applies, and pay its environmental contribution, calculated per tonne by material. Since 1 January 2023, all packaging carries an environmental label indicating the nature of its materials, using the codes of Decision 97/129/EC (Article 219). For imported packaging, the contribution is payable by the importer, unless the foreign brand has itself joined CONAI, the consortium states.

Towards a common European label

National labels have an end date. According to the Commission guidance document, Member States will no longer be able to keep their labels alongside the European harmonised label after 12 August 2028, or 24 months after the act that defines it if that comes later. The material codes of Decision 97/129/EC remain applicable until that date. For a brand that prints its packaging for several countries, each reprint between now and then is an opportunity to leave room for this label.

The symbol showing that packaging is covered by EPR is also changing medium. By 12 February 2027 at the latest, it is displayed only in a QR code or other digital marking (Article 12), and the Commission reads this as a ban on physical labels of this kind.

3Who can support a brand across several countries?

The Regulation reserves this support to no profession. Before choosing who, you need to know what: the workload is measured in requirements to maintain, country by country.

The 5 requirements to maintain in each country

In each country of sale, the brand maintains the same 5 requirements, which are never fulfilled in the same way:

• The national register, with a number specific to the country: unique identifier in France, LUCID number in Germany, CONAI membership in Italy.
• The contract that funds collection, with a PRO in France, a dual system in Germany and the consortium in Italy, each with its own fee schedule.
• Quantity declarations, by material and by period, whose calendar differs from one country to another, such as the German completeness declaration, due before 15 May.
• Packaging marking: Triman and Info-tri in France, environmental label in Italy, no mandatory marking in Germany.
• The local authorised representative when the brand sells directly from abroad, with a written mandate and, in Germany, a power of attorney drafted in German.

The count grows quickly: a French brand that adds Germany and Italy goes from 4 requirements to 13. The declared quantities must also remain consistent from one country to another: the same product references, split by destination country, and not estimates made separately for each organisation.

The roles that complement each other

None of the 4 roles involved covers all these requirements alone:

• The PRO, dual system or consortium funds collection and receives quantity declarations, but only for packaging placed on the market in its own country.
• The authorised representative takes on the brand's EPR obligations in a country where it is not established; the same provider can act in several countries, with one mandate per country.
• The compliance or consulting firm maps obligations country by country, organises the quantity data and links EPR to the Regulation's other requirements.
• The lawyer settles questions of classification, for example who is the producer when a brand sells through a distributor, an online marketplace or a fulfilment provider.

The one non-negotiable criterion: the right contact links each step to a legal text and to a country. It knows that the French unique identifier is worth nothing in Germany, that LUCID registration cannot be delegated, and that a sale through an online marketplace does not exempt the brand from registering in the consumer's country. It also knows the Regulation's other obligations, from the EU declaration of conformity to the technical documentation and its supplier evidence, including the banned packaging formats, which go through no national organisation.

Questions to ask

Before entrusting this work, 4 questions let you compare 2 offers:

• Which countries are covered in-house, and which go through a local partner, whose name and mandate the brand will know?
• Who holds the register identifiers and the portal access, and how does the brand recover them at the end of the contract?
• How are quantities by country calculated from sales, and who validates each declaration before it is sent?
• Does the service track rule changes, such as the switch to the VerpackDG in Germany, the vote on the European authorised representative requirement or the future harmonised label?

Warning signs

Some offers promise what the texts do not allow:

• A "European EPR compliance" sold as a single registration, when each Member State keeps its own register and its own organisations.
• A provider offering to register with the LUCID register or to file the data declarations there in place of the brand, when German law reserves them to the brand, unless an authorised representative is appointed (§ 5).
• Flat-rate quantity declarations, unconnected to actual sales by country, by product reference and by packaging material.

A useful deliverable links each finding to a specific obligation and a country, and says what remains to be done.

4What are the steps, and how much does packaging EPR cost abroad?

A compliance programme in several countries follows the same order everywhere: qualify the brand's role in each country, register, sign with the organisation, declare, then adapt the marking. The order matters, because registration conditions the sale: without it, the brand cannot make its packaging available in the country.

Deadlines at the end of 2026

In Germany, participation contracts with the systems concluded under the former law cease to apply by 31 December 2026 at the latest (§ 68 of the VerpackDG). In France, the ministry asks each producer of professional packaging to have joined a PRO by the end of the year. The PPWR timeline sets out the European deadlines that follow.

Contributions, on public fee schedules

Contributions are calculated on public fee schedules, which differ from one country to another. CONAI's gives the measure: at 1 October 2026, a tonne of steel packaging costs €5 and a tonne of glass €40. For plastic, the rate runs from €51 to €922 per tonne, depending on a category determined by how the packaging is sorted and recycled. The fee schedules of the French PROs are detailed in our guide to EPR schemes.

To fix ideas, take a constructed example: 2 tonnes of plastic packaging placed on the Italian market cost €102 in category A1.1, the cheapest, and €1,844 in category C, the most expensive. The same tonnage therefore costs 18 times more depending on the category, which makes packaging eco-design a cost lever as much as a compliance one.

The price of support

There is no public price list for coordinating EPR across several countries, or for the authorised representative mandate. The cost depends on the number of countries, the number of product references and materials, and the quality of the sales data available.

5What should you prepare before getting support?

Support goes faster when the brand arrives with its data. The items to gather:

• The list of countries of sale, with for each the channel used: direct sales, local distributor, online marketplace or fulfilment provider that stores goods on site.
• Quantities sold by country, by product reference and by period, which make it possible to reconstruct the packaging tonnages to declare in each country.
• The packaging bill of materials for each product reference, with the weight and material of each component, from the shipping carton to the label.
• The numbers and contracts already obtained in each country, with portal access, signed mandates and renewal dates.
• The packaging artwork, to check markings country by country before the next print run.

The "Am I affected by the PPWR?" test helps to qualify the brand's role. For a small brand, our article on micro-enterprises and creators details the French obligations, and our PPWR guide covers the rest of the Regulation.

For us at Projet Celsius, EPR in several countries is managed first as a data problem: reliable quantities by country, an up-to-date packaging bill of materials, and a table that links each obligation to its country and its deadline. We recommend starting with the countries of direct sales, since that is where an authorised representative is required, then handling marking at the next reprint. Our PPWR support service links this mapping to the Regulation's other requirements, such as the recycled content of plastic packaging.

6Key takeaways

• Packaging EPR remains national, with a register, a contract and declarations in each country of sale.
• Since 12 August 2026, a brand that sells directly in another Member State appoints an authorised representative there, unless a suspension is adopted.
• Rules diverge from one country to another, from the French unique identifier and Triman to the German LUCID register and the Italian CONAI.
• No single provider covers these obligations alone: the organisation acts only in its own country, and the authorised representative, the firm and the lawyer complement each other.

The French obligations of each scheme are detailed in our guide to EPR schemes, and the case of a seller established outside France in our article on the authorised representative for EPR.

Further resources

Frequently asked questions

1Is packaging EPR European?

It is framed by a European regulation, Regulation (EU) 2025/40, but it applies country by country. The producer registers in each Member State where it first makes packaging available, and funds collection in each, with that country's organisation. No single registration or contract covers the whole Union.

2Do you need an authorised representative in every EU country?

A producer that sells directly to end users in another Member State must appoint an authorised representative there since 12 August 2026 (Article 45 of the Regulation). The Commission proposes to suspend this obligation until 2035; the European Parliament is expected to vote on the text on 20 October 2026, and the Council would still have to agree. France imposes it anyway under its own law. In Germany, the obligation rests on the Regulation: for a brand established in the Union, it would fall with the suspension.

3What is the LUCID register?

It is the German packaging register, kept by the ZSVR foundation. Any producer that makes packaging available in Germany registers there before the first sale, including, since 12 August 2026, for its transport and professional packaging. Registration remains the producer's own obligation, even when it has appointed an authorised representative.

4Can a French PRO cover Germany or Italy?

No. A PRO approved in France covers packaging placed on the French market. In Germany, the brand takes part in a dual system; in Italy, it joins CONAI, or the importer pays the contribution. A provider can coordinate several countries, but the obligations are still met country by country, with each organisation.

5How much does packaging EPR cost in Italy?

CONAI's environmental contribution is calculated per tonne by material. At 1 October 2026, it is €5 per tonne for steel and €40 for glass. It runs from €51 to €922 per tonne for plastic, depending on its recyclability category, and from €45 to €285 for paper and board. The full fee schedule is published by CONAI.

6Is the Triman logo mandatory across Europe?

No. The Triman and Info-tri are French obligations. Italy imposes its own environmental label, Germany no national marking. The European regulation provides for a harmonised label, from 12 August 2028 at the earliest; according to the Commission, Member States will no longer be able to keep their national labels alongside it.

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