It depends on the destination country, and the difference is surprising. For domestic French sales, the EPR fee on the primary packaging, the bottle or the jar, is in principle carried upstream by whoever packed the product for the French market: you then declare only the shipping packaging you add. For distance sales to another EU country, the logic is often reversed, because you are the one making that packaging available on that market for the first time. You then carry local EPR on the whole parcel, primary packaging included. Germany, for example, designates as producer whoever first places packaging on the German market on a commercial basis. Online wine merchants and grocers discover this point late, often after a first letter. The rule should be checked country by country before shipping, since the definition of producer leaves Member States their own liability regime.
Read the source article: French EPR authorised representative: who must appoint one