Packaging EPR Marketplace Sellers: France, Germany and Spain

Packaging EPR Marketplace Sellers: France, Germany and Spain must assess obligations by the country where packaged goods are placed on the market, their actual role in the sale and their logistics flow. A marketplace may request registration evidence, but it does not automatically take over your duties. Check national rules before selling or sending stock.

Key takeaways

• Packaging extended producer responsibility (EPR) is assessed country by country, even where you sell the same product through one marketplace.
• The EPR “producer” is often the business first placing filled packaging on a national market, not the manufacturer of the box, bottle or mailer.
• Holding stock in a country, such as an Amazon FBA warehouse in Germany, can create local checks separate from those in your home country.
• A platform may suspend a listing or request a local registration number, but this does not automatically transfer regulatory responsibility from the marketplace seller.
• Regulation (EU) 2025/40 on packaging and packaging waste strengthens the EU framework, while national operational steps still need checking during the transition.

Who is covered by packaging EPR when selling through a marketplace?

You may be covered as soon as your business sells or dispatches packaged products to customers in France, Germany or Spain. The responsible entity is not always the product manufacturer: it depends on who first makes filled packaging available on the national market and on the definitions in each national scheme.

EPR, or extended producer responsibility, makes businesses placing certain products or packaging on the market contribute to waste prevention and management. The historic EU framework comes from Directive 94/62/EC on packaging and packaging waste. It is evolving under Regulation (EU) 2025/40 on packaging and packaging waste, commonly called the PPWR.

Start by identifying the business named on the customer invoice, the party deciding to offer the product for sale, and the party importing or dispatching it. A non-EU company sending a parcel directly to a French consumer may not have the same position as a French distributor buying and reselling an already packaged product.

Common situations

• EU-established seller: you sell packaged goods in your own name to consumers in a particular country. Check whether that country treats you as the business placing packaging on its market.
• Non-EU seller making direct sales: you ship from Shenzhen, the United States or the United Kingdom to an EU customer. National rules may address the distance seller or a local representative, depending on the country and scheme.
• Seller using FBA or a fulfilment provider: the warehouse does not automatically become responsible for your packaging. Local storage can, however, add tax, customs and product-compliance issues to assess in your country-by-country compliance plan.
• EU importer or distributor: if you import packaged goods under your brand or package them before sale, document your role carefully.

Example: imagine a US manufacturer selling branded water bottles on Amazon.fr and Amazon.de. It uses a retail box, an outer shipping carton and, in some cases, packaging added by a fulfilment provider. It cannot assume that German registration covers France: the organisations, registers, declarations and evidence requested are national.

EU Seller Kit — Use the EU Market Entry Compliance Assessment before your first shipment if you need to map packaging, VAT, customs, GPSR, WEEE or battery checks by product and trade flow. The assessment helps identify checks to make; it does not register you with EPR schemes.

What packaging and operations must you review?

Review all packaging associated with the goods you make available: sales packaging, grouped packaging and transport packaging. The correct assessment is therefore not limited to the box the buyer sees.

Packaging generally means an item used to contain, protect, handle, deliver or present goods. The exact classification of particular items, and how they must be declared, can nevertheless depend on national rules and reporting guidance. Keep a packaging record for each product reference showing material, weight, function and destination country.

Separate the packaging layers

Layer	Ecommerce example	What to check
Sales packaging	Headphone box, bottle or pouch	Material and weight placed on the market
Grouped packaging	Film around several units	Whether it forms part of the offer sold
Transport packaging	Shipping carton, void fill and tape	Who supplies it and who dispatches it

You may be responsible for more than one layer. If you dispatch orders yourself, include your shipping carton and void fill in the assessment. If the marketplace or fulfilment provider prepares the parcel, ask contractually who supplies those materials, who declares them and for which scope. A fulfilment invoice alone does not establish the legal allocation of responsibility.

The PPWR is intended to progressively harmonise EU packaging requirements. This does not mean that you can wait for every measure to apply before dealing with current national obligations. For present sales, check requirements in the destination country, the storage country and, where relevant, the import country.

If your product is electrical, contains a battery or falls within another product stream, packaging EPR may sit alongside separate obligations. Directive 2012/19/EU on waste electrical and electronic equipment and Regulation (EU) 2023/1542 on batteries and waste batteries are distinct frameworks. Do not treat packaging registration as WEEE or battery registration.

When do packaging EPR duties apply in France, Germany and Spain?

Obligations apply before or when goods are placed on the market under national rules; do not wait for a marketplace block before checking your position. Cross-border selling requires a separate assessment for every country you target.

France: check the packaging stream and sorting information

In France, household packaging is subject to an extended producer responsibility scheme. Depending on your role, you may need to join an approved producer-responsibility organisation, report packaging placed on the market and contribute to the scheme. Confirm the operational requirements with the relevant organisation and French authorities.

Sorting information is a related but separate issue. For packaging in scope, check the rules on the Triman mark and Info-tri information before printing packaging or publishing product images. See the practical checks in our guide to France’s Triman logo and Info-tri requirements.

Example: a Spanish brand sends packaged cosmetics directly to French consumers. Marketing the product in Spain does not automatically remove the need to review French packaging duties and sorting information.

Germany: LUCID registration and system participation

In Germany, the Packaging Act, VerpackG, requires relevant businesses to register in the LUCID register and, for certain packaging subject to system participation, to participate in an approved system and submit the related declarations. Marketplaces may request registration data and check its consistency before keeping a listing active.

A frequent misunderstanding is that a LUCID number alone is always enough. Registration, system participation and declarations are separate elements to assess according to your packaging and activity. Our guide to LUCID and VerpackG registration in Germany explains what to prepare before listing products or sending FBA stock.

Spain: check the register and producer responsibility

Spain also applies an extended producer responsibility regime for packaging. Obligations can include registration in the Register of Product Producers, joining a collective or individual system, and supplying data according to the packaging type and your activity. Check the required steps with the competent authorities, including the Spanish Tax Agency electronic office where your flows also involve tax or customs formalities.

The same company may need a separate identifier or evidence in each country. Do not reuse a French or German number as if it had EU-wide effect: national registers are not interchangeable.

How do you make marketplace sales compliant step by step?

The safest approach is to map your flows before choosing a scheme or submitting a number to a marketplace. This prevents you from declaring the wrong entity, omitting shipping packaging or registering in a country that does not match your role.

Practical procedure

1. List your actual sales and storage countries. Separate the customer’s country, warehouse country and dispatch country. Amazon Pan-EU, for example, can distribute stock across several Member States; review the compliance duties to plan for with Amazon Pan-EU.
2. Identify the entity placing packaged goods on each market. Record the contractual seller, importer, brand owner, fulfilment provider and invoice issuer. Logistics contracts can clarify allocation, but they do not replace the national legal definition.
3. Create a packaging inventory by SKU. For every product reference, record the material and weight of the box, pouch, inserts, void fill and shipping carton. Separate packaging supplied by you from packaging supplied by the platform.
4. Check the applicable national scheme. Identify the register, producer-responsibility organisation or system, the declarations required and the evidence to retain. Where scope is uncertain, seek confirmation from the authority or a qualified local adviser before filing.
5. Register and contract where required. Complete the process in the name of the correct entity. Keep evidence, identifiers and membership terms in a file your marketplace team can access.
6. Provide marketplace data carefully. Enter only data that matches the requested country and entity. Incorrect information can lead to a removed listing or a request for supporting evidence.
7. Report and update volumes. Set an internal calendar showing the reporting period, data source, person approving the figures and evidence archive.

Checklist before publishing a listing or sending stock

• I have identified the destination, storage and dispatch countries for every flow.
• I have determined which entity sells, imports and places filled packaging on the market in each country.
• I have separated sales, grouped and transport packaging.
• I have asked my fulfilment provider or marketplace who supplies and declares shipping packaging.
• I have checked applicable national requirements in France, Germany and Spain.
• I have retained registration, membership and declaration evidence, together with packaging-weight data.
• I have checked the information entered in marketplace portals before publication.

If you import stock into the European Union yourself, add customs and VAT to this sequence. Regulation (EU) No 952/2013, the Union Customs Code governs customs formalities, while VAT rules are based on Council Directive 2006/112/EC. Use the EU VAT calculator to compare domestic, intra-EU and import VAT scenarios; it does not replace validation of your tax treatment.

EU Seller Kit — Before sending a consignment to an EU warehouse, the customs cost simulator helps structure known import costs, while the HS classification assistant generates candidate subheadings to confirm in the CN or TARIC.

What documents and data should you keep?

You should be able to show that your assessment, declarations and marketplace information are consistent. Exact documents depend on the country and scheme, but a reliable packaging database materially reduces errors during an inspection or platform request.

Keep at least:

• the full identity of the registered entity and its role in the sales chain;
• registration, membership or system-participation evidence;
• identifiers supplied to marketplaces, clearly linked to the relevant country;
• submitted declarations, acknowledgements and calculation records;
• technical specifications or packaging schedules showing materials and weights;
• contracts with the manufacturer, importer, order-preparation provider and logistics provider;
• invoices and sales data that allow declared volumes to be reconciled;
• packaging artwork and sorting-information materials where they are required.

Do not confuse this EPR file with the product-compliance file. A toy, electrical appliance or cosmetic can require additional safety and conformity documentation. For instance, a CE-marked product must meet the applicable sector legislation; the official Your Europe guidance on CE marking confirms that the manufacturer remains responsible for conformity assessment and the required documentation.

Before publishing a listing, also check the product information required for distance sales. Regulation (EU) 2023/988 on general product safety includes information duties for distance offers. The Marketplace Product Compliance Scanner helps flag traceability, safety and compliance information to verify before publication; it does not replace an assessment of national packaging EPR duties.

How much work is involved, and which mistakes should you avoid?

Packaging EPR is not simply a matter of obtaining a number. It requires reliable packaging data, a clear allocation of roles and periodic follow-up. The workload rises with the number of countries, SKUs, sales channels and logistics providers involved.

What takes real work

The first task is gathering data. A supplier may give you the weight of the retail box but not know the weight of the shipping carton used by your warehouse. You may need to weigh samples, request specifications or apply a consistent documented method in line with the relevant scheme’s guidance.

The second task is organisation. Assign someone to maintain SKU data, sales by country and supplier changes. Any change in format, material or packing configuration can alter your reporting data.

Finally, build a review into every new market launch. A listing that works in France is not automatically ready for Germany or Spain. Check duties before enabling delivery to a new country, rather than after a listing suspension.

Frequent mistakes

Assuming the marketplace is always responsible. Some platforms have their own cooperation or checking duties, but this does not automatically make them the producer in your place. Regulation (EU) 2019/1020 on market surveillance and product compliance governs, among other matters, market surveillance and cooperation in the supply chain.

Reporting only the visible packaging. The shipping carton, void fill and materials added during fulfilment can be relevant. Document who supplies them and in which country they are used.

Using an identifier from another country. A German LUCID number does not demonstrate French or Spanish compliance. Link every identifier to its register, entity and scope.

Mixing EPR, VAT and product compliance. These matters meet in your operation, but their authorities, registers and evidence differ. For an overview by sales channel, read our guide to marketplace compliance in Europe.

Waiting for an account block. A request for evidence often arrives at the worst time: a product launch, stock arrival or busy sales period. Prepare the file before activating a country.

Which special cases need extra attention?

Special cases do not necessarily remove packaging EPR duties; they make it harder to identify the responsible party and the packaging in scope. If your model combines imports, distance sales, multi-country stock and regulated products, document your assessment before sales begin.

Direct sales from outside the EU

If you dispatch directly from China or the United States to an EU consumer, review packaging duties, VAT and customs formalities together. IOSS may apply to certain distance sales of imported goods, but it does not replace EPR duties. The European Commission explains OSS and IOSS; obtain tax advice where your model involves several countries or platforms.

Amazon FBA stock spread across several Member States

Amazon may store goods in several countries depending on the programme you choose. Assess every storage and market-placement country rather than assuming the country of your seller account is the only relevant one. Our guide to sending Amazon FBA stock into Europe helps connect this preparation with EORI, customs and VAT steps.

Reusable or returnable packaging

Reusable, returnable or refillable packaging may be subject to specific rules. Do not automatically classify it as exempt: check the national definition, reporting method and evidence expected by the relevant system.

Regulated products and safety information

Packaging EPR does not make a product compliant with product-safety law. If you sell a charger, toy or connected device, identify the applicable product legislation, marking requirements, documentation and information to display. For non-EU manufacturers of CE-marked products, a CE authorised representative can be appointed only after acceptance, entity assignment, a signed written mandate and active payment. This service does not replace the manufacturer’s conformity assessment, testing, technical documentation or EU declaration of conformity.

Tools and services to take action

• EU Market Entry Compliance Assessment: use it before a first shipment or new-country launch to build a checklist covering packaging EPR, VAT, customs, GPSR, CE marking and product-specific streams.
• Country Compliance: use this tool to organise customs, tax and product checks by your countries of origin, storage and destination.
• Marketplace Product Compliance Scanner: use it before publication to review safety, traceability and compliance information to verify on a product listing; it does not complete EPR registrations.
• EU VAT calculator: use it where packaged-goods sales involve imports, local stock or cross-border supplies and you need to compare VAT scenarios.
• EU Seller Kit pricing and plans: review SaaS options and add-on services relevant to your situation, without assuming that a subscription completes an EPR registration or appoints a representative.

Frequently asked questions

Can a marketplace manage packaging EPR for me?

Not automatically. A marketplace may collect information, require an identifier or apply local restrictions, but your responsibility depends on your role and national law. Check the platform terms and the relevant national scheme before treating a step as covered.

Must I register in every country where I deliver?

It depends on the national definition of producer, your sales model and your packaging. Distance sales into a country can create duties even without a local establishment. Assess France, Germany and Spain separately, then seek confirmation from the relevant organisation or authority if you are unsure.

Is Amazon shipping packaging my responsibility?

The answer depends on who supplies the packaging, the fulfilment arrangement and the country’s rules. Do not assume it is covered merely because Amazon prepares the parcel. Ask the provider for written clarification and retain it in your compliance file.

Is a German LUCID number valid in France or Spain?

No. LUCID belongs to the German packaging regime and does not replace French or Spanish steps. Each country may require its own registration, system participation, declarations and evidence.

Does packaging EPR replace GPSR or CE obligations?

No. Packaging EPR concerns the end-of-life management of packaging, whereas GPSR and CE rules concern product safety, conformity and product information. A product can be properly registered for packaging while still failing safety or marking requirements.

What should I do if I do not know my packaging weights?

Ask your manufacturer and fulfilment provider for specifications, then check them against samples where necessary. Create an SKU record listing materials and weights for each packaging layer. Where a national scheme prescribes a calculation or reporting method, follow that method and retain your sources.

Official sources

• Directive 94/62/EC on packaging and packaging waste — the historic EU framework for packaging and packaging waste.
• Regulation (EU) 2025/40 on packaging and packaging waste — the PPWR and the evolving EU framework for packaging.
• Regulation (EU) 2019/1020 on market surveillance and compliance of products — market surveillance and cooperation in the product supply chain.
• Regulation (EU) 2023/988 — General Product Safety Regulation — safety and distance-selling information duties for product offers.
• Directive 2012/19/EU on waste electrical and electronic equipment — the WEEE framework, separate from packaging EPR.
• Regulation (EU) 2023/1542 on batteries and waste batteries — battery rules that are separate from packaging obligations.
• Regulation (EU) No 952/2013 — Union Customs Code — customs rules relevant where you import stock into the European Union.
• Council Directive 2006/112/EC on the common system of VAT — the VAT framework for sales and import transactions.

This content provides general information and is not legal advice.