EPR obligations, country by country
Every French EPR stream in one table, plus the packaging, electricals, battery and textile registers a cross-border seller must know across the EU and the UK. Built from official sources and reviewed by our team.
All information reviewed in July 2026 against official sources (ecologie.gouv.fr, ADEME, EUR-Lex, national registers and gov.uk).
France: every EPR stream
France runs the widest EPR system in Europe under the AGEC law. Each stream requires registration in ADEME's SYDEREP register, a UIN (Identifiant Unique) per stream displayed in your terms and on your site, and declarations of the quantities placed on the French market.
| Stream | What it covers | Mandatory | Declarations | Worth knowing |
|---|---|---|---|---|
| Household packaging & graphic papersEMPAP | All packaging around products sold to French consumers (parcel boxes, filler, bags) plus graphic papers. | 1993 / 2007 | Annual; flat-rate option for small volumes | Every shipping box or filler you add to a consumer parcel counts and must be declared. |
| Electrical & electronic equipment (WEEE)EEE | All electricals sold to French users: phones, small appliances, chargers, lamps, e-toys, IT gear. | 2006 | Quarterly or annual (eco-organism schedule) | Distance sellers must appoint a French authorised representative (WEEE Directive Art 17). |
| BatteriesBAT | All batteries including those inside devices: portable, e-bike/e-scooter (LMT), SLI, industrial, EV. | 2001; all EU categories since Aug 2025 | Annual tonnage declaration | Batteries shipped inside products count too; an authorised representative is required for distance sellers (EU Reg 2023/1542). |
| Textiles, household linen & footwearTLC | Clothing, home linen and shoes sold to French households, including marketplace and dropship sales. | 2007 | Annual declaration of prior-year units | Applies from the first garment sold; obtain the UIN before listing on marketplaces. |
| Furniture & furnishing elementsEA | Furniture and furnishings: chairs, desks, shelving, mattresses, garden furniture, including flat-pack. | 2013 | Annual; larger volumes often quarterly | Fees are per item or per kg by furniture category; covers B2C and B2B furniture. |
| DIY & garden articlesABJ | Non-electric DIY and garden products: hand tools, thermal garden machines, pots, barbecues, ladders. | 2022 | Annual declaration | Powered tools fall under EEE instead; check each SKU's stream before declaring. |
| Sports & leisure articlesASL | Sport and leisure gear: bicycles, balls, tents, fitness and camping equipment sold B2C. | 2022 | Annual declaration | Classic bikes are ASL; e-bikes also trigger EEE and battery obligations. |
| ToysJOUET | Toys and games sold to French consumers, a core marketplace category. | 2022 | Annual declaration | Electronic toys owe EEE and battery contributions on top of the toy fee. |
| Household chemical productsPCHIM | Household chemicals leaving hazardous residues: paints, solvents, glues, garden chemicals. | 2013 | Annual declaration | Fees vary by hazard class and container size; check transport rules too. |
| Building & construction productsPMCB | Construction products and materials for buildings: insulation, tiles, joinery, plaster, cement. | 2023 | Periodic, often quarterly | Triggered even for B2B online sales of building materials shipped to France. |
| TyresPNEU | Tyres sold alone or fitted on vehicles and equipment placed on the French market. | 2004 | Annual declaration | Selling tyres or tyred equipment online to France makes you a producer. |
| Lubricant oilsLUB | Mineral and synthetic lubricants: motor oil, hydraulic and industrial oils sold to French users. | 2022 | Annual declaration | Applies to oils sold via marketplaces; declared per tonne placed on the market. |
| Unused medicinesMNU | Human medicines (take-back of unused medicines via pharmacies). | 2009 | Annual declaration | Concerns pharma marketing-authorisation holders; rarely relevant to general ecommerce. |
| Tobacco productsTABAC | Tobacco products with filters (cigarette-butt litter clean-up). | 2021 | Annual declaration | Distance selling of tobacco into France is itself prohibited; the stream targets the domestic supply chain. |
| Recreational & sport boatsBPS | Pleasure and sport boats placed on the French market (end-of-life dismantling). | 2019 | Annual declaration | The fee is due on the boat's first sale in France; register in SYDEREP before selling. |
| Perforating medical devices (sharps)DISP-MED | Sharps for self-treating patients: needles, pens, lancets sold with or as medical products. | 2012 | Annual declaration | Targets makers of self-treatment sharps, including online pharmacies shipping to France. |
| Vehicles (ex-VHU)VEHICULE | Cars, vans, 2-3 wheelers and quadricycles placed on the French market (end-of-life vehicles). | 2024 | Annual declaration (SYDEREP vehicle register) | Vehicle importers count as producers; one eco-organism plus many individual systems exist. |
| Professional (B2B) packagingEPRO | Packaging of products consumed or used by professionals: industrial, commercial and B2B parcel packaging. | 2026 | Annual declaration expected | Full start postponed in June 2026 to 1 Oct 2026 or 1 Jan 2027; restaurant packaging already applies. |
| Single-use sanitary textiles (wipes)TSUU | Pre-moistened wipes for body and household use: cosmetic, baby and cleaning wipes. | 2025 | Annual declaration | Cosmetics and cleaning brands selling wipes to France must join since July 2025. |
- Since 2022 every producer needs one UIN per stream, issued by ADEME through SYDEREP; it must appear in your terms and conditions and on your website (art. L541-10-13).
- Marketplaces must take over the producer obligations of non-compliant third-party sellers (art. L541-10-9), so platforms suspend listings without a valid per-stream UIN.
- A foreign seller can appoint a French mandataire to register, declare and pay for it; for electricals and batteries an authorised representative is mandatory, and the foreign producer remains legally liable.
- Fines reach €7,500 per unit or tonne for unmet obligations and up to €30,000 for a missing SYDEREP registration or UIN display, with possible daily penalties.
EPR across the EU and the UK
The registers a foreign ecommerce seller must know, stream by stream. Packaging, electricals (WEEE) and batteries are mandatory in every EU country; textiles EPR is live in a growing list and EU-wide by April 2028.
| Country | Packaging | Electricals (WEEE) | Batteries | Textiles | Worth knowing |
|---|---|---|---|---|---|
| Austria | EDM register + accredited scheme; Austrian AR mandatory for foreign distance sellers since 2023, no threshold | EDM/EAK register; Austrian AR mandatory | EDM register; Austrian AR mandatory | Not yet (EU-wide EPR due by April 2028) | No de minimis: AR and EDM registration must be in place before the first sale; marketplaces ask for an Austrian licence number. |
| Belgium | Register via the Interregional Packaging Commission + accredited scheme (300 kg de minimis); AR mandatory from Aug 2026 | Regional registration + annual BeWeee reporting; Belgian AR mandatory for distance sellers | Accredited scheme with regional approval; Belgian AR mandatory | Not yet (EU-wide EPR due by April 2028) | Three regions, no single portal: packaging via the IRPC, WEEE via BeWeee with regional deadlines between 31 May and 1 July. |
| Bulgaria | ExEA producer register from the first unit (no threshold); direct registration today, AR from Aug 2026 | ExEA producer register; AR required for foreign distance sellers | ExEA register; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | Registration needs a Bulgarian qualified e-signature; without eco-organism cover the punitive product fee applies, and records are kept monthly. |
| Croatia | EPRR register (FZOEU, via NIAS); AR mandatory without a Croatian OIB | EPRR register; AR mandatory; monthly reporting | EPRR/RPPO register; AR mandatory; monthly reporting (by the 20th) since 2025 | Not yet (EU-wide EPR due by April 2028) | Registration is retroactive: FZOEU expects declarations for everything placed on the Croatian market since sales began. |
| Cyprus | Producer register at the Department of Environment + accredited collective scheme | WEEE register at the Department of Environment; AR required for distance sellers | Batteries register; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | AR procedures are patchy in practice, so registration of foreign sellers is slow: start early. |
| Czechia | Accredited-scheme contract under the Packaging Act; local AR needed for foreign distance sellers | Ministry of Environment producer list; AR mandatory for distance sellers | Same ministry producer list; AR mandatory | Not yet (EU-wide EPR due by April 2028) | AR and scheme contract before the first parcel; quarterly reporting. The small-packaging exemption needs under 300 kg AND under CZK 25M turnover, and never covers WEEE or batteries. |
| Denmark | Danish Producer Register (DPA), packaging live since Oct 2025; AR mandatory without a Danish CVR | DPA register; Danish AR mandatory for foreign distance sellers | DPA register (rules refreshed Aug 2025); Danish AR mandatory | Not yet (EU-wide EPR due by April 2028) | Sellers without a Danish CVR must act through an AR, and quantities are reported in advance as a forecast. |
| Estonia | PAKIS packaging register; Estonian AR required for foreign sellers | PROTO register; registration only through an Estonian AR | PROTO register; Estonian AR mandatory | Not yet (EU-wide EPR due by April 2028) | Register access needs an Estonian e-ID, in practice handled by the AR; missed recovery targets trigger the packaging excise duty. |
| Finland | National producer register (LVV, ex-Pirkanmaa ELY, since 2026); AR optional until Aug 2026, then mandatory | Same national register; Finnish AR mandatory for foreign EEE sellers | Same register; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | The old €1M packaging turnover threshold is gone: even small foreign sellers are in scope from the first parcel. |
| France | SYDEREP (ADEME); one UIN per stream; mandataire option | SYDEREP; French AR mandatory for distance sellers | SYDEREP; AR mandatory since Aug 2025 | Live since 2007 (the pioneer) | See the full stream-by-stream table above: 19 streams, the widest EPR system in Europe, with marketplaces checking your UIN per stream. |
| Germany | LUCID register (ZSVR): registration is personal, no delegation, plus a dual-system contract; German AR mandatory from Aug 2026 (except registration) | stiftung ear register; foreign sellers cannot self-register, German AR mandatory | stiftung ear battery register; German AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | Marketplaces and fulfilment providers must verify LUCID and WEEE numbers and block non-compliant sellers; fines reach €100,000. |
| Greece | EMPA national producer register; Greek AR mandatory | EMPA register (WEEE section); AR mandatory for distance sellers | EMPA register (batteries section); AR mandatory | Not yet (EU-wide EPR due by April 2028) | The EMPA number must be printed on every invoice and receipt; fines of €100 to €5,000 for omitting it. |
| Hungary | OKIR register + MOHU partner portal; foreign webshops act only via a mandatory Hungarian AR | OKIR/MOHU registration; AR mandatory | OKIR/MOHU registration; AR mandatory | Live since 2023 | No de minimis; quarterly declarations with 8-digit KF codes due by the 20th after quarter end, and misclassification triggers audits. |
| Ireland | Approved-scheme system; from Aug 2026 distance sellers need registration + an Irish AR | Producer Register Ltd (PRL); Irish AR mandatory for foreign distance sellers | PRL register; Irish AR required for distance sellers | Not yet (EU-wide EPR due by April 2028) | Reporting is MONTHLY: WEEE and battery producers file to the PRL Blackbox by the 19th of each month. |
| Italy | CONAI registration + declarations; Italian AR mandatory for foreign distance sellers | Registro AEE; Italian AR mandatory for distance sellers | Registro Pile e Accumulatori; Italian AR mandatory | Adopted in draft; launch targeted 2026 | Three separate registrations (CONAI, Registro AEE, Registro Pile), each via an Italian AR; packaging declarations become quarterly or monthly as volumes grow. |
| Latvia | TULPE register (State Environmental Service); registration from 300 kg/yr; AR optional until Aug 2026 | Producer register run by LETERA (elektroregistrs.lv); AR mandatory for distance sellers | LETERA register; AR mandatory since Aug 2025 | Live since 2024 | Textiles EPR runs through the Natural Resources Tax: without an accredited scheme contract the punitive full-rate tax applies, and foreign online sellers routinely miss it. |
| Lithuania | GPAIS register from the first delivery (eco-fee from 0.5 t); direct registration allowed, AR from Aug 2026 | GPAIS producer register; AR needed for non-established sellers | GPAIS register; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | Not one annual filing: GPAIS requires ongoing Lithuanian-language journal bookkeeping plus the annual declaration within 50 days of year-end. |
| Luxembourg | Accredited scheme + reporting to the Administration de l'environnement; AR mandatory from Aug 2026 | e-RA producer register; AR required for non-established distance sellers | Accredited battery scheme (portable); e-RA approval for industrial/EV; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | A small market often skipped entirely: deadlines vary by stream (WEEE 30 April, batteries 30 June, packaging via the scheme by end February). |
| Malta | ERA producer register; no volume exemption for cross-border sellers; local AR needed | ERA WEEE register; AR mandatory for all distance sellers | ERA batteries register; AR mandatory unless established in Malta | Not yet (EU-wide EPR due by April 2028) | ERA registration must be renewed every year even for tiny volumes; under 100 kg you get a simplified declaration, not an exemption. |
| Netherlands | Verpact (single national scheme); fees from 50,000 kg (0 kg for single-use plastics); AR mandatory from Aug 2026 | National (W)EEE Register; Dutch AR mandatory for foreign distance sellers | National battery register; Dutch AR mandatory since Aug 2025 | Live since 2023 | UPV Textiel is live since July 2023: foreign fashion sellers must appoint a Dutch AR and file annual reports, and many miss it. |
| Poland | BDO register, no threshold; AR mandatory from Aug 2026 | BDO register; AR mandatory for foreign B2C sellers, no exceptions | BDO register; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | The BDO number must appear on invoices, and marketplaces block accounts without a valid one from August 2026: register by mid-July. |
| Portugal | APA producer register via SILiAmb; AR mandatory for distance sellers | SILiAmb register (APA); AR mandatory | SILiAmb register; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | SILiAmb access requires a Portuguese NIF, so the AR must be appointed before any registration or sale. |
| Romania | AFM (Environmental Fund) producer register; Romanian AR mandatory; fees via an accredited scheme or 2 RON/kg to AFM | ANMAP (ex-ANPM) producer register; AR mandatory | ANMAP register; AR mandatory since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | The heaviest admin in the region: monthly AFM declarations by the 25th, and foreign sellers need BOTH an authorised representative and a tax representative. |
| Slovakia | Register of Producers (ISOH); direct registration impossible, AR mandatory | ISOH producer register; AR mandatory before the first sale | ISOH register; AR mandatory | Not yet (EU-wide EPR due by April 2028) | No registration threshold and the AR mandate must run at least one year; packaging under 100 kg/yr skips the scheme contract but still registers and reports annually. |
| Slovenia | Producer register; no de minimis; AR mandatory for foreign distance sellers | Environment ministry (MOPE) producer register; AR mandatory | MOPE register; EU-law AR duty since Aug 2025 | Not yet (EU-wide EPR due by April 2028) | No threshold at all: a single parcel triggers registration, with quarterly scheme reports plus an annual report due 31 March. |
| Spain | Registro de Productores de Producto (packaging section); AR mandatory for foreign sellers | RII-AEE register; AR mandatory for non-established sellers | RII-PYA register; AR mandatory | Adopted in draft; expected 2026-27 | Customs blocks imports without RII-AEE/RII-PYA numbers since 2023; no de minimis, the AR is needed from the first parcel. |
| Sweden | Naturvårdsverket producer register + accredited scheme; direct foreign registration possible today, AR from Aug 2026 | Naturvårdsverket EE register; Swedish AR mandatory for distance sellers | Naturvårdsverket battery register; Swedish AR mandatory | Not yet (EU-wide EPR due by April 2028) | A dual duty: register with Naturvårdsverket AND join an accredited scheme; the annual report is due 31 March. |
| United Kingdom | pEPR live since 2025 (PackUK, data via RPD); no AR route: non-established sellers cannot register, the marketplace or first UK owner is obligated | Environment agency producer register; UK AR or approved scheme needed for own-website sales; marketplaces liable for their foreign sellers since Aug 2025 | Battery producer register; needs a UK business presence, no AR route: the UK importer takes the obligation | Not yet (scheme in development) | A mixed regime: packaging and batteries shift to your marketplace or UK importer (who may block listings), while WEEE still requires your own UK AR or scheme for direct sales. |
You are the producer
EPR makes the producer pay for a product's end of life, and EU law expressly defines the foreign distance seller as the producer in the destination country (WEEE Directive, Batteries Regulation, PPWR). Selling into a country from abroad makes you directly obligated there, with no turnover threshold in most streams.
Three streams exist in every EU country: packaging, electricals (WEEE) and batteries. Textiles EPR is live in France, the Netherlands, Hungary and Latvia, and Directive 2025/1892 obliges every member state to run one by April 2028.
France: UIN, SYDEREP and the AGEC law
France requires one UIN (Identifiant Unique) per stream, issued by ADEME through the SYDEREP register, displayed in your terms and on your site. With 19 streams, most catalogue items trigger at least two obligations (the product's stream plus its packaging).
Marketplaces must take over the obligations of non-compliant sellers, so they demand valid UINs and delist without them. Fines reach €7,500 per unit or tonne, plus up to €30,000 for missing registration.
Authorised representatives, stream by stream
For electricals, an authorised representative in each destination country has been mandatory for distance sellers since the WEEE Directive (Art 17). The Batteries Regulation extended the same duty to batteries from August 2025.
The PPWR completes the set: from 12 August 2026, distance sellers must appoint an authorised representative for packaging EPR in every member state where they are not established, while producer registers stay national.
Marketplaces now police EPR
Germany has barred marketplace sales without LUCID and WEEE registration since 2022; France shifts the obligations onto the platform unless the seller proves compliance. The PPWR makes verification an EU-wide duty for online platforms and fulfilment providers from August 2026.
In practice this means suspended listings, not just fines: register before you sell, and keep your numbers visible where each country requires them (invoices in Greece and Poland, terms and website in France).
The traps that catch sellers
Several countries have no threshold at all: one parcel to Slovenia, Austria, Spain or Bulgaria creates obligations. Croatia even applies them retroactively to everything you have already sold there.
Reporting rhythms differ wildly: annual in most streams, monthly in Ireland, Romania and Croatia, forecast-based in Denmark, with continuous journal bookkeeping in Lithuania. Budget the eco-contributions per unit sold: EPR is pay-as-you-sell.
The United Kingdom's own system
The UK runs EPR outside the EU framework. Packaging (pEPR, live since 2025) and batteries offer no authorised-representative route: a non-established seller cannot register, so the marketplace or first UK owner becomes obligated instead.
WEEE works the other way: since August 2025 marketplaces are the producer for their overseas sellers' household electricals, but selling from your own website still requires your own UK representative or an approved compliance scheme.
This guide is general information, not legal advice. EPR rules, registers and eco-organism schedules change frequently, and several 2026 reforms are still being phased in; always confirm your position before relying on it. Last reviewed July 2026.
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