Packaging law from A to Z

A representative established in the destination country who takes over a foreign producer's EPR obligations. Since 12 Aug 2026, Art. 45 PPWR has required an authorised representative from every seller selling at a distance into an EU country without an establishment of their own – with no de-minimis threshold (a softening of this obligation is still being negotiated at EU level as of Sep 2026). Public provider prices are mostly around €250–500 per country per year, volume-dependent also above that; the German twist: the LUCID registration itself nevertheless remains the seller's personal obligation.

Poland's central waste database, in which parties placing packaged goods on the market must also be registered. The BDO number must be stated on invoices and documents and is checked by marketplaces. In practice, foreign direct shippers work via an authorised representative or a recovery organisation.

CONAI is the Italian packaging consortium that parties placing packaging on the market join; the CAC (Contributo Ambientale CONAI) is the material-based environmental contribution on packaging. Special situation for foreign online sellers: Italy does not yet have an operational packaging register – according to the CONAI guide 2026, EU foreign sellers currently have no direct CONAI obligation (exception: selling via platforms) until the new RENAP register launches. This transitional situation can change at short notice – see the Italy guide for the current status.

A country's approved take-back schemes that producers join (in France for household packaging: Citeo, Adelphe, Léko; for commercial packaging from 2027: Citeo Pro, Léko Pro, Twiice). Internationally they are called PROs (Producer Responsibility Organisations). Joining fulfils the financial EPR obligation; contributions follow the public tariff (barème).

Austria's electronic data management system for environmental and waste data, through which packaging registrations and reports are also handled. In practice, foreign distance sellers handle the EDM registration via their collection and recovery scheme or their authorised representative.

The Austrian term for participating in an approved collection and recovery scheme (e.g. ARA, Reclay, ERP Austria, Bonus Holsystem) – the discharge of obligations via an approved scheme: the seller 'entpflichtet' its packaging, and the scheme takes over collection and recovery. For household packaging the obligation applies with no volume threshold; below 1,500 kg per year a flat-rate small-volume fee is available.

EPR means: whoever places packaged products on the market in a country bears the responsibility for their disposal – organisationally (registration, reporting) and financially (licence fees to take-back schemes). In e-commerce, the seller generally counts as the producer of the shipping packaging. EPR systems are organised nationally; every destination country has its own register, its own schemes and its own evidence requirements.

The French EPR registration number from the ADEME register. You receive it via your éco-organisme (e.g. Citeo, Adelphe, Léko) and must store it with marketplaces, among others. It follows the pattern 'FR' + six-digit number + underscore + two-digit scheme code (household packaging: 01) + four letters, e.g. FR123456_01ABCD. A common mistake on Amazon: the éco-organisme's customer or contract number is entered instead of the IDU – the check then reports 'number invalid'.

The public German packaging register, run by the Zentrale Stelle Verpackungsregister (ZSVR). Anyone placing packaged goods on the market for German end customers must register there before the first sale – personally; the registration cannot be delegated. Important: LUCID only covers Germany; for other EU countries, their own registers apply.

The French version of the authorised representative: since 10 Jul 2026 (Law No. 2026-602, Art. L541-10-9-1 Code de l'environnement), producers without an establishment in France must appoint, in writing, a Mandataire established in France who steps into their EPR obligations. In practice, éco-organismes and EPR service providers offer this role as well.

The EU Packaging Regulation (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) has applied directly in all EU Member States since 12 Aug 2026 and harmonises packaging law. Important for online sellers: extended producer obligations, an authorised representative for distance selling into countries without an establishment of your own (Art. 45), and verification duties for marketplaces. Further stages follow: harmonised labelling from 2028, recyclability and empty-space requirements from 2030.

The Spanish producer register at the environment ministry MITECO, in which parties placing packaging on the market must register (legal basis: Real Decreto 1055/2022). The registration number (format ENV/year/number) is requested by marketplaces, among others, and must appear on invoices. Producers without an establishment in Spain must appoint a representante autorizado in Spain for the registration and annual reports (Art. 17.2 RD 1055/2022); according to MITECO, the chosen collective scheme (SCRAP) can also take on this role by power of attorney.

Packaging filled only at the point of sale to the end customer (e.g. bakery bags, coffee-to-go cups). It comes with a special rule: the seller can buy pre-licensed stock and thereby shift the obligation to the upstream distributor. This exception does not automatically apply to standard shipping cartons in online retail – a common misconception.

The packaging the goods travel in to the end customer (carton, filler material, tape, mailing bag). In Germany the rule is: whoever fills the shipping packaging counts as its producer – so the party required to license it is regularly the seller, not the carton supplier. The ZSVR has confirmed this in its PPWR guidance for shipping and online commerce (the producer is whoever combines carton, tape and filler material into the packaging; shipping packaging is subject to system participation without exception); for edge cases, only a written clarification of roles is reliable.

The French EPR register operated by ADEME, in which producers are listed per product filière (EPR stream) and receive their IDU. In practice, the entry is handled via your chosen éco-organisme. The dataset is publicly accessible – useful for checking your own IDU or a supplier's.

The German obligation to license sales and shipping packaging with an approved dual system (approved German take-back scheme, e.g. Interzero/Lizenzero, Landbell, Der Grüne Punkt, Noventiz, Reclay). The fees depend on material and volume; the reported volumes must also be filed identically in LUCID. Without system participation, a distribution ban applies.

The French sorting logo with its accompanying Info-tri sorting instructions, mandatory for household packaging in France since 2022. The harmonised EU labelling under the PPWR becomes mandatory from 12 Aug 2028 and will gradually replace national sorting logos; until then, Triman/Info-tri remains mandatory for shipping to France. Note: in July 2025 the European Commission took France to the CJEU over the Triman requirement (single-market infringement) – the case was still pending in early September 2026 and does not change the applicable obligation until a ruling.

The German act implementing the EU Packaging Regulation (Verpackungsrecht-Durchführungsgesetz), in force since 12 Aug 2026. It replaces the Packaging Act (VerpackG) but keeps the core system: LUCID registration plus system participation. The main novelty is the authorised-representative requirement for foreign direct sellers (Section 5(2) VerpackDG) – previously, an authorised representative was merely a voluntary option (Section 35(2) of the old VerpackG); the LUCID registration itself remains strictly personal before and after. Existing system participation contracts remain valid until 31 Dec 2026 at the latest (Section 68(1) VerpackDG).

The Dutch producer organisation for packaging (formerly: Afvalfonds Verpakkingen), through which producers fulfil their EPR obligations in the Netherlands and report volumes. Important: the 50,000 kg threshold for the afvalbeheersbijdrage (waste management contribution) remains in place even after the PPWR took effect (verified with Verpact and Rijkswaterstaat) – the reporting obligation for single-use plastic (SUP), however, applies from the first kilo.

An annual, audited declaration of the packaging volumes placed on the German market, to be submitted by 15 May of the following year once certain volume thresholds are reached: 80,000 kg of glass, 50,000 kg of paper/paperboard/cardboard, or 30,000 kg of lightweight packaging (ferrous metals, aluminium, plastics, beverage cartons and other composites combined). Small online sellers are usually well below these; anyone crossing the thresholds needs a registered auditor. For the 2026 reference year, the ZSVR requires a uniform declaration – following the VerpackDG in form and the VerpackG in content.

The German register authority for packaging (Central Agency Packaging Register). It runs LUCID, verifies producer details, publishes the list of approved dual systems and, since 12 Aug 2026, has been fleshing out the requirements for authorised representatives (written contract in German, only one authorised representative per producer).