New EU packaging regulations - what every Amazon seller should know about EPR

Last updated: 20/04/2026

From 12 August 2026, sellers operating in the European market will have to face new packaging requirements. The new European Union Regulation 2025/40 replaces existing rules and introduces harmonised standards across all member states. For Amazon sellers, this means primarily one thing - the necessity to register in the EPR system in every country where they sell.

Table of contents:

1. What is EPR and why is it so important now?

2. Which packaging is subject to the new regulations?

3. Who is a producer under the regulations?

4. How does the registration process work?

5. Authorised representatives - when are they needed?

6. What about the "Pay on Behalf" service?

7. FBA - who is responsible for which packaging?

8. What are the penalties for non-compliance?

9. Timeline - when does what happen?

10. United Kingdom - a separate case

11. What next?

12. FAQ - frequently asked questions

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What is EPR and why is it so important now?

Extended Producer Responsibility (EPR) is a system that obliges businesses to financially contribute to the waste management of their packaging. Sounds abstract? In practice, this means three primary obligations:

1. Registration - separate in each country!

This is the most important change. You must register as a packaging producer in each EU country where you introduce packaged goods onto the market for the first time. A single registration for the entire Union is not enough - each country has its own system and its own register.

Example? If you sell on Amazon in Germany, France, and Spain, you need three separate registrations:

• In Germany - in the LUCID system (Stiftung Zentrale Stelle Verpackungsregister)

• In France - through the government portal Filières à REP

• In Spain - through MITECO

2. Reporting - detailed packaging data

After registration, you must report regularly:

• How many kilograms of packaging you introduce onto the market in a given country

• What materials they are made of (plastic, paper, glass, metal, etc.)

• Whether they are single-use or reusable packaging

3. Eco-fees - funding the recycling system

Based on the reported data, you pay a so-called eco-contribution to producer responsibility organisations (PROs). These funds finance the collection and recycling of packaging waste.

Which packaging is subject to the new regulations?

The new regulation covers all types of packaging - both those that reach consumers (B2C) and industrial packaging (B2B). Here is the full list:

Primary packaging (sales packaging)

• This is the packaging in which the product reaches the final user

• Example: shoe box, pill blister, shampoo bottle

Grouped packaging

• Groups several units on a shop shelf

• Example: cardboard sleeve containing 6 yoghurts

Transport packaging

• Protects goods during transit

• Example: pallet with stretch wrap, shipping box

Service packaging

• Filled at the point of sale

• Example: paper bag, take-away container

Composite packaging

• Made of several materials that cannot be separated

• Example: milk carton (layer of paper + aluminium + plastic)

Who is a producer under the regulations?

Crucial question: do these regulations apply to you?

You are a producer if:

• You are the first to introduce a packaged product onto the market of a given country

• You import goods from outside the EU

• You sell online to clients in another EU country (cross-border sales)

You are not a producer if:

• Your supplier has already fulfilled the EPR obligations in that country

• Example: you are based in Germany, you buy products from a Spanish supplier who sends them directly to Spanish clients - in this case, the supplier is the producer

In doubtful cases, it is worth consulting with a lawyer specialising in environmental law.

Need support? Comprehensive sales management for manufacturers on Amazon.

How does the registration process work?

Step 1: Identify the countries where you need to register

Check in which countries you conduct sales and where you introduce packaging for the first time.

Step 2: Register in the corresponding national systems

Each country has its own system. Here are the most important addresses:

Step 3: Obtain a registration number (ERN)

Upon completing registration, you will receive an ERN (Extended Producer Responsibility Number). Note: in countries with public registers (such as Germany), wait 48-72 hours for the number to appear in the register before submitting it to Amazon.

Step 4: Report the number in Amazon Seller Central

Important: you must do this separately for each country!

Procedure:

1. Select the country in the top left corner of Seller Central

2. Go to: Account Health → Compliance → Manage Quality and Compliance

3. Click "Submit Compliance Information"

4. Enter your ERN and save

Amazon will verify the number within 5 business days. The