EPR registration in practice: Germany, France, Italy and Spain

EPR, extended producer responsibility, is the obligation to pay for collecting and treating the waste left over from the products you put on a given national market. For a seller shipping into Germany and France from elsewhere in the EU it comes down to three things: you register separately in each country, separately for each waste stream (packaging, electrical equipment, batteries, and in France also furniture, textiles and a dozen more categories), and you then enter the numbers you receive into your seller account. Germany runs two separate registers: LUCID at the ZSVR for packaging, and stiftung ear for equipment and batteries. France has a single producer register at ADEME, but the identification number (IDU) is issued per filière and usually comes through the compliance scheme you sign a contract with. Without those numbers, platforms deactivate listings, because the law tells them to check. Below: a stream-country-register-number table, the sequence in which some steps block others, and the list of things you cannot do yourself without a representative in the country.

Legal position and platform requirements as of 8 August 2026. This text is not legal or tax advice. It draws on material from the German institutions ZSVR, stiftung ear and the Federal Environment Agency (Umweltbundesamt), the French agency ADEME, European Commission and EUR-Lex documents, and Amazon's official seller pages; every claim carries its source. The rules are mid-change: on 12 August 2026, four days after this article is published, the EU Packaging and Packaging Waste Regulation (PPWR) starts to apply, together with the German implementing act. Rates and tariffs are set by the compliance schemes themselves, so confirm any figures directly with them. Assessing your own case may need a lawyer or a tax adviser.

Why EPR reaches you even though your company sits elsewhere

An EPR obligation arises where the product reaches the consumer, not where your company is registered. The ZSVR says it plainly: any company commercially placing packaged goods on the German market has to register with LUCID, no matter where in the world that company is based. There is no de minimis threshold and no exemption for low packaging volumes (ZSVR, obligations of online retailers).

In practice this catches a lot of sellers off guard: the first parcel sent to a German consumer already triggers the obligation, because the box, the film and the filler are packaging placed on the German market. No warehouse in Germany and no local entity is needed.

Two boundaries worth drawing, because these obligations get mixed up constantly:

• EPR is not VAT. VAT registration follows where the goods physically sit and where they ship from; EPR follows who receives the product and what it is made of. The wider tax picture, including VAT OSS and the point at which local registration becomes unavoidable, sits in our guide chapter on taxes on Amazon in Europe. This article deliberately skips those basics and goes down to registers and numbers.
• EPR is not GPSR. GPSR governs product safety and the data in your listing; EPR governs the waste the product leaves behind. Separate duties, even though platforms check both in the same corner of the panel. The safety side is covered in our piece on GPSR on marketplaces.

Amazon Pan-EU deserves a separate flag. A model in which Amazon spreads your stock across warehouses in several countries multiplies not only VAT registrations but also the number of markets on which you place packaging, so every new storage country is potentially another full set of EPR numbers.

Stream, country, register, number: what connects to what

This table answers the question that stalls most launches: where exactly do you sign up, and what do you then type into the seller account.

Sources for the table: ZSVR on LUCID registration, stiftung ear on producer obligations, ADEME on the IDU and its list of approved schemes (both in French), plus Amazon's seller pages for Germany and France.

A caveat on the German rows. The absence of a register for furniture and textiles is today's position, not a permanent rule. The revised Waste Framework Directive (EU) 2025/1892 entered into force on 16 October 2025 and gives member states 30 months to set up extended producer responsibility schemes for textiles and footwear (European Commission). If you sell apparel, check the state of the register in your target country before each season.

Germany: three registrations across two institutions

The German model is split by institution: packaging sits with the ZSVR, equipment and batteries with stiftung ear. There is no single desk, no shared application form, and three independent tracks that run at very different speeds.

Packaging: LUCID plus a dual system

Registration is only the first of three duties. The ZSVR lists them together: registration with LUCID, a system participation contract for packaging subject to system participation, and volume reporting made in parallel to the system operator and to LUCID. Registration itself is free and done online (ZSVR).

The practical consequence is that a LUCID number on its own does not equal compliance. A number entered in the seller account without a signed dual system contract is something a platform can spot, because its verification duty covers both: the ZSVR states that electronic marketplaces are required by law to check registration and system participation alike.

Electrical equipment: registration before the first sale

Here the order is rigid, and it is what wrecks seasonal plans most often. stiftung ear sets out an eight-step procedure, two steps of which are blocking:

• Guarantee before the application. If you place equipment used in private households on the market, the registration application has to include proof of an insolvency-safe guarantee. Without it the application is incomplete.
• No selling before the decision. stiftung ear is unambiguous: only once you have received your registration order are you allowed to place equipment on the German market. Processing a complete and correct application usually takes three to four weeks, and longer when application volumes are high (stiftung ear, applying for WEEE registration).

Registration is tied to brand and equipment type, so adding a brand to the portfolio means running the procedure again rather than editing a record.

Batteries: new rules since October 2025

German battery law was rebuilt around the EU Battery Regulation. The Batterierecht-Durchführungsgesetz (BattDG) entered into force on 7 October 2025, and registration is handled by stiftung ear (Umweltbundesamt, in German).

This is the stream that gets skipped most often, because a battery is rarely the product itself. A remote control, a kitchen scale, a toy with a coin cell: in each case you place both equipment and a battery on the market, and that is two separate registrations with the same institution.

What changes for packaging on 12 August 2026

Until now a company based outside Germany could register with LUCID by itself, with no German entity involved. That changes on 12 August 2026, when Regulation (EU) 2025/40 (PPWR) starts to apply, having entered into force on 11 February 2025 (European Commission, the text on EUR-Lex). The German implementing act, VerpackDG, takes effect the same day.

The ZSVR describes the new division of roles like this: companies based abroad, without an establishment in Germany, that ship packaged goods directly to German end users must appoint a bevollmächtigter, an authorised representative. That representative takes over the full set of duties, including system participation contracts, volume reports in LUCID, declarations of completeness and take-back obligations. One exception matters: registration with LUCID remains a strictly personal duty of the company and the representative cannot do it for you (ZSVR on bevollmächtigung, in German).

If you sell on the German Amazon and have been handling packaging in-house, this calls for a decision this month rather than at the next reporting date. The PPWR rule is EU-wide, so an equivalent obligation applies in every other market where you are not established, France included. Confirm the local implementation with your compliance scheme, because national detail varies.

France: one register, many filières, an IDU per stream

France took the opposite route to Germany: a single producer register run by ADEME, but far more streams inside it. The identifiant unique (IDU) has been mandatory since 1 January 2022 under article L. 541-10-13 of the environment code, and an IDU is issued per filière (ADEME, in French).

Three things set the French route apart, and they are worth knowing before the first parcel goes out:

• The number does not come from the authority. In a collective system it is the compliance scheme that registers you and passes on the IDU; ADEME notes the producer cannot do this itself. The order is therefore the reverse of Germany's: contract first, number second.
• Packaging and paper share one number. Amazon states it directly in its French requirements: packaging and paper run on a single identifier, while every other category needs its own.
• The IDU has to be shown, not merely held. ADEME points out that producers communicate their identifiers in their terms of sale and on their website. This one gets forgotten, because no platform asks for it.

Amazon lists 19 EPR categories for France, running from electrical equipment, batteries and packaging through furniture, textiles, toys and sports goods to construction products and tobacco (sell.amazon.fr). The current list of filières and approved schemes is published by ADEME, and that is the only place worth checking, because the list keeps growing.

There is also a mechanism that explains why platforms push harder in France than anywhere else. ADEME explains that the operator of an online interface becomes the producer itself for goods where there is no proof that the seller has discharged its obligations under its own IDU. The platform is not enforcing somebody else's rule; it is limiting its own liability.

Italy: registers held at the chambers of commerce, one per stream

The Italian model splits the way the German one does, but the institutions differ: equipment and batteries sit in national registers run through the chambers of commerce, packaging sits with the CONAI consortium. The difference from Germany worth knowing upfront concerns whether you may register yourself at all.

Electrical equipment: Registro AEE, before you start selling

The national register of producers of electrical and electronic equipment explicitly covers companies in other EU states selling to Italian customers at a distance. The timing is unambiguous: “I produttori sono tenuti ad iscriversi al Registro nazionale, via telematica, prima che inizino ad operare nel territorio italiano", that is registration before beginning operations on Italian territory, not after the first sale (Registro AEE).

Article 30 of decree D.Lgs. 49/2014 provides for a rappresentante autorizzato: a producer established in another EU member state “può designare con mandato scritto un rappresentante autorizzato", may appoint an authorised representative by written mandate. The representative is a legal entity established in Italy and carries the producer's obligations, including organising one-for-one take-back of equivalent waste equipment across the country.

This is where Italy parts company with Germany. The register's own manual describes the filing as made “personalmente o tramite un rappresentante autorizzato", so the self-service route exists in the rules. In Germany, stiftung ear rules it out outright: a foreign company cannot register itself. Before you build a plan on that difference, confirm your own case with the register, because chamber-of-commerce practice can be narrower than the wording of the decree.

Batteries: Registro Pile e Accumulatori, including embedded cells

The duty falls on anyone placing batteries or accumulators on the Italian market professionally for the first time, including those built into equipment (“compresi quelli incorporati in apparecchi o veicoli"). This is the trap for a seller convinced they do not sell batteries: a rechargeable lamp, a toy with a coin cell, a wireless mouse all count as placing batteries on the market.

The register covers sales through any channel: “a prescindere dalla tecnica di vendita utilizzata, comprese le tecniche di comunicazione a distanza". The filing goes to the competent chamber of commerce (Registro Pile).

Packaging: CONAI and the contributo ambientale

Packaging is administered by the CONAI consortium, and the financing mechanism is the Contributo Ambientale CONAI, charged by packaging material. The duty to declare falls on whoever brings packaging onto Italian territory, and joining the consortium happens before packaging is placed on the market.

This is where publicly available material stops being conclusive. For a company shipping a parcel directly to a consumer in Italy, the decisive question is who counts as the importer under CONAI's rules, and we are not going to answer that for you: we did not find an unambiguous answer in the consortium's published guides. Put that question to CONAI or to your adviser before you cost out an Italian launch. We would rather say we do not know than print a number here that reads well.

Spain: one register for packaging, two industrial ones for the rest

Spain splits the duties across two ministries: packaging sits with the environment ministry (MITECO), equipment and batteries with the industry ministry, inside the Registro Integrado Industrial. Three registers, three separate filings.

Packaging: Registro de Productores de Producto, packaging section

The basis is Real Decreto 1055/2022 on packaging and packaging waste. Product producers or their authorised representatives register in the packaging section of the producer register (RPP) run by MITECO.

Two things set Spain apart from the other countries in this article:

• The registration number goes onto your paperwork. The number issued has to appear on invoices and other documents accompanying commercial transactions in packaged products, from the moment they are placed on the market. It is not a number you paste into a seller account once and forget.
• A foreign company acts through a representative, or the duty passes to the importer. Selling into the Spanish market from abroad requires an authorised representative in Spain; without one, the obligation sits with the importer.

On top of that comes joining a collective scheme (SCRAP), the Spanish equivalent of the German dual system. The deadlines for constituting those schemes were 30 June 2024 for household and hospitality packaging and 31 December 2024 for commercial and industrial packaging (MITECO).

Electrical equipment: RII-AEE

Article 8 of Real Decreto 110/2015 requires the producer or their authorised representative to enter the electrical and electronic equipment section of the Registro Integrado Industrial (RII-AEE). The duty covers sales through any direct channel to households and professional users in Spain, including where the seller is established in another member state. The entry itself is free of charge (Ministerio de Industria y Turismo).

Batteries: RII-PyA

Batteries and accumulators have their own national register inside the same industrial system (RII-PyA), under Real Decreto 106/2008 as amended by Real Decreto 710/2015. Registration is free, but a reporting duty comes with it: quarterly declarations of the types, origins and quantities placed on the market (Ministerio de Industria y Turismo).

The four countries side by side

The comparison shows what is hardest to read off separate official pages: where you can act alone, and where you need someone on the ground.

Amazonway's read, not a quote from any authority: the cost of entering a market is not the registration fee, because those are often zero (RII-AEE and RII-PyA are free, so is LUCID registration). The cost is the representative or the compliance scheme, plus the reporting, which comes back every quarter or every year and does not stop after launch. When you cost out the next market, cost that line, not the application form.

The order of work, where some steps block others

The expensive part of EPR is rarely the fee. It is the time lost to doing things in the wrong order. What follows is sequenced by dependency, not by convenience.

• Step 1: map the streams per SKU. For each product, establish what you actually place on the market: transport and grouped packaging, equipment, a battery inside, the casing material. This list determines how many registrations you need, so an error here multiplies downstream.
• Step 2: decide on a German representative. With no establishment in Germany you need a bevollmächtigter for equipment and batteries, and from 12 August 2026 for packaging too. The registration application cannot move before that contract is signed, which makes it step zero rather than a closing formality.
• Step 3: the guarantee for household equipment. The financial security is arranged with a bank or an insurer, and it usually sets your real start date, because financial institutions work to their own clock.
• Step 4: applications to the German registers. stiftung ear quotes three to four weeks for a complete application, and selling before the decision is not allowed. LUCID is immediate, but on its own it does not close the packaging file.
• Step 5: the dual system contract in Germany. You sign it after LUCID registration, because the system needs your number, and then the same volumes get reported in two places.
• Step 6: scheme contracts in France. One contract per filière, each ending in its own IDU. There is no self-service registration step you could run ahead in parallel.
• Step 7: numbers into the seller account. Only with the full set do you fill in the EPR compliance portal in the panel. Entering a number in advance achieves nothing, because the data is verified against the registers.
• Step 8: a reporting calendar. Volume reports, declarations of completeness and annual settlements run on their own deadlines, unrelated to your sales cycle. Left out of the calendar, they resurface at the worst possible moment, which is the fourth quarter.

Practical conclusion, and our recommendation: when you build the timeline for a new market, treat EPR as a process measured in weeks rather than days, and start it alongside VAT registration rather than after it.

What you cannot do yourself without a local representative

This is the part that is hard to work around, and much better known in advance than after a rejected application.

Germany, equipment and batteries. A producer without an establishment in Germany who sells at a distance to German end users has to appoint an authorised representative who performs the duties in their own name (stiftung ear). The same applies to batteries under BattDG (Umweltbundesamt).

Who can take the role, and on what terms. stiftung ear is specific: any reliable and legally capable person with a branch in Germany can act as authorised representative, including an affiliated company or a specialist service provider. The mandate must be written, in German, signed by both parties, concluded for a minimum of three months, and only one representative may be appointed for all of a producer's brands and equipment types (stiftung ear, registration as a foreign company). That last condition has operational bite: you cannot split brands between two providers.

France. ADEME allows a producer to act through a mandataire, who assumes producer responsibility and files the declarations of quantities placed on the market. From 12 August 2026 the PPWR requirement for a packaging representative in every member state where the producer is not established sits on top of that.

What stays with you regardless. LUCID registration as a personal duty, keeping registration data current, the accuracy of the volumes you declare, and entering the numbers into the seller account. A representative is accountable for the procedure, not for the fact that you estimated your packaging weights by eye.

What happens to listings when numbers are missing

Amazon describes the consequence identically for both markets: without valid proof of compliance the platform may deactivate non-compliant listings, or comply on your behalf (sell.amazon.de, sell.amazon.fr). The second option can be the worse one, because somebody ends up paying for that compliance.

The pressure is legal rather than contractual, which is why arguing with support gets nowhere:

• Packaging in Germany: electronic marketplaces and fulfilment service providers are required by law to verify LUCID registration and system participation (ZSVR).
• Electrical equipment in Germany: the platform duty to check seller registration took effect on 1 July 2023 (eBay seller announcement, in German).
• France: without proof of your IDU the platform is itself the producer in the eyes of the rules, so switching a listing off is cheaper for it than keeping it live (ADEME FAQ, in French).

It is equally worth knowing what the platform does not ask about. Amazon's German portal collects numbers for two streams, packaging and electrical equipment, whereas the battery registration duty exists whether or not anyone chases you for it. Being compliant with a panel is not the same as being compliant with the law. Compliance gaps surface in the same place as other listing problems, on the Account Health page.

Amazon also sells a paid EPR Services option; its French seller page quotes 39 euros a month excluding VAT (as of 8 August 2026). It is a convenient route, but it does not transfer responsibility for the accuracy of the data you declare.

What it costs, and what cannot be quoted upfront

We are not giving cost ranges, because for EPR they do not exist in any useful form: the fee depends on material, weight, unit count and the tariff of one specific scheme. Instead, here is the list of items you need to price yourself to get a real budget.

• LUCID registration: free of charge, online (ZSVR).
• German dual system contract: priced by the system operator itself, by packaging material and weight. Several systems compete on price, so the offers are worth comparing.
• French eco-contributions: set by the tariff (barème) of the scheme covering the filière, usually modulated by product characteristics.
• Representative fees: per country, and in Germany effectively one fee covering all your brands, since only one representative is allowed.
• Financial security for household equipment: the cost of the bank or insurance guarantee, set by the financial institution.
• Reporting effort: either your own team's time or an outsourced fee, plus any platform charge for a compliance service.

Confirm the exact rates directly with the compliance scheme and the dual system you contract with. The "average EPR cost" figures circulating online almost always leave out packaging weight, which is the variable that decides the bill.

How Amazonway helps with this

EPR rarely comes apart on a difficult rule. It comes apart on the fact that registrations run in parallel across several institutions, in two languages, on deadlines nobody tracks until a listing disappears. At Amazonway we run this part of the process for clients: mapping streams per SKU, handling registrations and the number entries in the accounts, then keeping the reporting calendar so sales do not stall over a formality.

An honest caveat: we are not a law firm or a tax advisory practice, and we do not replace either a lawyer or a tax adviser. Nor are we the authorised representative in Germany or the mandataire in France, since that role belongs to an entity established in the country; what we do is help you choose one and get the cooperation running. We do not promise sales outcomes, nor that an authority will always decide within its stated timeframe.

FAQ: EPR registration in Germany, France, Italy and Spain

Do I need an EPR number if I ship from abroad and hold no local stock?

Yes, if you ship to consumers in that country. The ZSVR states that any company placing packaged goods on the German market must register with LUCID regardless of where it is based, with no volume threshold. Foreign stock is a criterion for VAT, not for EPR.

How many numbers do I need for Germany and France?

In Germany, as many as you have streams: a LUCID number for packaging, a WEEE number for equipment and a separate battery registration with stiftung ear. In France, one IDU per filière, except that packaging and paper share one identifier. A clothing seller shipping a gadget with a battery may therefore need a very different set of numbers from a cosmetics seller.

Is LUCID registration on its own enough?

No. The ZSVR lists three duties together: registration, a system participation contract for packaging subject to system participation, and volume reporting to both the system and LUCID. Platforms are obliged to check registration and system participation alike.

Who can be my authorised representative in Germany?

Any reliable and legally capable person with a branch in Germany, including an affiliated company or a specialist service provider. The mandate must be written, in German, signed by both parties and concluded for at least three months, and a producer may appoint only one representative for all brands and equipment types.

What changes on 12 August 2026?

Regulation (EU) 2025/40 (PPWR) starts to apply and, in Germany, the VerpackDG implementing act enters into force. Companies without an establishment in Germany that ship packaged goods to end users must appoint an authorised representative for their packaging obligations. LUCID registration itself remains a strictly personal duty of the company.

How long does electrical equipment registration take in Germany?

stiftung ear quotes three to four weeks for a complete and correct application, with the caveat that high application volumes and complex cases take longer. Equipment may not be placed on the market before the registration order arrives.

Do furniture and textiles need registering in Germany?

As of 8 August 2026 there is no separate German EPR register for those categories; the ZSVR and stiftung ear registers cover packaging, equipment and batteries. In France both categories have their own filière and their own IDU. For textiles the position will change, because the revised Waste Framework Directive (EU) 2025/1892 obliges member states to set up EPR schemes within 30 months of 16 October 2025.

Sources

• Registro AEE, national register of equipment producers (Italy)
• Registro Pile e Accumulatori, national register of batteries (Italy)
• D.Lgs. 49/2014, art. 30 (rappresentante autorizzato), and chamber-of-commerce guidance on AEE producer duties
• MITECO, waste prevention and management (Spain), Real Decreto 1055/2022
• Ministerio de Industria y Turismo, RII-AEE and RII-PyA
• ZSVR, registration in the LUCID packaging register and obligations of online retailers
• ZSVR, authorised representation under the PPWR (division of duties from 12 August 2026, in German)
• stiftung ear, applying for WEEE registration, registration as a foreign company and producer obligations
• Umweltbundesamt, BattDG entry into force (7 October 2025, in German)
• ADEME, the unique identifier (IDU), the list of REP filières, approved compliance schemes and the FAQ (in French)
• European Commission, the packaging regulation (PPWR) and the revised Waste Framework Directive; PPWR text on EUR-Lex
• Amazon, EPR requirements for Germany and France
• eBay, marketplace duties for electrical equipment from 1 July 2023 (in German)

Find out which numbers you are missing

The usual scenario is not that somebody ignored EPR. It is that two numbers out of three are in place, the dual system contract dates from last year, and nobody checked whether the new brand needs its own registration. If you sell into Germany or France and are not sure where the gaps are, start with a review of your assortment by waste stream.

Book a free review of your EPR obligations →