Packaging EPR for e-commerce: where you register and who pays

An online shop based in Bucharest imports goods from China, stocks them in Romania and sells to end customers in Romania, Hungary, Greece and Bulgaria, partly through its own site and partly through marketplaces. The question we hear most often from companies in this position is simple: where do I have obligations, and what does it cost.

The short answer is that you have obligations in every Member State where the packaging first reaches an end user, and registration happens separately in each of them. The long answer is worth five minutes, because the details drive the invoice.

Manufacturer and producer are not the same thing

The PPWR uses two terms that are constantly conflated.

The manufacturer, under the regulation, is the operator placing the packaging on the market under its own name or brand. It is responsible for the conformity assessment, the technical documentation and the EU Declaration of Conformity.

The producer, for extended producer responsibility purposes, is the operator first making the packaging or packaged product available on the market of a given Member State, and therefore carrying the obligations to register, report quantities and finance collection, sorting and recycling.

The two roles can sit with different operators and, more importantly for online retail, can be located in different countries. You can be manufacturer for your own packaging and, at the same time, EPR producer in four markets.

The rule that matters in e-commerce

The EPR obligation triggers where the packaged product first reaches an end user in that country. Distance selling from another Member State does not exempt you; it is precisely the situation for which EU legislation introduced the authorised representative mechanism.

Three practical consequences follow.

First, if you ship from Romania to customers in Hungary, Greece or Bulgaria, you are generally the EPR producer in those countries, even with no local entity, warehouse or staff.

Second, if you are not established in that Member State, you must appoint an authorised representative to fulfil the EPR obligations on your behalf.

Third, if you sell through marketplaces, the contractual allocation needs checking. The PPWR explicitly addresses online marketplaces as responsible actors when they intermediate the making available of third party sellers' products. Some platforms assume the obligation for certain flows; others pass it entirely to the seller and require proof of registration as a listing condition.

Transport packaging counts too

This is where most companies lose money. The EPR obligation does not cover only the product's primary packaging. The shipping carton, stretch film, tape, void fill and shipping label are all packaging. If you are the one first making them available on a national market, they enter your declared quantities.

For a mid volume online retailer, shipping packaging frequently accounts for more than half of the total reportable mass. It is also the easiest category to underestimate, because nobody weighs it.

What is coming on the register side

The regulation obliges every Member State to set up a national producer register. The deadline was not 12 August 2026. Article 44 gives Member States 18 months from the entry into force of the Commission implementing act setting the registration and reporting format. The registers will also have to link to each other to facilitate cross border registration.

Until then, existing national systems apply. In Romania the mechanism runs through authorised producer responsibility organisations, and in other Member States through equivalent national schemes, with thresholds, formats and calendars that differ from country to country.

The operational conclusion: do not wait for a unified European register before registering where you already sell. Current national obligations are not suspended by the PPWR timetable.

What it realistically costs

Cost has three components, and confusing them produces bad estimates.

A one off registration fee per country. A recurring contribution to the national scheme, calculated on declared quantity and material type. Administration cost, meaning the authorised representative, periodic reporting and internal record keeping.

At low volumes, under one tonne of packaging waste per country, registration is relatively affordable and recurring contributions are modest. What drives cost up is not volume but the number of markets and the reporting frequency.

One factor that will reshape the equation is eco-modulation. Financial contributions will be linked to the recyclability performance of the packaging, which means poorly designed packaging becomes more expensive not only through material but through the cost of its own compliance.

Do this in this order

List the markets where you actually delivered to end users over the last twelve months, with volumes. Not the markets you theoretically opened for shipping, but the ones you shipped to.

Estimate packaging mass by material and by market, including shipping packaging. A reasonable estimate based on parcel counts and average packaging weight is enough to decide where you have exposure.

Confirm in writing what the marketplace takes on.

Register in order of volume, not alphabetically and not in order of anxiety.

Build the records in parallel. A single file linking order, destination country, packaging used and mass by material solves your reporting for the next five years.

Frequently asked questions

If I only sell through marketplaces, do I still have EPR obligations? It depends on the contract and the Member State. In many situations the obligation stays with the seller, and the platform requires proof of registration.

Do I need an authorised representative in every country? As a rule, in every Member State where you have EPR obligations and are not established.

What happens if I do not register? The main risk is not only the fine, but losing the ability to lawfully make products available on that market, and being delisted by platforms that verify registration.

Do imports from outside the EU change anything? Yes. If you are the first to place the goods on the Union market, you are the importer under the regulation and, in most cases, the EPR producer for that packaging.

If you sell across several Member States and do not have a clear picture of your exposure, we assess your markets and tell you where registration is required, in what order, and at what cost.

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