Registration is per country, always: every member state runs its own EPR register and there is no EU-wide number. A representative is required per country in two situations: for producers not established in the EU, in every member state where they sell (EU packaging regulation, since 12 August 2026), and where national law says so regardless of EU status, as France does since 10 July 2026 and Germany does for direct sales to end users. The Commission proposed suspending the representative duty for EU-established producers; nothing is adopted, and it never touched national rules or registration.
Registration: per country, no exceptions
France has SYDEREP and the IDU; Germany has LUCID; Spain, Italy, the Netherlands, Austria, Belgium each have their own register or scheme. An EPR number from one country is checked against that country's register only. Amazon's Account Health has one field per country per stream for that reason. Whatever happens with representatives, this part does not change.
Representative: when it is required
- Non-EU producer, any member state where you sell: required under article 45 of the EU packaging regulation (2025/40) from 12 August 2026, and under most national laws before that (Germany since 2019 for packaging).
- EU producer, France: required since 10 July 2026 by article L. 541-10-9-1 for any producer not established in France, all streams, packaging and products alike.
- EU producer, Germany: required from 12 August 2026 for direct sales to German end users from abroad (VerpackG § 35, aligned to the EU regulation).
- EU producer, other member states: depends on national law; several apply the EU rule as written, some have not yet enforced it.
The proposed EU suspension
In summer 2026 the Commission proposed to suspend the representative requirement for producers established in the EU, after complaints that appointing one in 26 other member states is disproportionate. As of September 2026 it is a proposal. It does not affect non-EU producers, does not affect registration, and does not override national laws such as France's. If it passes, an Italian company would no longer need a representative under EU law in Spain, but would still need one in France under French law.
What this means in practice
- List the countries where you sell to end users.
- Register in each. Most sellers do this themselves or through a dual system or scheme in that country.
- Appoint a representative where required: France for everyone not established there; Germany for direct sales; every country for non-EU companies.
- A representative must be established in the country; nobody can cover 27 countries with one entity, whatever the marketing says. Providers who offer "all of Europe" subcontract to a local entity per country.
For France, the scope check tells you whether the representative rule applies to your company, and the Free EPR Calculator shows the eco-contributions per stream.
Frequently asked questions
Is there an EU-wide EPR number?
No. Each member state keeps its own register. The EU packaging regulation harmonises what is registered, not where.
We are a German GmbH. Do we need a representative in France?
Yes, since 10 July 2026, because you are not established in France. This is French national law and does not depend on the EU proposal.
We are a US company selling in five EU countries. How many representatives?
Five, one per country, each established in that country. Plus registration in each.
Can one company be our representative everywhere?
Not legally. A representative must be established in the member state. Multi-country providers use one local entity per country.
Sources
- EUR-Lex — Regulation (EU) 2025/40 (PPWR)
- European Commission — PPWR guidance notice C(2026)3702
- Légifrance — Code de l'environnement
- Ministère de la Transition écologique — filières REP
- Eldris — Non-EU sellers EU EPR gap (2026)
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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