Packaging EPR in all 27 EU countries: national routes in 2026
PPWR does not issue one EU producer number. Use this list to open the first national packaging EPR checkpoint in each of the 27 Member States.
Short answer: Packaging extended producer responsibility still has to be checked country by country. The Packaging and Packaging Waste Regulation (PPWR) has applied generally since 12 August 2026, yet it does not issue one producer number for the Union. For each of the 27 Member States you still name the producer, open the local register or scheme, split the packaging stream, and keep the party that reports it. The entries below are first checkpoints, not a claim that one filing finishes every duty.
What a 27-country packaging EPR file actually is
Packaging EPR is the duty of the legally defined producer to finance and document the packaging it first makes available on a national market. PPWR gives the Union definitions and asks Member States to operate producer registers. The register name, the approved organisation, the authorised-representative rule and the kilogram form stay national. smbf.me is packaging EPR software: it can import orders, map destinations and keep packaging data, reports and evidence. It is not legal advice, not a producer responsibility organisation, not an authorised representative, and not a single EU registration.
Write the legal seller, importer, delivery recipient, country of establishment, and whether the pack reaches a household or a business. Then list every sales pack, shipping carton, insert, film, pallet and service pack by material and empty weight. A marketplace listing or a warehouse postcode does not settle who first placed the pack.
Why copying one number across the map fails
Marketplaces, customs files and brand owners ask for a producer identifier per destination. If the identifier belongs to another country, or to a distributor who is not the producer for your sales route, the listing can be blocked and the kilogram file cannot be defended. A small-volume line in one fee table does not cancel registration in another Member State.
The cost of getting this wrong is operational, not abstract. You end up reconciling a German system report against a French IDU, or storing an Austrian representative mandate against a Swedish seller who never appointed one. The applicability test is the right first pass if the producer role is still unclear.
How people usually try to cover the EU, and the downside
Teams often take a LUCID number, a CONAI membership or a dual-system invoice and paste it into every marketplace field labelled "EPR". That skips the producer test in the destination and the stream split the local form actually uses. Another pattern is to treat a 300 kg or 50,000 kg figure from one country's notes as if it cleared every other market.
The downside is a file that looks complete until an authority, a scheme or a marketplace asks who first made this pack available there. You then cannot show a register extract, a mandate and a kilogram calculation for the same legal entity and period. The multi-country workflow is built to stop that mix-up.
How to work the 27 routes from one packaging record
Keep one measured bill of materials. Translate it into each country's live form. In smbf.me that means a country workspace per destination, with evidence history, not a shared "EU compliant" tick.
- Record the legal seller, importer, recipient, place of establishment, household or commercial use, and every packaging component by material and weight.
- For each destination, apply that country's producer definition and any authorised-representative rule; do not paste a number from another Member State.
- Open the national register or scheme route listed for that country and save the producer identity that matches the sales chain.
- Map component kilograms to that country's live form and calendar, then reconcile with sales, imports and returns for the period.
- Store four files per market: the producer decision, register evidence, scheme or representative agreement, and the material declaration with receipt.
Austria (AT)
Check the obligated seller, household or commercial stream, and an approved collection-and-recovery system. A foreign distance seller without an Austrian seat or branch who supplies private end users needs an Austrian representative; EDM reporting is a separate question. Read the Austria EPR guide and country page. Austrian business portal.
Belgium (BE)
Identify the responsible packer or importer and split household from commercial and industrial packaging. Fost Plus and Valipac cover different streams; the interregional authority is moving to the EPRiBEL name. The 300 kg take-back threshold is not the 100/300-tonne prevention-plan test. Read the Belgium country page. Interregional authority FAQ; Fost Plus; Valipac.
Bulgaria (BG)
Check the public register for persons placing packaged goods on the market through NISO, then confirm a permitted collective or individual recovery route. Businesses outside a valid route may face a product fee; monthly packaging records matter. Read the Bulgaria country page. Executive Environment Agency.
Croatia (HR)
Check the producer's RPPO entry, the Environmental Protection and Energy Efficiency Fund (FZOEU) reporting route and any representative mandate for a non-established producer. Separate single-use and reusable packaging data. Read the Croatia country page. RPPO official portal.
Cyprus (CY)
Identify the first placer of the packaged product, then confirm the Department of Environment's current packaging route and an approved recovery organisation or individual arrangement. Do not infer a national filing code from household collection colours. Read the Cyprus country page. Department of Environment.
Czechia (CZ)
Check the Ministry of the Environment list of persons placing packaging on the market, the packaging records and the take-back and recovery route. EKO-KOM is a common collective route; the obligated entity depends on the supply chain. Read the Czechia country page. Ministry packaging guidance.
Denmark (DK)
Start with Danish Producer Responsibility (DPA) registration, a collective packaging scheme and the national quantity report. DPA distinguishes EU/EEA direct sellers from sellers established outside the EU/EEA when explaining representation. Read the Denmark country page. DPA registration.
Estonia (EE)
Check Pakendiregister/PAKIS records, any producer responsibility organisation and packaging excise exposure. Reconcile quantities reported through the organisation with the entity's own import and sales evidence. Read the Estonia country page. Climate Ministry.
Finland (FI)
Confirm producer registration with the national supervisory authority LVV and the applicable packaging producer organisation. Keep material quantities and identify who files on behalf of the producer. Read the Finland country page. LVV producer responsibility guidance.
France (FR)
Distinguish household packaging, catering-sector professional packaging and the wider professional-packaging route scheduled to become operational in 2027. Confirm the relevant eco-organisation, the stream-specific IDU and any France-based mandataire. Read the France country page. ADEME IDU guidance; ministry launch notice.
Germany (DE)
The producer's own LUCID registration, system participation and matching data reports are distinct steps. Check the packaging class and the German representative rule for a foreign direct seller. Read the Germany country page and LUCID guide. ZSVR registration.
Greece (GR)
Confirm an EOAN producer entry in EMPA and an approved collective or individual packaging compliance route. A non-established producer should check the Greek authorised-representative process before filing. Read the Greece country page. EOAN.
Hungary (HU)
Map the producer and packaging stream to the OKIRkapu producer-data process and MOHU's EPR operational and fee route. Keep the EPR record separate from any environmental product-fee determination. Read the Hungary country page. OKIRkapu.
Ireland (IE)
All packaging producers have baseline duties. A major producer meeting Ireland's packaging-volume and turnover test has additional duties and must join an approved body; Repak is the approved packaging scheme. Do not use that threshold as an EU-wide exemption. Read the Ireland country page. Irish government rule change.
Italy (IT)
Identify the Italian producer or importer and check CONAI membership, the environmental contribution (CAC) and declaration route. Packaging material, first placement and any cross-border sales arrangement affect who pays or reports. Read the Italy country page. CONAI declaration guidance.
Latvia (LV)
Check the State Environmental Service packaging/EPR route, any producer responsibility system and the natural-resources tax declaration to VID. Foreign distance sellers should examine the Latvian representative or direct-registration path. Read the Latvia country page. State Environmental Service.
Lithuania (LT)
Register the producer or importer in GII through GPAIS before first placement where required; keep packaging accounting there. Check the material, quantity and any tax or collective-system consequences separately. Read the Lithuania country page. Environmental Protection Agency.
Luxembourg (LU)
Confirm the packaging producer and the current Environment Agency procedure, then check an approved organisation such as Valorlux and its declaration route. Do not assume that a membership number and a state producer identifier are the same thing. Read the Luxembourg country page. Environment Agency packaging EPR.
Malta (MT)
Check registration with the Environment and Resources Authority (ERA), the WMP identifier, renewal, recovery-scheme coverage and annual return. An overseas producer should check the Maltese representative requirement. Read the Malta country page. ERA EPR guidance.
Netherlands (NL)
Check Verpact registration and the applicable packaging contribution and declaration rules. Hold a definitive representative or 50,000 kg threshold conclusion: current Verpact and government guidance differ from each other and from the PPWR cross-border text on these points. Read the Netherlands country page and resolve the producer route with the competent authority before filing. Verpact; Dutch government.
Poland (PL)
Determine the business entering packaged products on the Polish market, its BDO registration and the relevant recovery-organisation or individual route. Keep material-level records for the regional marshal return. Read the Poland country page. BDO national portal.
Portugal (PT)
Register the packaging producer in APA's RPP through SILiAmb/SIRER, identify an integrated or individual system and preserve the contract. Confirm the declaration year and current window; a prior 2026 extension should not be copied into a later filing calendar. Read the Portugal country page. APA producer responsibility.
Romania (RO)
Identify the entity responsible for packaging put on the Romanian market and its Environmental Fund Administration (AFM) declarations. Check whether an OIREP contract covers recovery obligations; do not invent a separate packaging register or a universal representative number. Read the Romania country page. AFM.
Slovakia (SK)
Check the packaging producer's Ministry register/ISOH entry, the reporting route and an authorised producer responsibility organisation (OZV) or individual fulfilment. Keep material and volume evidence. Read the Slovakia country page. Ministry of Environment.
Slovenia (SI)
Check the producer entry through ARSO's GEA application, then confirm a packaging waste management company (DROE) or individual route and the annual report. Read the Slovenia country page. ARSO.
Spain (ES)
Register the responsible producer or representative in the packaging section of the RPP, identify the household, commercial or industrial stream and check the SCRAP and annual national return. The 2026 producer definition has a transition around 12 August. Read the Spain country page. MITECO RPP guidance.
Sweden (SE)
Check Naturvårdsverket's producer registration, the packaging producer responsibility route and who handles municipal collection financing. The representative rule for EU-established cross-border sellers changed with PPWR; assess the seller's establishment and recipient. Read the Sweden country page. Swedish EPA PPWR guidance.
Checklist before you treat a market as filed
Work through the list in order. A later kilogram file does not cure a wrong producer identity.
- Record the legal seller, importer, recipient, place of establishment, household or commercial use, and every packaging component by material and weight.
- For each destination, apply that country's producer definition and any authorised-representative rule; do not paste a number from another Member State.
- Open the national register or scheme route listed for that country and save the producer identity that matches the sales chain.
- Map component kilograms to that country's live form and calendar, then reconcile with sales, imports and returns for the period.
- Store four files per market: the producer decision, register evidence, scheme or representative agreement, and the material declaration with receipt.
Mistakes that make an EU-wide file unusable
Teams treat a scheme invoice as proof that "Europe is done", then cannot say who first placed the pack in the destination. Keep the identity note, the contract and the kilogram file in the same period, for the same legal entity.
Cross-border sellers also paste a number from Germany or Italy into another national portal. PPWR does not license that shortcut. Read the registration and representative rules for the destination next to this list, and confirm establishment, direct-to-end-user sales and who is actually registered before you sign a mandate.
A third failure is copying a threshold. Ireland's major-producer test, Belgium's 300 kg take-back line and the disputed Dutch 50,000 kg figure are local. Sweden's agency says packaging producer responsibility applies regardless of quantity first supplied. Do not import a skip from one row into the next.
Common questions about packaging EPR in the 27 Member States
Can one EU packaging registration cover all 27 Member States? No. The Packaging and Packaging Waste Regulation sets a Union framework and requires producer registers in Member States. Packaging first made available in a country still needs that country's register, scheme or reporting route. A LUCID, CONAI or other national number does not prove compliance elsewhere. PPWR
Does a dual-system or scheme invoice replace national registration? Usually not. A scheme contract can cover collection, recovery or a contribution for a defined stream. The producer still has to complete any separate register step and keep the kilogram file aligned with the same legal entity and period. Treat invoice, register extract and declaration as three records.
If volumes are small, can I skip packaging EPR in every country? There is no Union-wide volume exemption from being a packaging producer. A national threshold may change a fee, a prevention plan or a reporting simplification without removing registration. Ireland's major-producer test and Belgium's 300 kg take-back line are examples of local rules, not an EU skip.
Did PPWR replace national packaging EPR on 12 August 2026? PPWR has applied generally since 12 August 2026, but Member States still run the local register, scheme and reporting processes. Several countries are in a documented transition. Recheck the linked authority page at the filing date rather than copying last year's portal path. PPWR
For the live country checks, start from the country pages. If the producer role is still open, use the applicability test. Once several destinations are in scope, keep them on the multi-country EPR workflow.
Sources and review method
National routes were taken from the linked authority, register or scheme pages and from the country files on this site. Recheck the form and calendar before you file. This article is not legal advice.