Entering a new EU market can be a quick step from a sales perspective. However, when it comes to Extended Producer Responsibility (EPR), each additional market may trigger new registration requirements, involve a different responsible legal entity, and create its own operational obligations. Without the required registration, the packaging or packaged products concerned generally cannot be placed on that market for the first time.

What may initially seem like a European sales question can therefore quickly become a market access issue: Who places which products on the market, in which country – and are all the necessary arrangements in place?

Companies operating in multiple markets need more than a loose collection of individual national activities. They need a clear overview of where obligations arise and who is responsible for fulfilling them.

European Sales, National Registration

The Packaging and Packaging Waste Regulation (PPWR) provides for national producer registers. As a general rule, producers must register in each Member State where they first make the relevant packaging or packaged products available on the market, or where the applicable conditions for registration are met. Without the required registration, they are generally not permitted to make those packaging items or packaged products available on that market for the first time.

For internationally active companies, a single “EU-wide EPR registration” is therefore not sufficient. Instead, their distribution structures must be assessed country by country.

• In which countries do we sell directly?
• Where do we distribute through third-party distributors?
• Which legal entity within our corporate group actually places the products on the market in each country?
• Which packaging streams result from these activities?

Only once these questions have been answered can a reliable EPR mapping be established.

Europe's Regulatory Patchwork Remains Operationally Relevant

The PPWR harmonises important fundamental principles and also provides for greater harmonisation of registration and reporting formats. At the same time, national registers, competent authorities and operational structures will remain in place. Member States are responsible for organising registration, overseeing reporting and ensuring compliance with EPR obligations, among other tasks.

For companies, this creates a complex compliance landscape.

The more markets a company enters, the more important centralised processes become. Otherwise, there is a risk that registrations will be managed locally and independently, with different responsible parties, data sources and deadlines.

The First Step: An EPR Matrix

A centralised EPR matrix can provide the necessary transparency. At a minimum, it should identify which legal entity operates in which country, which packaging streams are affected, who qualifies as the obligated producer, and which registration or organisational structure is used.

Even more importantly, this information needs to be linked to packaging data. Companies that have already structured their packaging information and systematically recorded materials, weights and components are also laying an important foundation for other compliance processes.

1cc helps you determine which EPR obligations arise in your relevant markets and which entity qualifies as the obligated producer in each case. TechProtect ensures that these requirements, packaging streams and responsibilities are structured and managed efficiently at an operational level. This allows you to maintain control over your EPR compliance even as your international sales activities expand.

Registration Is Only the Beginning

EPR compliance does not end with registration. Particularly when operating in several European markets, companies must keep track of different national requirements and manage their obligations on an ongoing basis.

For many companies, the most resource-intensive part of EPR compliance actually begins after registration. In the next article in our series, we explain why registration is only the first step and what really matters when it comes to ongoing EPR reporting.

Turn Europe's Compliance Patchwork into a Manageable Process

We help you gain a clear overview of which EPR obligations arise in which markets, which legal entity is responsible, and how operational implementation needs to be organised. This transforms Europe's complex compliance landscape into a manageable process.