Summary

Extended Producer Responsibility (EPR) is no longer a niche policy for eco-conscious companies — it’s a growing legal obligation across the EU. In 2025, the landscape is shifting fast: France is expanding requirements, Spain and Portugal now mandate packaging labels, and a new EU regulation (PPWR) will unify EPR enforcement across member states. What sounds like a bureaucratic headache is, for the right companies, a chance to get ahead. In this post, we explain what’s changing, who’s affected, and how you can turn compliance into competitive advantage.
Stylized map of Europe with markers and icons representing EPR categories like packaging, electronics, and textiles, visualizing EPR changes in 2025.

The new reality: EPR is scaling fast

For years, EPR has quietly shaped the way producers handle the end-of-life stage of their products. But what used to be a fragmented landscape of national rules is now evolving into a standardized, EU-wide framework — with real consequences for those who don’t keep up. EPR compliance has become a prerequisite for market access, especially in e-commerce and cross-border sales. Brands that fail to comply may no longer be allowed to sell in their target markets.

In 2025, the pace is accelerating. France is tightening its EPR laws and demanding more transparency on environmental characteristics from brands. Denmark, Portugal, Spain, Luxembourg, and the UK are rolling out new rules that expand the scope of EPR to include packaging labelling, commercial waste, and in some cases, new registration platforms. And the Packaging and Packaging Waste Regulation (PPWR) — set to replace the existing EU directive — will make compliance not only necessary, but uniform across all 27 EU member states.

If your company sells physical products in Europe, the question is no longer if EPR applies to you. It’s how well prepared you are to deal with it.

Who is affected by EPR? (Hint: probably more companies than think)

One of the most common misconceptions about EPR is that it only applies to packaging manufacturers or industrial producers. But in legal terms, the “producer” is defined as the company that introduces packaged goods into a national market — and that can include importers, retailers, D2C brands, and online marketplaces.

Let’s say you run a German e-commerce shop and ship products to France. Even if you didn’t manufacture the packaging, you are the first entity to place it on the French market. That makes you the producer under EPR law — and therefore responsible for registering, reporting, and paying relevant fees. This applies across product categories, from packaging and electronics (WEEE), to batteries, textiles, and in some cases, even toys or furniture.

Online marketplaces are also in the spotlight. Platforms like Amazon are already enforcing EPR compliance by requiring sellers to provide valid registration numbers. If sellers don’t comply, they risk being blocked. In some cases, the marketplaces themselves may be forced to take over producer responsibility — a legal liability that’s pushing them to clean up their vendor lists. In other words, the EPR net is widening, and it’s catching a lot more businesses than many realize.

🗺️ 2025 EPR Updates: What’s Changing, Country by Country

EPR is becoming more harmonized at the EU level — but national requirements still matter. Here’s a breakdown of the most important changes that came into effect in 2025 across key countries:

🇫🇷 France

France has extended its EPR obligations to include industrial and commercial packaging. Companies with more than €10 million in annual revenue must now inform customers about environmental characteristics of their products — including packaging, electronics, textiles, and furniture. France remains one of the most comprehensive EPR markets, already covering categories like toys and mattresses as well.

🇪🇸 Spain

As of January 2025, all household packaging must display sorting labels to guide proper disposal. Commercial packaging is now also subject to licensing. These rules affect both local businesses and cross-border sellers shipping into the Spanish market.

🇵🇹 Portugal

Portugal introduced a similar labelling requirement for household and commercial packaging, although implementation details remain less standardized. Licensing obligations have also been extended to include commercial packaging, although questions remain about enforcement and responsible parties.

🇩🇰 Denmark

A new national EPR system for packaging was launched in 2025, requiring all producers to register with the Danish Dansk Producentansvar (DPA) authority. The system is similar to Germany’s LUCID register and aims to bring transparency to packaging flows.

🇱🇺 Luxembourg

Luxembourg now places greater accountability on importers, requiring them to license industrial packaging from the beginning of 2025. This is a shift from focusing only on local manufacturers to all market entrants.

🇬🇧 United Kingdom

The UK launched PackUK, a centralized EPR administrator that now manages registration, fee collection, and payment of waste management costs to local authorities. This reform shifts the financial burden of packaging waste away from the public and onto businesses.

Circular diagram illustrating Extended Producer Responsibility in English, with labeled steps like (Re-)Manufacturing, Store, Usage, Collection, and Recycling.

From burden to business model: what smart brands are doing differently

Let’s face it: at first glance, EPR looks like a cost. Registration fees, paperwork, legal uncertainty — it’s easy to treat it as another compliance headache. But forward-looking brands are flipping the script. They see EPR not just as an obligation, but as a gateway to a smarter product lifecycle — and to closer, more circular customer relationships.

Some use EPR as a springboard to introduce take-back programs or second-use services. Others revisit their packaging design to reduce complexity and cost — in many cases, finding that switching to simpler, more recyclable materials doesn’t just tick a regulatory box, but actually cuts shipping costs and waste. And brands that are transparent about their EPR compliance can position themselves as trustworthy partners in B2B procurement or consumer-facing sustainability communication.

At koorvi, we see this shift every day. Companies come to us because they need to deal with EPR. But they stay because they realize the same infrastructure can be used to take back products, assess their condition, refurbish them, and resell them with full transparency. It’s not just about avoiding fines — it’s about unlocking value after the first sale.

Practical first steps: What you can do now

If you’re selling physical products in Europe, you need to get your EPR strategy in place — today, not tomorrow. That starts with identifying which categories you fall under. Packaging is the most common, but electronics, batteries, and textiles are increasingly covered by national EPR schemes.

Then, map out your target markets. If you’re placing products on the market in more than one country, you likely need to register separately in each of them. This includes joining national EPR schemes, paying the associated fees, and keeping up with annual reporting obligations.

Packaging labels are another area to address urgently. The new requirements in Spain, Portugal, and France are already in force, and the rules may vary depending on whether you sell to households or businesses. In parallel, your internal systems need to track material types, volumes, and sales by destination country — data you’ll need for EPR reporting, and that’s best handled by automated tools.

Finally, ask yourself how you can go beyond compliance. Are you already collecting used products? Could your packaging be easier to sort or reuse? Are you considering resale as a service? The infrastructure you build for EPR can be the same one you use for circular growth.

EPR isn’t optional — but it can be profitable

2025 marks a turning point for Extended Producer Responsibility in Europe. What was once a scattered set of national rules is becoming a unified, enforceable standard. Whether you sell headphones, strollers, or electric kettles — if you put products on the EU market, you’ll be held responsible for what happens after the sale.

The good news? Responsibility can be profitable. Companies that build the right systems now won’t just avoid risk — they’ll gain control over their second markets, increase customer loyalty, and stand out in an increasingly regulated landscape.

Most businesses still treat EPR as a compliance issue. But the best ones will treat it as a business model.

👉 Want to turn regulation into retention, and compliance into circular growth? Let’s talk.

FAQs

Do I need EPR registration if I sell on Amazon or my own webshop in Europe?

Yes — if you’re selling physical goods to customers in EU countries, you’re likely considered a “producer” under EPR law. That includes Amazon sellers, Shopify brands, and D2C webshops. You need to register with the national EPR systems in each country where your products are placed on the market. Without valid registration numbers, marketplaces can block your listings — and in some cases, hold you legally responsible.

What does the new EU Packaging Regulation (PPWR) change for businesses?

The PPWR replaces the previous EU Packaging Directive and introduces binding rules on recyclability, reuse quotas, and reporting — across all 27 member states. For businesses, this means stricter design requirements, standardized labelling, and a lot more scrutiny on packaging materials. It’s not just about compliance anymore — it’s about designing your packaging and product flows for a circular future.

How do I know if I count as a “producer” under EPR?

EPR doesn’t just apply to manufacturers. If you package products, import them, or sell them cross-border (even via dropshipping), you may legally be considered the first entity to place them on a national market — and that makes you the “producer.” This holds true whether you’re a small brand shipping abroad or a global distributor working across multiple countries.

What are the EPR labelling rules in Spain, France, and Portugal?

In 2025, all three countries introduced new rules for mandatory packaging labels. These labels must show consumers how to sort packaging materials correctly for recycling. France and Portugal also require environmental disclosures for some product categories. If you sell into these markets, it’s your responsibility to ensure your packaging is correctly labelled — regardless of where you’re based.

How can I manage EPR compliance across multiple EU countries?

Managing EPR in multiple countries means juggling local registers, languages, reporting cycles, and legal frameworks. The key is to centralize your data, standardize your packaging reporting, and use tools (like koorvi or other platforms) that help you track, report, and automate compliance. Bonus: the same systems often support take-back programs and resale initiatives — turning compliance into circular growth.

Can EPR be turned into a business opportunity?

Absolutely. While EPR starts with compliance, it often becomes the foundation for something much more strategic. Brands use EPR infrastructure to power take-back programs, resell refurbished products, design better packaging, and win trust from increasingly eco-conscious B2B buyers and consumers. At koorvi, we help companies build systems that do both — protect the planet, and grow the business.