Summary

Whether you're selling packaging, electronics, or batteries: if your products reach customers in Germany, you're legally responsible for their entire lifecycle. That's what Extended Producer Responsibility (EPR) demands, and 2026 brings real changes: the new BattDG battery law, the ElektroG4 amendment, and the EU decision on mandatory textile EPR. In this blog, we break down what companies need to know, how registration works, what happens in case of non-compliance, and how koorvi helps turn legal duties into scalable systems.
Digital illustration showing the German and EU flags, a cardboard box and a laptop – visualizing EPR regulation updates in Germany and Europe.
Update, June 2026: Since 7 October 2025, the Battery Law Implementation Act (BattDG) has replaced the old BattG, and the EU has made EPR for textiles mandatory (transposition by June 2027). This article reflects the current state.

What does EPR actually mean?

Extended Producer Responsibility (EPR) is a regulatory framework that makes companies accountable for their products from cradle to grave – including collection, take-back, recycling, and safe disposal. The goal is simple: reduce waste, promote recycling, conserve resources.

In Germany, EPR is implemented through specific laws:

These laws define how companies must register, report, finance, and manage the post-consumer phase of their products.

Textiles are next: Directive (EU) 2025/1892 came into force on 16 October 2025 and introduces mandatory EPR for textiles and footwear across the EU for the first time. Member states must transpose it by 17 June 2027, and working EPR systems must be in place by 17 April 2028. Germany is currently drafting its textile law, with stakeholder comments open until 24 April 2026. France has shown for years how textile EPR works in practice. For fashion and home-textile brands, the window to build take-back, sorting, and resale structures is now, before the obligation arrives. The reform is part of a broader EU push that also includes the upcoming Circular Economy Act.

Who is affected?

In short: every business placing regulated products on the German market. This includes:

  • Domestic manufacturers based in Germany
  • Importers delivering goods to Germany
  • Online sellers and marketplaces like Amazon, eBay, Zalando
  • Foreign direct-to-consumer brands shipping to German customers

Even small businesses and startups are not exempt. Since 2022, many platforms like Amazon have made EPR proof mandatory for sellers to stay live. So compliance isn't just a legal topic – it's also about business continuity.

What do companies need to do to stay compliant with EPR?

The path to EPR compliance is well-defined, but not without effort. Here's what businesses need to do:

1. Register with the relevant authorities

Depending on the product category, companies must register with different bodies:

  • Packaging: Central Packaging Register (LUCID)
  • Electronics & Batteries: Stiftung EAR

Registration is mandatory and the basis for legal distribution. Since the BattDG took effect, battery producers register per battery category and brand; the transition period for converting old BattG registrations ended on 15 January 2026.

2. Apply for an EPR registration number

Each product category (packaging, electronics, batteries) requires a separate number. This acts as proof of compliance for authorities, platforms, and partners.

3. Report product volumes

Companies must regularly declare the types and quantities of goods they place on the market – by weight, material, and product class.

4. Pay license fees

Fees are calculated based on declared volumes and product types. They fund the collection, sorting, and recycling of waste via Producer Responsibility Organizations (PROs).

5. Meet recycling quotas

Minimum recycling rates apply by law depending on product category. Companies must ensure their systems meet those thresholds.

Step-by-step guide to becoming EPR-compliant in Germany in 2026 – including icons for registration, EPR number, product data, license fees, and recycling targets.
This is how you can comply with the EPR regulations in Germany in 2026.

What happens if you don't comply?

Non-compliance can be costly. Consequences include:

  • Sales bans on German marketplaces and retailers
  • Fines up to €200,000
  • Legal warnings from competitors under unfair competition law
  • Reputational damage, especially for brands with sustainability claims

Platforms like Amazon and Zalando now strictly require EPR compliance. No proof = no sales.

EPR as a strategic opportunity: more than just compliance

EPR is often viewed as a legal burden. But with the right perspective, it becomes a business asset:

  • Trade-in programs and credit systems improve customer loyalty
  • Take-back and reuse models create secondary revenue streams
  • Brands gain more control over material flows and supply chains
  • And EPR can become a proof point for sustainability in brand positioning

👉 See how Apple uses EPR and trade-ins to grow revenue.

How koorvi helps companies manage EPR

koorvi isn't just a tool for compliance. It's a full infrastructure for circular business models. Our platform helps you go from obligation to opportunity:

  • Digital return and registration forms integrated with CRM/ERP
  • Automated product volume tracking & fee calculation
  • Item-level tracking by category and origin
  • Integrated network of recycling, logistics, and refurbishment partners
  • Compliant documentation for EAR, LUCID, and marketplaces

EPR doesn't have to be a hassle. With koorvi, it becomes a competitive advantage. Let's speak!

FAQs

What does Extended Producer Responsibility (EPR) mean in simple terms?

Extended Producer Responsibility (EPR) means producers remain responsible for their products after consumers discard them, including collection, recycling, and proper disposal. In Germany, EPR is implemented through the Packaging Act (VerpackG), the ElektroG for electronics, and the BattDG for batteries. The goal is to reduce waste and close material loops.

What changes for EPR in Germany in 2026?

Three things. The BattDG has replaced the old Battery Act since 7 October 2025, with registrations per battery category and brand and a conversion deadline of 15 January 2026. The ElektroG4 amendment brings new take-back and labeling duties from 1 July 2026. And the EU has adopted mandatory EPR for textiles, which Germany must transpose by June 2027.

Do I need a separate EPR number for each product category?

Yes. Packaging requires registration with the Central Packaging Register (LUCID), electronics and batteries with Stiftung EAR, and each category gets its own registration number. Since the BattDG, battery producers register per battery category and brand. Marketplaces like Amazon check these numbers per category before activating listings.

What happens if a company does not comply with EPR regulations?

Non-compliance risks sales bans on German marketplaces, fines of up to €200,000, and legal warnings from competitors under unfair competition law. Platforms like Amazon and Zalando block listings without valid EPR proof. For brands with sustainability claims, the reputational damage often outweighs the fine.

Is EPR for textiles coming?

Yes, it is already decided. Directive (EU) 2025/1892 has been in force since 16 October 2025 and obliges member states to introduce EPR for textiles and footwear by 17 June 2027, with working systems in place by 17 April 2028 at the latest. Germany is drafting its textile law now. Fashion and home-textile brands should build take-back and resale structures before the obligation kicks in.