If you are a small business wanting to sell products across Europe, you face a complex web of packaging compliance requirements. Under the new Packaging and Packaging Waste Regulation (PPWR), producers must register in each country where they sell. We commissioned independent research to explore the real-life experience of an Amazon seller going through the entire registration process in 10 EU countries. Our analysis revealed that the process looks significantly different in every member state today.
Under the Packaging and Packaging Waste Regulation (PPWR), producers must register and obtain Extended Producer Responsibility (EPR) registration numbers for packaging in every member state they operate. Online marketplaces must verify sellers' registration status before allowing sales. Yet across 10 EU countries, our research found 64 unique registration fields. Requirements range from 11 fields to over 20, averaging 16 per country. 55% of fields are country-specific, and 83% are required by just 3 countries on average.
Registration across multiple countries and categories is currently a complex, data-intensive, costly, and time-consuming process - creating potentially substantial barriers to selling goods across borders particularly for small and medium enterprises and foreign businesses selling in multiple countries. Fragmentation and complexity are seen in both the registration processes and registration data requirement across countries, driven by member states' discretion in implementing national systems to address local differences.
Registration process fragmentation
- Time and costs: Packaging registration can take between two and six weeks depending on the country and potentially longer for producers that need an authorised representative (AR) contract with service providers first. Registration costs through service providers are substantial and can multiply when operating across several countries and categories, especially for non-resident sellers requiring AR.
- Restriction on who can complete the registration process: Most countries limit who can complete the registration process - only the producer or an authorised representative. For example, in Germany, only the producer can register, while the AR cannot.
- Authorised Representative requirements are not governed by a single EU regime: Non-resident producers must appoint an AR in each country and product category where they operate, facing different requirements across EU member states. This fragmentation appears at multiple levels. Different EU regulations set different AR rules: the EU Battery Regulation requires ARs for all distance sellers, both EU and non-EU, with no exceptions, while the Packaging and Packaging Waste Regulation only requires ARs for EU distance sellers, letting member states decide rules for non-EU producers. Member states also interpret regulations differently, creating variations in AR obligations at the national level. Country-specific formalities add more complexity – Italy, for example, requires formal mandates for AR appointments, making the process difficult and expensive. Therefore, an AR approved under one regulation or in one country won't automatically work elsewhere. This creates a complex system that's especially hard to navigate for businesses without dedicated compliance or legal teams.
- Multiple authentication systems: Spain, Sweden, Poland, and Italy mandate national electronic ID systems to access and complete the registration process, while others use email-based authentication - creating technical barriers for cross-border sellers.
- Dual registration requirements: Italy, Spain and Poland have a two-step registration process, requiring sellers to register with both a national government registry and a Producer Responsibility Organisation, increasing time and administrative burden. In contrast, France, Belgium, Netherlands, Sweden and Ireland use a simple one-step process.
- Offline processes still exist: Belgium requires offline registration via email with manual forms and signed contracts, preventing digital scalability.
- Language barriers: Registration portals in many countries are only available in local languages, creating additional obstacles for international businesses.
Registration data fragmentation
Our research uncovered 64 unique registration fields across 10 EU markets—80% mandatory in at least one country. Requirements range from 11 fields (Belgium, Spain) to over 20 (Sweden), averaging 16 per country. The takeaway: no two countries ask for the same thing.
Even more concerning: 55% of fields (35 fields) are country-specific, and 83% of fields are required by an average of just 3 countries. This means there's no consistency – what one country requires, others don't.
For a business trying to sell across all 10 major EU markets, fragmented requirements create a compliance maze that demands navigating 10 different systems, each with unique processes, timelines, costs, and technical requirements. Businesses must master disparate portals, incompatible authentication systems, and divergent data requirements across member states. This makes compliance a resource-intensive burden that disproportionately impacts smaller participants.
Minimal harmonisation with EU standards
The disconnect with EU regulations is stark: only 17 of 64 fields are required in the draft PPWR Implementation Act Annex I. This means 73% of current requirements (47 fields) are not mandatory requirements as per the EU regulation, representing national additions that create compliance barriers.
On average, each country requests 8 fields (48%) beyond PPWR Implementation Act requirements. Countries are requesting reporting-stage data like packaging volumes and packaging material breakdowns at registration, when producers often don't yet have this information. Examples of excess information include transport company details, hazardous waste classifications, storage methods, and financial turnover – information that is not relevant for the core objective of registration: producer identification.
The interoperability solution
PPWR requires the European Commission to establish harmonised registration and reporting formats. This means also building interoperable infrastructure that enables data to flow efficiently between systems, countries, and even across different waste streams like packaging, batteries, and electronics. Interoperability is the foundation for making cross-border commerce work for businesses of all sizes while ensuring effective environmental protection across Europe.
Here's what interoperability makes possible:
- Seamless data exchange: Digitised and interoperable national registers with API access enable the seamless exchange of registration and reporting data between registries, producers, online marketplaces (OMPs), and fulfilment service providers. This allows all relevant parties to carry out registration, reporting, and EPR compliance checks on a scale.
- Single registration, cross-border reach: Standardised login processes, unified data fields, and automated data sharing remove the need for producers to navigate multiple different systems manually. A producer registers once with consistent information, provides standardised reporting data, and interoperable systems handle cross-border distribution — removing duplication and administrative burden.
- OMPs can act as EPR intermediaries to facilitate compliance: OMPs already hold most of the producer identification data needed for registration through their existing Know Your Customer processes. With interoperable systems, online marketplaces can help producers register by collecting any missing information and submitting it directly to registries, with proper consent and validation. This reduces friction for small producers and administrative burden for PROs and authorities, whilst driving compliance.
Online marketplaces present a proven pathway to scale compliance support. In France, Italy, Spain, and Belgium, they already act as EPR intermediaries for reporting and eco-fee payment. Amazon's Pay on Behalf programme demonstrates this model's effectiveness, reporting and paying eco-fees on behalf of over 300,000 sellers across five countries.
Extending this intermediary model to registration, while preserving AR frameworks for other obligations, would enable marketplaces to help producers meet core EPR obligations. This approach improves compliance and waste reporting accuracy, streamlines eco-fee collection, all while lowering administrative burden for producers and authorities alike.
A practical path to harmonisation
The European Commission's implementing acts represent a pivotal opportunity to build truly interoperable EPR infrastructure. Our analysis identified 37 fields that could be removed across the countries we studied, simplifying the producer’s experience while maintaining compliance integrity.
The vision is straightforward: member states establish digitised national registers as single sources of truth, built on existing EPR registries rather than creating new ones. These registers provide API access for automated compliance verification and streamlined registration. Registration requirements align with PPWR standards, focusing on producer identification rather than operational reporting. Innovative approaches, like marketplace EPR intermediary approach, leverage existing data and relationships to reduce barriers, especially for small and medium-sized enterprises.
When systems can talk to each other seamlessly, when data flows efficiently across borders, and compliance becomes a streamlined digital process — that's when we unlock the full potential of the Single Market while advancing environmental goals.
This blog post draws on research commissioned by Amazon. The findings were developed in an advocacy context to inform public policy discussions. Read full Amazon case study: Fragmentation in EPR packaging registration and opportunities to harmonize.
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