info@ecopv-eu.com

+49 6196 5835357

info@ecopv-eu.com

+49 6196 5835357

Frequently Asked Questions

We have the answers to your EPR compliance questions regarding WEEE, batteries, and packaging.

You can find even more interesting facts here in our News section.

Learn more in our blog posts or browse through our FAQs.​

VerpackG und PPWR FAQ: Häufig gestellte Fragen zu gesetzlichen Vorgaben für Verpackungen

Schnell-FAQ: Verpackungsgesetz & PPWR

Mit dem Übergang vom deutschen Verpackungsgesetz (VerpackG) zur neuen EU-Verpackungsverordnung (PPWR) kommen weitreichende Änderungen auf Unternehmen zu. Was passiert am 12. August 2026? Ab diesem Datum gilt die EU-Verpackungsverordnung (PPWR)

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Frequently Asked Questions About EPR (Extended Producer Responsibility)

EPR Basics

EPR stands for “Extended Producer Responsibility” and is the European environmental principle under which distributors bear financial and operational responsibility for their products throughout their entire life cycle – from manufacturing to final recycling. In Germany, EPR is implemented through the ElektroG, the BattDG, the VerpackDG, and the EWKFondsG.

 

This concept shifts waste disposal costs from local governments and taxpayers directly to the private sector. The goal is to create financial incentives for recycling-friendly product design. In practice, EPR means you are subject to a strict registration requirement in national registries, ongoing volume reporting, and financial contributions to waste management systems. Anyone who fails to comply with these obligations is acting illegally and risks sales bans as well as hefty fines.

In Germany, statutory EPR compliance comprises four main pillars: packaging, electrical appliances, batteries, and single-use plastic products. Each product category has its own regulatory agencies, reporting cycles, and deadlines.
 

The four pillars are structured as follows:

  • Packaging: All sales and transport packaging must be reported in the LUCID registry. Since August 12, 2026, this requirement has been based on the Packaging Act Implementation Act (VerpackDG) and the EU Packaging Regulation (PPWR).
  • Electrical Equipment (WEEE): All products that require electricity or generate electromagnetic fields (including PV modules) fall under the ElektroG and must be registered with the EAR Foundation.
  • Batteries: All battery types (from button cells to PV storage batteries) are subject to the Battery Implementation Act (BattDG) and must be reported in the EAR Battery Registry.
  • Single-Use Plastics (EWKFondsG): Certain takeout packaging, tobacco filters, and fireworks require an annual special levy through the DIVID portal of the Federal Environment Agency.

The EPR concept was developed in Sweden in the 1990s to give manufacturers a direct economic incentive to build more durable products. The European Union adopted the principle in the 2000s and enshrined it in its key waste directives.

 

Germany implemented this European legislation gradually through standalone national measures such as the Battery Act and the Packaging Act. Since this patchwork of national regulations made cross-border e-commerce extremely difficult, the EU will radically harmonize the legal framework in 2026. Through directly applicable EU regulations – such as the new EU Battery Regulation and the PPWR for packaging – the same design standards apply throughout Europe, which we continuously monitor to support your international market presence.

EPR is an EU-wide environmental principle. Every EU member state requires producers to cover disposal costs; however, the administrative implementation – in the form of registries and fees – continues to vary from country to country.

 

The foundation is made up of common European guidelines that are implemented at the national level. With the EU regulations set to take full effect in 2026 – the EU Battery Regulation and the PPWR for packaging – the European Union is radically standardizing the rules of the game in the single market. With the ElektroG, the new VerpackDG, and the BattDG, Germany is among the pioneers in comprehensive monitoring. Anyone exporting to multiple EU countries must comply separately with the respective national reporting requirements, which we manage centrally on your behalf.

A traditional tax flows into the general government budget without being earmarked for a specific purpose. EPR fees, on the other hand, are strictly earmarked and directly finance the collection, sorting, and recycling of products.

 

With a tax, the company has no influence over how the funds are used. EPR fees (such as dual system licenses or PRO contributions), on the other hand, go directly to the waste management and recycling systems, which use them to operate the infrastructure. In addition, EPR directly rewards environmentally friendly behavior: A recycling-friendly packaging design or a reduction in plastic content immediately lowers your individual EPR costs through the statutory bonus systems.

Voluntary sustainability (e.g., CO2 offsetting, ESG reporting) is a corporate initiative that companies may choose to undertake without legal consequences. EPR obligations, on the other hand, are mandatory under strict law – violations result directly in fines and sales bans.

 

A strong commitment to environmental sustainability never exempts you from statutory reporting requirements. Even if a product consists of 100 percent biodegradable materials, it must be registered with the LUCID registry or the EAR Foundation. However, voluntary measures and legal compliance complement each other economically: Companies that voluntarily optimize their products in line with “Design for Recycling” principles are rewarded with significantly lower licensing fees when filing mandatory EPR reports.

Who Is Affected (Roles & Responsibilities)

Anyone who makes products or packaged goods available on the German market for the first time on a commercial basis is responsible. This applies to traditional manufacturers, importers, brand owners, and foreign online retailers who ship directly to German end customers.

 

The decisive factor is the principle of first placing on the market, not the physical location of the company’s headquarters. Anyone who purchases goods abroad and offers them for sale in Germany via their own online store, Amazon, or eBay is legally considered a manufacturer. If you distribute a product under your own private label, you also bear full responsibility.
Pure resellers of goods already registered in Germany are exempt from product packaging requirements, as the obligation remains with the upstream supplier.

 

Important: If, as a reseller, you put your own shipping packaging (cardboard boxes, filler material, tape) into circulation, you must always license it yourself.
Legal responsibility generally remains with the company and cannot simply be delegated to upstream suppliers or customers under civil law. Administrative compliance (such as packaging licensing) is handled through dual systems. Foreign companies without a German branch may also appoint an EPR Authorized Representative in Germany who fully assumes the legal obligations on their behalf.

Under EPR law, a manufacturer is defined as the party that first places the product on the German market – regardless of whether they physically produce or import it. Distributors are purely retailers who resell already registered branded goods without modification.

 

If you import goods from abroad, the law automatically classifies you as a manufacturer. Pure distributors do not have primary data reporting obligations but are subject to a strict verification requirement: If you offer products from manufacturers who are not properly registered, an immediate sales ban takes effect, and you are liable for the violation. If you distribute goods produced by third parties under your own brand name, you immediately become the manufacturer with full legal responsibility. This distinction is critical for dropshippers and e-commerce retailers.

EPR compliance requires full compliance with four basic obligations: registration with the authorities, ongoing reporting of quantities, connection to a recycling system, and financing of the entire recycling process.

 

Depending on the product category, specific additional obligations apply: Packaging requires registration in the LUCID registry and a dual-system license. Electrical appliances require EAR registration, including an insolvency-proof financing guarantee. Batteries require affiliation with a Produicer Responsibility Organization (PRO). Single-use plastics require fee processing via the DIVID portal. All data and disposal routes must be documented in an audit-proof manner. We handle these operational processes as a bundled service for your company.

Yes. The legal EPR obligations apply without exception starting with the very first item sold. There are no revenue thresholds, minimum quantities, or grace periods for founders or small business owners.


Many startups unwittingly fall into the compliance trap because they underestimate the strict rules in e-commerce. Large online marketplaces automatically verify registration numbers electronically – if verification is missing, listings are blocked before going live. A violation leads not only to account suspensions but also to retroactive estimates by regulatory authorities and hefty fines. The good news for founders: While the administrative burden remains the same, the ongoing recycling fees scale with the actual weight, so the costs for small quantities are very low.

The registration and data reporting obligations take effect upon placing the product on the market and apply equally to both B2B and B2C providers. Differences primarily lie in the take-back channels and the financing of waste management logistics.


While B2C products are recycled through household-based collection (recycling centers, dual systems), B2B products usually require their own commercial take-back systems. The Packaging Act (VerpackDG), effective as of August 2026, significantly tightens regulations in the B2B sector: Membership in Producer Responsibility Organizations (PRO) is now also gradually becoming mandatory for commercial transport and industrial packaging. The EU labeling requirements under the PPWR (Packaging and Packaging Waste Regulation) make virtually no distinction between B2B and B2C. Those serving mixed customer groups must strictly separate the quantities reported in the EAR and LUCID systems.

Registration & Process

The registration process consists of several stages and is divided into a detailed product analysis, the submission of data to the authorities, and the subsequent system connection. Sales are only legally compliant once all steps have been completed

 

First, we analyze your product portfolio, as each product category (WEEE, batteries, packaging, single-use plastics) has its own regulatory portal. After digitally submitting your company data and tax IDs, the critical step follows: finalizing disposal contracts with dual systems or Producer Responsibility Organizations (PRO). While activation in the LUCID packaging registry usually occurs immediately, the application review by the EAR Foundation typically takes four to eight weeks due to warranty checks.

No. Neither the German nor the European EPR system has any minimum thresholds, minimum sales thresholds, or exemption limits for registration and participation in the system. The obligations apply without exception starting with the very first gram placed on the market.


Anyone who commercially offers even a single shipping carton, a button cell battery, or an electronic component must be fully registered in advance. The only exception regarding additional administrative obligations: Under the EWKFondsG, the requirement to submit an expensive, externally audited auditor’s report is waived for annual quantities below 100 kilograms – however, registration and the per-kilogram fee to the UBA must still be paid starting with the very first product. Anyone who relies on supposed exemption thresholds risks immediate marketplace bans.

The reporting frequencies are mandated by law and vary significantly depending on the product category and distribution model (B2C or B2B). While electrical appliances in the B2C sector require fixed monthly reporting obligations, the reporting intervals for packaging and batteries depend heavily on the contractual requirements of the take-back systems; however, they must be reported to the central registries by the specified deadlines.
 

The cycles in detail:

  • ElektroG (WEEE): For B2C devices, the quantities placed on the domestic market (actual input reports) must be reported to the EAR Foundation monthly by the 15th day of the following month in order to calculate the pickup coordinates. For purely B2B devices, an annual report submitted by April 30 of the following year is sufficient for input reporting. Reports on output (self-collection and indirect exports) as well as annual statistics must be submitted uniformly for both device types (B2C and B2B) only once a year by April 30 of the following year via the EAR portal.
  • VerpackG / PPWR: Requires a forecast of planned quantities at the beginning of the year as well as a final actual report (year-end report) by May 15 of the following year via the LUCID portal. Important: Any interim reports during the year (monthly or quarterly) are subject to the thresholds of your chosen dual system and must be immediately and exactly replicated in the LUCID portal.
  • BattDG: Registration and the legally required volume reports on product placement on the market are handled centrally via the EAR Foundation’s portal. The legal reporting obligation to the EAR Foundation is annual. The frequency of interim reporting (e.g., quarterly) is determined by the contractual terms of the respective Product Responsibility Organization (PRO) selected.

A collective system is a government-approved waste management network that organizes the collection, logistics, and final recycling of waste on behalf of the business community. Manufacturers fulfill their legal take-back obligations by paying fees to these systems.


Instead of each company setting up its own prohibitively expensive take-back infrastructure, these organizations consolidate the recycling streams. For packaging, the dual systems handle curbside collection (yellow bags). For batteries, authorized Producer Responsibility Organizations (PROs) manage fire-safe logistics and recovery in accordance with the Battery Act (BattDG).


We at ECOPV-EU are ourselves one of the few state-authorized PROs for used device batteries in Germany. This allows us to consolidate official registration and operational recycling directly in-house.

The insolvency-proof guarantee is a legal requirement for B2C electrical appliances under the ElektroG. It ensures that the disposal of end-of-life appliances is financially secured in the event that the manufacturer becomes insolvent.


Without this proof, the EAR Foundation will not issue a WEEE registration number, which results in an immediate sales ban. The guarantee prevents disposal costs from being passed on to the general public or remaining market participants in the event of insolvency. The amount is calculated individually based on tonnage and category-specific recycling costs. Bank guarantees or escrow accounts tie up liquidity unnecessarily.
We provide you with a state-recognized, collective guarantee system. This saves you time-consuming bank audits and significantly speeds up your EAR application.

Before beginning the registration process, you must conduct a comprehensive inventory of your product range. You need to determine which of the four EPR pillars apply, which target countries you export to, and who is legally considered the manufacturer.


The most costly mistake in EPR compliance is overlooking overlapping obligations. For example, if you distribute an electronic product with a built-in battery in a shipping carton, you must complete three separate registrations (WEEE, battery, packaging) at the same time. You must also verify whether you import the goods yourself or purchase them domestically. If you do not have a registered office in Germany, you are required to appoint a domestic authorized representative.

You must archive all registration notices, monthly and annual volume reports, PRO and system contracts, as well as the corresponding invoices, in an audit-proof manner.

 

Market surveillance authorities may request these records retroactively at any time. The statutory retention period for EPR documents in Germany is ten years.
In the event of an audit by the EAR Foundation, the Central Packaging Register (ZSVR), or the relevant market surveillance and state authorities, you must provide complete proof that the reported figures in kilograms and metric tons exactly match your actual sales reports and delivery notes.
Missing documents are classified as an administrative offense and result in heavy fines, even if fees have been paid.
We manage your EPR documentation in a legally compliant and digital manner within our system so that you can provide information immediately during official audits.

Costs & Cost-Effectiveness

The costs typically consist of a registration fee, ongoing license or recycling fees based on the quantity sold, and, if applicable, costs for an Authorized Representative or a guarantee fund. The amount depends heavily on the product category, material type, and volume sold.

 

For packaging, license fees are based on the material and weight of the packaging placed on the market. For electrical appliances, in addition to EAR registration, there are often costs for an insolvency-proof guarantee as well as pro-rata disposal costs. For batteries, Producer Responsibility Organizations (PROs) handle collection and recycling in exchange for a volume-based fee. Added to this are potential costs for an Authorized Representative abroad, as well as internal or external expenses for ongoing reporting and documentation. Companies that must manage multiple product categories simultaneously often benefit from bundled full-service packages that offer registration, reporting, and warranties from a single source at competitive rates, thereby reducing administrative burdens and hidden follow-up costs – such as those resulting from missed deadlines or duplicate registrations.

The operational implementation – registration, reporting, guarantees, and authorization – can be fully transferred to specialized EPR service providers. However, the legal responsibility as a manufacturer remains with the company itself; the service provider handles the practical administration, not the legal liability.

 

Many companies make a conscious decision to handle the complex and frequently changing EPR requirements not internally, but through a specialized full-service provider. Such service providers typically handle registration in the relevant registries, ongoing volume reporting, the provision of guarantees, and – if necessary – act as local authorized representatives in various EU countries. This reduces internal administrative burden, lowers the risk of missing deadlines, and consolidates multiple product categories – such as packaging, electrical appliances, batteries, and single-use plastics – under a single point of contact.

 

ECOPV-EU, for example, is a specialized provider based in Eschborn that offers precisely this full-service EPR solution, including its own guarantee system and acting as an authorized representative for foreign companies. Important to note: The legal manufacturer responsibility formally remains with the company; the service provider acts on its behalf and ensures legally compliant and timely implementation.

International Trade & EU Countries

No. EPR registries are organized on a national basis – a German registration with EAR or LUCID is valid exclusively for the German market. A separate, independent registration is required for each additional EU country in which you place products on the market for the first time.

 

There is currently no EU-wide, unified EPR registry. Each member state has its own implementing laws, registration agencies, and reporting formats: Germany uses EAR and LUCID, France uses its own environmental organizations, and the Netherlands uses a centralized digital reporting system. Companies that sell across borders must therefore register separately in each target country and comply with the applicable deadlines, reporting cycles, and fees in each location. For companies not headquartered in the respective country, there is often an additional requirement to appoint a local authorized representative. The EU Packaging Regulation (PPWR) is intended to partially harmonize this patchwork system starting in 2026, but it does not replace the national registries themselves. For growing companies, this means that every new expansion into a target market requires its own EPR review, which is why many providers opt for a centralized, cross-border compliance partner.

An EPR Authorized Representative is a person or company based in the EU that fulfills a manufacturer’s EPR obligations in the destination country on behalf of that manufacturer, who does not have a local presence there. This requirement applies primarily to electrical equipment and batteries; for packaging, it has been in effect EU-wide since August 2026 under the PPWR.

 

Companies without a branch in the respective EU country often cannot register there themselves and must therefore appoint a resident authorized representative in writing. For electrical equipment, this is already standard practice in almost all member states; for batteries, the requirement has applied since August 2025 for cross-border shipments by manufacturers without a local presence. For packaging, the rules were inconsistent – some countries, such as France, Spain, or Austria, required an authorized representative, while others did not; since August 2026, this has been mandatory for all EU member states under the EU Packaging Regulation (PPWR). The authorized representative typically handles registration, ongoing reporting, and communication with authorities and registries.

 

Specialized service providers such as ECOPV-EU offer this service for the ElektroG and BattDG and also assist companies with the PPWR, so that foreign companies do not have to establish a separate structure for each country.

Any business that sells to end customers across national borders triggers its own EPR obligations in each destination country – including separate registration, reporting, and, in some cases, the appointment of a local authorized representative. Cross-border trade thus multiplies the administrative burden for each additional sales market.

 

As soon as a company ships products to another EU country and delivers them to end customers there, it is considered the first distributor in that country and must comply with the respective national EPR requirements – regardless of whether it is already registered in its home country. This applies to registries, reporting deadlines, language requirements, and, in some cases, the obligation to appoint a local authorized representative. For growing online retailers, this means that every new expansion into a target market requires its own compliance review before the first sale takes place. Failure to do so may result in the same consequences in the target country as in the home market: fines, sales bans, or marketplace suspensions. Since national registries, deadlines, and fee structures vary widely, it is often worthwhile for internationally active retailers to work with a central compliance partner who coordinates the processes across multiple countries, rather than seeking out local contacts for each market individually.

Despite common EU directives, national EPR systems differ significantly in terms of registry structure, reporting deadlines, fee models, and language. Germany, for example, uses EAR and LUCID; the Netherlands uses a centralized digital reporting system; and France relies on several industry-specific environmental organizations.

 

The EU directives merely provide a legal framework; the specific implementation remains the responsibility of the member states. This leads to noticeable differences: While Germany operates two separate registries – EAR (electrical equipment) and LUCID (packaging) – the Netherlands consolidates many reports through a central digital portal. France, on the other hand, requires separate, specialized eco-organizations for individual product groups – such as textiles, furniture, or packaging – each operating independently. Fee structures also vary widely – ranging from flat-rate annual fees to tiered pricing based precisely on the type of material. For international companies, this means that successful registration in one country does not necessarily indicate the level of effort required in another.

The EU Packaging Regulation (PPWR) is intended to gradually reduce this fragmentation, but a fully unified EU system does not yet exist.

Any expansion into a new EU country triggers its own EPR obligations there, regardless of existing registrations in the home market. Before the first sale, the registries, deadlines, authorized representative obligations, and costs in the target country should be reviewed, and registration should be completed.

 

From an EPR perspective, expansion should be planned before – not after – market entry, as registration in some countries can take several weeks, and sales without a valid registration would be illegal from the outset. First, it must be determined which national registry is responsible, whether a local authorized representative is required, and what deadlines and fee structures apply. Since the systems vary considerably between member states, the effort required in one market cannot simply be applied to another. Companies expanding into multiple countries simultaneously – for example, as part of a pan-European e-commerce strategy – benefit particularly from central EPR partners who coordinate registration and ongoing support for multiple target markets, thereby enabling a parallel market launch without compliance delays.

E-Commerce & Marketplaces

In principle, the seller remains responsible, but marketplace operators are also legally liable. Due to strict legal platform liability requirements, Amazon, eBay, and other marketplaces are obligated to thoroughly verify their sellers’ EPR compliance. Without proof of valid registration numbers, a strict, automatic sales ban applies.

 

Even if the marketplace merely provides the technical infrastructure, it may not allow unregistered sellers to sell, as the platforms themselves would otherwise risk heavy fines and sanctions from the authorities. Large marketplaces therefore check fully automatically and in real time whether valid registration numbers – such as a WEEE number (ElektroG) or a LUCID number (VerpackDG/PPWR) – are stored in the seller’s account for listed products. If this information is missing or incorrect, the listing is immediately deactivated or the entire seller account is suspended. For sellers, this means that the registration numbers for each target country and each product category must be accurate, as even the smallest discrepancies can lead to sudden account suspensions and revenue losses that threaten their business.

Sanctions & Monitoring

Violations of EPR regulations are considered administrative offenses and can result in substantial fines of up to 100,000, 200,000, or, in some cases, even 500,000 euros. In addition, companies face immediate official sales bans, automated marketplace suspensions, and costly cease-and-desist letters from competitors.

 

Depending on the product category, oversight is carried out by various federal agencies and regulatory bodies – such as the Central Agency for Packaging Registration (ZSVR) for packaging or the EAR Foundation for electrical appliances. Those who are not registered or report incorrect quantities risk not only regulatory fines but also immediate exclusion from the market: Due to statutory platform liability, marketplaces such as Amazon, eBay, or Temu are required to verify registration numbers (such as LUCID or EAR) in real time and immediately suspend incomplete accounts. In addition to direct financial penalties, affected companies face revenue losses and reputational damage that could threaten their very existence. Since authorities across Europe are significantly tightening their controls and digitally cross-checking national registries, the probability of remaining undetected as an unregistered “free rider” has dropped to zero.

Competent authorities such as the Central Packaging Register (ZSVR), the EAR Foundation, or market surveillance authorities digitally cross-check registers, conduct random inspections, and are increasingly using automated systems to monitor listings on online marketplaces.

 

The monitoring mechanisms vary depending on the product category but are increasingly carried out digitally and in a networked manner. The ZSVR, for example, cross-checks reported packaging volumes against the volumes licensed by dual systems and can initiate fine proceedings in the event of discrepancies. The EAR Foundation verifies whether electrical appliances offered on the market have a valid WEEE number, including by cross-referencing with marketplace data. In addition, authorities and customs are increasingly scrutinizing imports to identify unregistered goods at the border. Consumer protection organizations and competitors are also increasingly reporting missing registrations, which can lead to cease-and-desist letters. Due to the growing digitization of registries and the exchange of data between authorities and marketplaces, the frequency of inspections is expected to continue to increase in the coming years.

If an audit reveals a lack of registration, the business faces severe fines from the authorities, retroactive license fee payments for all quantities already sold, and an immediate official ban on sales. While EPR law does not provide for criminal consequences (such as imprisonment or a criminal record), authorities can, however, fully confiscate any profits obtained unlawfully.

 

Unlike with everyday administrative offenses, the penalties for EPR violations have extremely harsh retroactive effects: Inspectors estimate, based on customs and import data, accounting records, or platform sales figures, how many products have been placed on the market unregistered since the business began operations. On this basis, authorities impose fines, while the dual systems or Producer Responsibility Organizations (PROs) demand payment of the regular recycling fees for past years down to the last cent. In addition, an immediate sales ban is imposed. Since registration (particularly for electrical appliances through the EAR Foundation) can take several weeks, this leads to revenue losses in online retail that threaten a company’s very existence. If a company notices a missing registration on its own, it should rectify the situation as quickly as possible through a full-service provider to preempt discovery by the authorities and the associated penalties.

Product Line Changes & Growth

Yes. Each EPR product category – packaging, electrical appliances, batteries, single-use plastics – has its own registry and its own registration processes. For example, if you are already registered as a packaging manufacturer and also sell electrical appliances, you need a separate WEEE registration with the EAR Foundation.

 

The individual EPR registries are legally and organizationally independent of one another, even if they pertain to the same company. An existing LUCID registration for packaging does not replace the required EAR registration for electrical appliances or the affiliation with an Producer Responsibility Organization for batteries. For companies expanding their product range – such as a packaging manufacturer that also introduces battery-powered products – this means that an additional, separate registration is required before the new product category can be sold. If this is overlooked, the same penalties and sales bans apply to the new category as if there were no registration at all. It is therefore advisable to check early on – ideally during the product development phase – whether any expansion of the product range triggers additional EPR obligations for new product categories.

Each new product type may trigger its own EPR obligations – such as an additional report on new packaging materials, a new category of electrical appliances, or an additional battery type. Existing registrations must be updated accordingly, and quantities must be recalculated.

 

EPR registries generally require the most accurate classification possible of the products offered, as fees and recycling rates are derived from this information. If the product range is expanded – for example, to include a new type of packaging material or an additional category of electrical appliances – the existing registration must be adjusted accordingly, and the projected quantity must be reported again. In the case of entirely new product types – such as a company that previously dealt exclusively in packaging beginning to sell battery-powered devices for the first time – a completely new registration in a different registry may even be required. Companies should therefore always accompany product line expansions with a brief EPR review before new products go on sale. Those who work with a full-service partner can usually report such changes easily without having to go through the entire registration process from scratch.

Future & Developments

EPR law is currently undergoing a period of intensive reform: The EU Packaging Regulation (PPWR) has been in effect since August 2026, the new Battery Regulation has been phased in since 2023, and other product groups, such as textiles and furniture, are under discussion. Significant changes can be expected several times a year.

 

Unlike established areas of law, EPR law is currently evolving at a particularly rapid pace, as the EU is promoting the circular economy as a central goal of the European Green Deal. In recent years alone, the ElektroG has been amended several times (currently ElektroG4), battery law has been fundamentally reformed by the new BattDG, and the PPWR has introduced, for the first time, an EU regulation rather than a directive for packaging – regulations are directly applicable in all member states. In addition, work is underway on EU-wide regulations for textiles, furniture, and other product groups. For companies, this means that a one-time registration does not provide lasting certainty – deadlines, categories, and reporting requirements can change within a matter of months. Regular monitoring of legal developments or a specialized compliance partner is therefore particularly valuable right now.

The Digital Product Passport is a digital documentation system planned for EU-wide implementation that enables the traceability of a product’s origin, material composition, and recyclability throughout the entire supply chain. It complements EPR obligations by creating transparency for authorities, recyclers, and consumers.

 

Under the EU Ecodesign Regulation and the new Battery Regulation, the Digital Product Passport will be phased in for various product groups, starting with batteries and textiles, among others. The goal is to make information on material origin, repairability, carbon footprint, and recycling processes digitally and permanently accessible, for example via a QR code on the product. For companies, this means a significantly more comprehensive documentation requirement throughout the entire supply chain, as suppliers, manufacturers, and distributors must provide data in a standardized manner. In conjunction with EPR, the DPP reinforces the trend toward greater traceability: While EPR governs the financial and operational responsibility for disposal, the Product Passport ensures the corresponding transparency. Companies that already document their EPR data accurately are significantly better prepared for the upcoming DPP requirements.

2026 marks a major turning point: Since August 2026, the EU Packaging Regulation (PPWR) has been directly applicable in all member states and, among other things, has made it mandatory to appoint an authorized representative for packaging throughout the EU. At the same time, many companies are continuing to implement the requirements of the new Battery Implementation Act.

 

The PPWR is gradually replacing the previous Packaging Directive and, in the long term, parts of Germany’s Packaging Act (VerpackG) with directly applicable EU law. Key changes include, among other things, mandatory minimum recycled content requirements, stricter guidelines for excess dimensions and empty volume in packaging, and the EU-wide requirement to appoint an authorized representative for companies not headquartered in the respective country, particularly in B2C online retail. For electrical appliances and batteries, the transition periods from earlier reforms (ElektroG4, BattDG) continue to run in parallel, with increasingly stringent reporting and labeling requirements.

 

Companies must also begin intensive preparations as early as 2026 for the Digital Product Passport, which will become mandatory for the first product groups starting in February 2027. Companies should also check whether the PPWR requires them to appoint an authorized representative for the first time – even if this was not previously the case – since the scope of affected companies is expanding significantly.

At the EU level, there is discussion about expanding EPR obligations to include additional product groups, particularly textiles and furniture. Regulations concerning tires, mattresses, or certain building materials are also already being tested or prepared in some member states.

 

As part of the European Green Deal and the Circular Economy Action Plan, the EU aims to gradually extend EPR principles to an increasing number of product categories. The discussion is most advanced regarding textiles, where individual countries such as France have already introduced their own producer responsibility systems, and an EU-wide obligation starting in 2028 has already been decided. National EPR systems also exist in individual member states for furniture, mattresses, certain building materials, and tires, which could be harmonized across Europe in the future. For companies outside the traditional EPR categories of packaging, electronics, and batteries, it is therefore worthwhile to regularly monitor legal developments in their industry, as new obligations are often introduced with relatively short transition periods. Those who stay informed early on can adjust their processes and budgets in a timely manner, rather than having to react to new regulations at the last minute.

ECOPV-EU as a Partner

ECOPV-EU is a full-service provider specializing in Extended Producer Responsibility (EPR), based in Eschborn, that supports manufacturers and retailers with ElektroG/WEEE, batteries (BattDG), and VerpackDG/PPWR – from registration and ongoing reporting to acting as an authorized representative.

 

Since 2020, ECOPV-EU has been helping companies implement the complex and frequently changing EPR requirements in Germany and the EU in a legally compliant manner. The full-service offering includes registration with relevant authorities such as the EAR Foundation, ongoing volume reporting, the provision of insolvency-proof guarantees for electrical appliances, and the operational collection, logistics, and recycling of used batteries as an authorized Producer Responsibility Organization (PRO). For companies without a registered office in Germany, ECOPV-EU also acts as an official representative vis-à-vis the EAR Foundation and other authorities. The goal is to relieve manufacturers and retailers of administrative burdens so they can focus on their core business, while ECOPV-EU coordinates registration, reporting, guarantees, and take-back through a single point of contact.

EPR Categories: Frequently Asked Questions About Individual Product Groups

WEEE & ElektroG4

PV & Photovoltaics

Battery & BattDG

VerpackDG & PPWR

EWKFondsG

Your officially authorized partner for Extended Producer Responsibility (EPR).

Comply with all WEEE, battery, and packaging regulations in a legally compliant manner now!

Contact

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info@ecopv-eu.com

+49 6196 5835357

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65760 Eschborn