Table of Contents
Direct sales to end customers (B2C E-Commerce) via online shops and marketplaces offer enormous growth opportunities. However, for retailers who ship their products across borders, Extended Producer Responsibility (EPR) quickly becomes a complicated hurdle.
In pure B2C e-commerce, you are the first distributor in every European destination country to which you deliver directly, and you are therefore subject to a legal obligation.
Mastering International EPR Complexity
Outsource all country-specific obligations with our Partner RecycleMe’s end-to-end solution and secure global legal certainty while focusing on your core business.
Request now
EPR: The obligation of the distance seller
EPR is an environmental policy instrument that stipulates that the party who places products on the market for the first time in a country is responsible for the subsequent disposal and recycling of the product packaging. For selected product groups, the return of the products themselves must also be ensured (such as waste electrical equipment or batteries).
In cross-border B2C business, this means that as soon as you, as a foreign trader, deliver directly to private end customers in another country, you are considered a “manufacturer” or “importer” there and are subject to EPR obligations.
The relevance of packaging in e-commerce
Packaging obligations are particularly important for e-commerce. This applies not only to product packaging, but also to the shipping packaging (cardboard boxes, filling material) that you use to send the goods to the end customer.
Other EPR categories that frequently affect B2C retailers include, for example:
- WEEE (electrical equipment): If you sell electronics (from mobile phones to coffee machines).
- Batteries/rechargeable batteries: If these are included in your devices or sold separately.
- Textiles: If you ship clothing or home textiles (in countries with textile EPR).
The problem of national fragmentation
The biggest challenge for B2C e-commerce retailers is the lack of European harmonisation. Each target country has its own regulations and systems:
- • Registration requirements: In many countries, you must register with national registers (such as LUCID in Germany) and / or (if there is no national register) with a collective take-back system before making your first sale.
- • Financial obligations: You must pay licence fees to national take-back systems for the quantity of packaging material placed on the market (by weight and type of material).
- • Labelling requirements: Some countries, such as Italy and France, have specific requirements for environmental labelling on packaging.
Please note: Under the EU Packaging Regulation (PPWR), the new, standardised labelling requirements for packaging must be complied with from August 2026. - • Authorised representative: Non-resident companies must appoint an authorised representative in some countries (e.g. France and Austria for WEEE).
Please note: Under the PPWR, the obligation to appoint an authorised representative will be extended to all EU countries from August 2026.
How to navigate B2C EPR obligations
The crucial step for distance sellers is to identify the exact obligations for the respective target country and the relevant product category.
A structured approach includes:
- Country selection: Determine all countries to which you deliver directly to end customers.
- Category check: Check which of your products (packaging, WEEE, batteries, etc.) are EPR-relevant in these countries.
- Obligation comparison: Clarify the registration, licensing and reporting obligations for each country-category combination.
EPR Requirement Monitor
A precise analysis of country-specific EPR (Extended Producer Responsibility) requirements is essential for expansion into new e-commerce markets.
This analysis ensures the legal compliance of your logistics and market access. Specialised services such as the EPR Requirement Monitor provide a customised report tailored to B2C business.
