Which EU rules apply to steel imported above the CBAM threshold?

EPR; extended producer responsibilityif packaging comes with it

If any packaging accompanies these goods; including transport and industrial packaging, which most member states count; you are the producer of that packaging in every country where you first place it on the market. For genuinely unpackaged bulk, check before assuming it applies. There is no EU-wide register: each state has its own scheme, number, fee and report.

• Packaging triggers it on its own; pallets, drums, wrapping and liners included in most states.
• You named 1 member state; that many separate registrations, each with its own register, number and fee.
• Register before the first sale into that country; several states treat selling without a number as an offence.
• From 12 August 2026, if you make packaging or packaged products available for the first time in another member state directly to end users, you must appoint an authorised representative for extended producer responsibility there, by written mandate and per country. Sell to a distributor established in that country instead and he is the producer there, not you.
• That first rule already covers you if you sit outside the EU and supply end users directly: Article 3(1), point (15)(c) and (d) says established in a member state or in a third country. Only if you sell to a distributor in that country instead is the mandate a member-state option rather than a duty.