Do marketplaces really check, or is that a threat? they check
They check, because the obligation is on them too. Where a member state requires it, the platform must verify that a seller is registered before allowing sales into that country, and platforms enforce by restricting listings rather than by warning. A missing number is the most common reason an otherwise healthy listing stops selling in one country only.
Full answer — the grounds, the numbers, the pitfalls
The pattern to recognise: your listing is fine in the Netherlands and blocked in Germany, or fine everywhere and blocked in France. That is not a product problem; it is a registration problem in one country.
What resolves it:
- Register in that country's scheme and obtain the number.
- Enter it in the platform's producer-responsibility fields, per country and per stream.
- Keep it current; numbers lapse when the scheme contract does.
Because the platform carries liability, appeals that argue the product is compliant do not move it. Only the number does.
Source: national EPR laws imposing verification duties on online marketplaces; platform seller requirements. Checked: 3 September 2026.
12 August 2026: what exactly changes? one per member state
From that date the EU Packaging Regulation requires a producer who supplies end users in that state directly — Article 3(1), point (15)(c) and (d), which covers a seller established in a member state or in a third country — must appoint an authorised representative for packaging there, in every member state other than the one where he is established (Article 45(3), first subparagraph). Selling to a distributor in that country instead makes him the producer there; for other third-country producers the mandate is a member-state option, not a duty. It is not one EU-wide appointment: it is one per member state where you place packaging and are not established. Sell into eight, appoint eight.
Full answer — the grounds, the numbers, the pitfalls
This catches two groups who had not needed a local presence before:
- Non-EU sellers shipping direct to EU consumers.
- EU sellers selling cross-border; a Dutch company selling into Germany, France and Spain is not established there and needs a representative in each.
The representative registers you, reports your packaging volumes and pays the fees on your behalf. That does not move the liability off you; it gives the member state someone locally answerable.
What to do before the date: list the member states you actually ship packaging into, check where you are established, and start with the states where you have the most volume; appointment and registration both take time, and the deadline is the same day for everyone.
Common mistake: reading it as an EU-wide appointment. There is no single desk; the arithmetic is per country, like the rest of EPR.
Source: Regulation (EU) 2025/40 on packaging and packaging waste, Article 45(3) (a producer must appoint, by written mandate, an authorised representative for extended producer responsibility in each member state where it makes packaging available for the first time other than the state where it is established), with Article 44 (the national register) and Article 45(4) (the verification duty on online platforms); Article 71 sets the date of application at 12 August 2026.
Checked: 5 September 2026.
I have been selling without registering. What now? register first
Register, then deal with the past. Schemes generally expect the volumes you already placed on the market to be declared and paid for, and a late registration does not erase the earlier period. What it does do is stop the breach continuing; which is the part that grows.
Full answer — the grounds, the numbers, the pitfalls
The order matters, because each step reduces the next problem:
- Register and contract with a scheme now. Every day of continued selling adds to the exposure and is the easiest thing to prove against you.
- Declare the historic volumes. Schemes have a route for this. Estimating conservatively and documenting the estimate is better than silence.
- Expect the platform check to clear only after the number exists. Reinstatement follows registration, not the other way round.
In Germany there is a second exposure worth naming: because the register is public, a competitor can see the gap and act on it under competition law, independently of any authority.
Common mistake: waiting for an authority to make contact. In the states where this bites, the first letter usually comes from a competitor or a marketplace, not a regulator.
Source: VerpackG and the ZSVR register's public nature; national scheme practice on retroactive declaration. This is the area where national law differs most; take advice for the specific country. Checked: 3 September 2026.