Sprache: DE

Distribution within the EU 
Frequently Asked Questions from Manufacturers, Online Retailers, Importers, and Distributors

1. In which countries am I obliged to register?

1.1 In which countries must I register electrical or electronic devices?

In all EU countries, electrical devices must be registered before being placed on the market, regular quantity reports must be submitted, and advance payments must be made for professional collection and disposal. Annual final statements are used to precisely settle the actual quantities placed on the market each year. This applies not only, but especially, to online retailers.

1.2  In which countries must I register batteries or devices with batteries?

In all EU countries, batteries must be registered before being placed on the market, regular quantity reports must be submitted, and advance payments must be made for professional collection and disposal. Annual final statements are used to precisely settle the actual quantities placed on the market each year. There is an EU regulation that every member state must implement 1:1. This applies not only, but especially, to online retailers.

1.3 In which countries must I register my packaging?

By 2025, all EU countries must implement regulations for extended producer responsibility for packaging. The last EU country that still has to implement this is Denmark. The introduction is planned for 01.04.2024.

Go to the blog post "Denmark: Single-Use Plastic Directive and Packaging Registration"

In all other EU countries and the United Kingdom, different national obligations already apply to the distributors of packaging, especially, but not only, for online retailers.

1.4 Do I have to register as an online retailer in every EU country?

Yes, as an online retailer distributing to private end consumers, you must register your electrical devices, batteries, and packaging in every EU country to which you sell. Exceptions for packaging only apply to Denmark and some countries with de minimis limits or special regulations, which we can check individually for you. These include Belgium, the Netherlands, Italy, and for 2023, Finland. In the United Kingdom, there are also certain special regulations for packaging. In France, additional product groups must be registered and reported separately, such as furniture, toys, sports and leisure items, garden tools, textiles.

2. In which countries do I have to print markings on the packaging?

In the area of Extended Producer Responsibility (EPR), a handful of EU countries have individual labeling obligations, such as Italy, France, Portugal, and Bulgaria.

We offer a special consulting service on labeling obligations.

In addition, markings for single-use plastic products must also be applied.

Here's the link to the blog post: "European Union: EU Single-Use Plastic (SUP) Directive"

3. Distribution to Retailers and Distributors Abroad

3.1 I deliver to retailers and distributors abroad in the EU, what are my own obligations?

Initially, your buyers, i.e., the local retailers, are responsible for fulfilling the obligations of Extended Producer Responsibility for the products and packaging they import, depending on national regulations. However, it is always necessary to consider both the supply chain due diligence law and the fact that, especially if you are listed as the manufacturer on the packaging or products, you can still be approached by authorities. At this point, it is recommended to either take over the obligations yourself and price them in or to have all purchasing distributors provide the respective registration numbers, etc.

3.2 My commercial buyers abroad say they take care of EPR obligations and registrations, what do I need to consider?

On the one hand, you should consider the supply chain due diligence law, and on the other hand, you should be aware that there is an increased risk of being contacted by authorities if you are listed as the manufacturer on the exported packaging and products. Therefore, you should at least get the registration numbers from all countries and all commercial buyers. Alternatively, in most countries, you can also take over the EPR obligations for your products abroad yourself and pass on the costs to the buyers at your own discretion/negotiation.

4. I have been placing products on the market for some time, can I register retroactively?

This is regulated differently in EU countries. There are countries like France, Belgium, or Spain that allow retroactive licensing when registering anew.

5. Are there different regulations in every EU country that affect me?

In the areas of packaging and electrical appliances, the EU has so far provided directives. This means that each EU member state can implement these specifications differently in legal terms. In the area of packaging, this has led to particularly individual regulations and definitions. In the area of batteries, there has been a new EU regulation since 2023, which must be implemented 1:1 by all states, so that the regulations must be the same everywhere. In France, there are additional EPR areas such as furniture, garden tools, toys, etc. Therefore, only there, these product groups also prescribe additional regulations for market participants. For the area of textiles, there are regulations so far in France and the Netherlands, but by 2025 every EU country must legally implement this topic.

6. I run a small business (under 5 employees), are there different regulations for me?

There are no general exceptions for micro-businesses. Especially if you distribute to private end consumers as an online shop, you are subject to your Extended Producer Responsibility in all EU countries. However, particularly in the area of packaging, there are countries with certain exceptions (e.g., if one does not have a branch) and de minimis limits. The latter are in place, for example, in the Netherlands, Belgium, the United Kingdom, and currently still Finland.

7. Is there an Extended Producer Responsibility for areas outside the usual three EPR streams (electrical appliances, batteries, packaging)?

Yes, particularly in France, there are a total of 12 EPR product areas, which include, for example, furniture, garden tools, toys, sports and leisure articles, or printed products. At the EU level, there is a requirement that all member states must introduce EPR regulations for textiles by 2025. France and the Netherlands have already implemented this first.

7.1 What regulations apply to textiles?

Currently, only France and the Netherlands have the obligation to register textiles as part of the Extended Producer Responsibility (EPR), report quantities, and financially provide for the proper return and disposal. However, an EU directive also mandates all other member states to legally implement this EPR sector by 2025.

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