What are the Extended Producer Responsibility (EPR) requirements for packaging and what do I need to do?

EPR is a policy approach whereby producers take physical or financial responsibility for the end-of-life management of their products and their packaging. EPR is one of the most important pillars to ensure circularity in the EU. 

Every company that puts certain products, including batteries, or packaging on a national market is EPR responsible and has to ensure its EPR compliance by participating in an EPR system - the so-called Producer Responsibility Organisations (PROs). 

These organisations manage the process of taking back products and ensuring their proper disposal. This involves setting up recycling infrastructure, which is funded by fees that the producers pay to the PROs, based on the quantity of products they introduce to the market.

In order to ensure that their products are EPR-compliant, companies therefore register with a PRO, report the quantity of products sold, and pay the respective fee to the PRO. 

EPR for packaging has already been rolled out in most European countries for a number of years. The new PPWR has now made EPR for packaging mandatory throughout all EU member states. This means that from 12 August 2026, all member states must enable producers to be able to register their packaging. 

The PPWR also includes a mandatory compliance system for marketplaces that operates as follows: 

Each online marketplace - in this instance, Zalando - is required to ensure that partners are EPR-compliant. To comply with this provision, we must be able to prove that our partners who sell in the respective countries via Zalando have been registered with the respective PRO for packaging. To do this, Zalando will collect the national EPR registration details from our partners.

Partners, in turn, are responsible for registering with the relevant PRO and ensuring that they are compliant to be able to continue selling on Zalando. 

A producer refers to "any natural or legal person who develops, manufactures, handles, processes, sells or imports waste-generating products or the elements and materials used to manufacture them”. Please note that a producer is not the equivalent of a manufacturer.

For the purposes of EPR, a producer is the company that first brings packaging onto one of the national markets. The decisive factor is therefore who brings the packaging onto the national market.

In the case of a company selling its products directly to end-users, it is the distant seller i.e. the company selling online. For Zalando and our partners, this therefore refers to partner brands as well as most retailers. 

However, if a retailer works with an upstream supplier in the same country who is considered a producer as defined above (e.g. an importer or a manufacturer), the retailer is not considered a producer.

Please be aware that EPR refers both to primary packaging (product packaging) as well as secondary packaging (shipping packaging) added by you.

Please reach out to the relevant PRO that you are registered with, or a local PRO in the country you need to register in, if the classification between producer/non-producer raises questions.

If you are a ZFS partner, then ZFS takes care of the shipment, meaning the secondary (shipping) packaging is the responsibility of ZFS. You don’t need to report the secondary shipping packaging to the PRO and you don’t need to provide Zalando with EPR details for it.

In the context of EPR for packaging, an upstream supplier refers to a supplier of a retailer that is located in the same country as the retailer, such as an importer or manufacturer. The importer or manufacturer who first brings the packaging onto one of the national markets is therefore considered the producer in the respective country for EPR purposes.

The EU PPWR makes EPR for packaging mandatory in all EU member states. Most EU member states have already introduced EPR for packaging, or are expected to introduce EPR shortly. The date of implementation of the new PPWR is 12 August 2026.

From that date, we will begin collecting EPR details in zDirect for the following countries: 

• Belgium 

• Croatia

• Denmark 

• Estonia 

• Finland 

• Greece 

• Hungary 

• Lithuania 

• Luxembourg 

• Poland 

• Slovakia

• Sweden

We strongly recommend that you begin the EPR registration process in all countries that you sell or are planning to sell in, so you’re ready to share your EPR packaging details when further countries are available in zDirect.

EPR refers both to primary packaging (product packaging) as well as secondary packaging (shipping packaging) added by you.

Within the EPR requirements, packaging means an item, irrespective of the materials from which it is made, that is intended to be used for the containment, protection, handling, delivery or presentation of products. This includes primary packaging (e.g. polybags, shoe boxes, hangtags) and secondary (shipping) packaging (e.g. boxes, bags, filling materials, tapes, shipping labels).

If you are classified as a producer, you must register for EPR in each country you sell. There is no EU-wide registration. 

Please also note that there are other EPR requirements for batteries, electronic products and textiles, as well as some other categories, in addition to packaging. 

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