EPR Filing in Europe: Pitfalls and Practical Steps
Cross-border e-commerce sellers and packaging exporters selling into Europe who skip EPR registration and compliance filing face delisted products and frozen funds on Amazon, Temu and AliExpress.
Germany’s Packaging Act (VerpackG): A Practical Four-Step Method
- Step 1: Register a LUCID account with the ZSVR: Register free of charge on the official system and obtain a LUCID number starting with “DE”.
- Step 2: Contract with an approved dual system (Dual System): Choose a cooperating recycler (such as Interseroh, Der Grüne Punkt or BellandVision). Buy recycling quotas based on the weight of cartons, plastic film, tape and other packaging you expect to export to Germany that year, and pay the recycling fees.
- Step 3: Report the dual-system contract back to the LUCID platform: Submit the contracted recycler’s name and the purchased material quantities to LUCID to close the data loop.
- Step 4: File the year-end actual-weight reconciliation report early the following year: Declare on actual shipped weights, with overpayments refunded and shortfalls topped up.
France’s Packaging Rules and the New Triman Labeling Requirements
- Filing platform: Citeo, the officially authorized French organization.
- Mandatory Triman labeling:
- Since 2023, France has prohibited printing only a simple recycling loop (Möbius loop); packaging must carry both the Triman badge and the Info-tri sorting guidance box.
- The disposal category of each packaging component must be stated clearly in French (for example: “Le couvercle et la boîte se recyclent” — the lid and the box are recyclable; place in the yellow bin).
- Penalties: For goods with missing or incorrect labeling, French customs may seize the shipment and impose fines of up to €15,000.