EPR Registration: Who Must Register and What to Report
You sell clothing online from Germany into France, the Netherlands and Sweden. You have worked out that textile EPR applies to you. Now you need somewhere to send the registration. There is no single place to send it. In one of those three markets there is nothing to send yet.
EPR lives in EU law as a directive, and a directive does not register anybody. It tells Member States to build schemes. Each one then writes its own rules: who signs up, what you declare, how often you declare it.
At a glance:
- Registration duties arise under national law. There is no single EU register you can file once.
- Selling into a country from outside it does not avoid the obligation. Distance sellers are named in the directive itself.
- A producer established in another Member State must appoint an authorised representative in the market it sells into. That one is not optional.
- France and the Netherlands run live schemes. Sweden has none yet, and its design proposal is due on 13 November 2026.
- Member States must transpose by 17 June 2027. Schemes must be established by 17 April 2028, and the smallest firms are covered from 17 April 2029.
Why registration is national, not European
The legal home of EPR is the Waste Framework Directive, Directive 2008/98/EC. For textiles, Directive (EU) 2025/1892 of 10 September 2025 amended it. That amendment was published in the Official Journal on 26 September 2025. It entered into force on 16 October 2025.
Two dates matter. They sit in two different instruments. Article 2 of the amending directive sets one: Member States must transpose it into national law by 17 June 2027. Article 22a(14), as inserted into the Waste Framework Directive, sets the other. Member States must ensure the schemes are established by 17 April 2028.
Both dates bind governments, not you. Your own duty arrives when the national law says so. It arrives through the scheme that law sets up. For how schemes, producer responsibility organisations and fee modulation work, read what EPR is.
Who counts as the obliged party
The obliged party is the business a national scheme names as the producer, per product and per market. The label follows whoever first puts the garment in front of a buyer in that country. Not whoever made it.
The country detail below comes from two EU Horizon research deliverables, TRUSTex D4.1 and D4.5. They are published at ecosystex.eu. Both carry the note that the draft has not yet been validated by the granting authorities. Read them as research findings about how national schemes are built. Not as the text of the law. Confirm any row against the national instrument before you file.
| Country | Who must register | Caught when selling in from abroad | Local representative |
|---|---|---|---|
| France | Manufacturers and commissioners selling under their own brand, importers, private-label and licensed distributors | Yes. Online sellers and marketplaces are named even when based outside France | Not named in the research. Registration runs through the éco-organisme |
| Netherlands | Whoever places textile products on the market on a professional basis, irrespective of the selling technique used, B2B as well as B2C | Yes, by the same wording | Required for a manufacturer or retailer not established in the Netherlands |
| Hungary | The original manufacturer, or whoever makes the first domestic sale | Yes. Foreign sellers shipping direct to Hungarian consumers must register | Permitted, not required |
| Sweden (proposal only) | Nothing to register for yet. No scheme, no register, no fee | Not yet. A distance-selling limb appears in the 2020 proposal, not in law | Not yet decided |
| Italy (draft regulation) | Anyone first introducing finished textile products to the Italian market | Yes. Distance, online and tele-sales are named, as are rental and promotional giveaway | Not settled in the draft |
Two rows are not law yet. Italy's sits in a draft regulation. Italy's environment ministry records a favourable opinion on it, dated 23 July 2026. Nothing is in force there yet. The scope and fee picture is in the textile EPR post.
Sweden is the sharper trap. Older sources describe a 2020 proposal as though it were operative. There is no Swedish textile EPR today. Naturvårdsverket, the national environmental agency, states that how the producer responsibility will be designed in Sweden is not decided. It also states that the new rules start to apply in 2028. The government only gave it the design task in December 2025. Interim legislative proposals were due by 1 September 2026. The final report is due on 13 November 2026.
The case people get wrong: selling in from outside
Distance selling is supplying a customer in another country without holding an establishment there. Most first-time filers assume they can ignore it. It is the case the rules were written to catch.
The directive says so itself. Article 3(4b), point (d) of the amended Waste Framework Directive treats you as a producer. That is so if you sell in-scope products by distance contract to end users in a Member State. It bites whether you sit in another Member State or in a third country. Every live scheme in the table reads the same way. The Netherlands does not even ask about your selling method.
So the German brand in the opening paragraph is two registrations today, not three. One French, one Dutch, each on that country's terms. Sweden becomes a third when its scheme exists, and not before.
Marketplaces sit in an awkward spot. France, for example, names the marketplace itself as a producer. Where a scheme does that, the platform carries its own duty. It does not lift yours. From transposition the platform has to check you too. Article 22a(13) requires Member States to ensure online platforms obtain your registration number before they let you use their services. The number they want is the one for the Member State where the consumer sits. So get it in writing. Which of you registers, for which market, under which number.
When you need an authorised representative
An authorised representative is a person or company based in the country that takes on a foreign producer's scheme duties there. The scheme then has someone local to hold to account.
From transposition this stops being a per-country lottery for one large group of sellers. Article 22a(3) requires each Member State to ensure that a distance-selling producer established in another Member State appoints an authorised representative on its territory. That appointment is by written mandate. For a producer established in a third country the same article is weaker. It says only that Member States may provide for it. So that half stays national, and the intra-EU half does not.
Today the picture still varies, as the last column of the table shows. France's rules as reported name the duty but not a representative requirement. So check the scheme's own guidance before you file.
Plan for this early. A representative means a contract, a mandate, and a party willing to file on your behalf. That is weeks of work, not an afternoon.
The register you actually file with
A register of producers is the national list a Member State keeps of the producers its scheme covers. Article 22b of the amended directive requires every Member State to set one up. Each must also make producers register in it. So you hold as many registration numbers as you have markets. Each one is issued on local terms.
What scope you are registering for
The amended Waste Framework Directive sets a minimum scope in Annex IVc, written in CN codes. Every national scheme must cover at least that floor. Several go further.
The floor covers CN chapters 61 and 62 in full. That is all knitted and woven clothing. Part I adds household textiles and headgear, from blankets under 6301 to hats under 6505. It also adds worn clothing and other worn articles under 6309. Part II adds leather apparel under 4203 and footwear from 6401 to 6405. The country by country view, with fees beside it, is in textile EPR.
So your classification work decides your registration work. See what an HS code is for how those codes are built.
What you report, and how often
EPR reporting is the regular declaration of how much you placed on a national market, broken down the way that scheme asks. The scheme uses it to set your fee. It also uses it to measure the country's collection targets.
France shows the usual rhythm, and who issues what. You join an éco-organisme, Refashion for textiles. It then registers you in the SYDEREP declaration system. Your identifiant unique, the IDU, is issued by ADEME under Article L.541-10-13 of the Code de l'environnement. The éco-organisme passes it on to you. Your declaration of quantities is annual. Registered drop-off operators separately give the scheme collection data quarterly. So the reporting calendar has more than one clock in it.
A scheme and its operator are not the same age either. ADEME's own timeline for the textile stream puts the entry into force of the scheme at 2007. The producer responsibility organisation took its first approval in 2009, as Eco TLC. It now trades as Refashion. A claim that the scheme has run since 2007 through Refashion squeezes two separate facts into one.
Build the data collection before the deadline, not after it. A scheme keeps asking for the same three fields: volumes by product category, by material, and by market. An order management system rarely holds all three in one place.
Small firms, and the fee you cannot model yet
Two rules matter most if you are small. Only one of them is good news.
The first one delays the smallest producers. A new paragraph in Article 41 of the amended directive pushes their start date out to 17 April 2029. It covers enterprises that employ fewer than 10 persons. Their annual turnover and annual balance sheet must not exceed EUR 2 million. Read that as a year of grace, not an exemption.
The second is worse. Nobody can yet tell you what a durable product does to your fee. Article 22c(5)(a) ties fee modulation to the ecodesign requirements adopted under Regulation (EU) 2024/1781. None have been adopted for textiles. Article 22c(7) leaves the modulation criteria themselves to future Commission implementing acts. So there are no harmonised eco-modulation criteria today. Schemes such as France's set their own in the meantime.
What happens if you skip it
Sanctions sit in national law, not in the directive. They differ by country. Anyone quoting you a single EU penalty figure is guessing.
The practical problem bites first. A customer, a retailer or a platform asks you to show you are covered. Without a registration number you give an explanation instead. Explanations are what get orders paused.
Where Bindu fits. Bindu holds the product and market data that registration and reporting both run on. CN codes sit on every line. So you can see which national schemes a shipment touches. When a scheme asks for volumes by category and market, the answer comes out of one record. Not four spreadsheets. See how the packaging and product compliance workflow is put together.
FAQ
Do I have to register for EPR in every country I sell to? In practice yes, wherever you place products on that market and its scheme names you as the obliged party. Article 22b makes every Member State keep its own register. Related reading: what EPR is and what the PPWR is.
Source: Directive (EU) 2025/1892, Article 22b
Am I caught if I sell into a country from outside it? Generally yes. Article 3(4b), point (d) of the amended Waste Framework Directive treats a distance seller as a producer. That covers a seller established in another Member State or in a third country. France, Hungary and the Netherlands each catch the foreign seller in their own wording.
Source: Directive (EU) 2025/1892, Article 3(4b)
When do I need an authorised representative? From transposition, whenever you are established in one Member State and sell by distance contract into another. Article 22a(3) makes that appointment mandatory, by written mandate. For a third-country producer the same article leaves it to each Member State. The Netherlands already requires one from any manufacturer or retailer not established there.
Source: Directive (EU) 2025/1892, Article 22a(3)
Do I have to register in Sweden yet? No. Sweden has no textile EPR scheme, no producer register and no fee. Naturvårdsverket says the design is not decided. It also says the new rules start to apply in 2028. It reports its proposal to the government by 13 November 2026. So treat any Swedish registration duty as a 2028 planning item.
Source: Naturvårdsverket, producer responsibility for textiles
Is second-hand clothing inside the scope? Worn clothing under CN 6309 is part of the minimum scope in Annex IVc of the amended Waste Framework Directive. So it sits inside the EU floor. Member States may extend beyond that floor, and several do.
Source: Directive (EU) 2025/1892, Annex IVc
By when must the national rules be in place? Article 2 of Directive (EU) 2025/1892 sets one date: transposition into national law by 17 June 2027. Article 22a(14) of the amended Waste Framework Directive sets the other: schemes established by 17 April 2028. Some schemes, such as France's, already operate ahead of both. Sweden has not started yet.
Source: Directive (EU) 2025/1892, Article 2 and Article 22a(14)