An analysis commissioned by Amazon has identified significant differences in the national registration processes for extended producer responsibility (EPR) for packaging across Europe. The case study examines the requirements in ten EU member states and calls for greater harmonisation in the wake of the implementation of the European Packaging and Packaging Waste Regulation (PPWR).
With the PPWR, Regulation (EU) 2025/40, manufacturers will in future have to register packaging in every Member State where they first place packaging on the market. At the same time, online marketplaces and fulfilment service providers will be obliged to check the EPR compliance of their traders. According to the analysis, this opens up the possibility of greater harmonisation of registration and reporting processes across Europe.
The study analyses the registration procedures in Germany, France, Spain, Ireland, the Netherlands, Portugal, Sweden, Poland, Italy and Belgium. Amazon states that it identified a total of 64 different registration fields, with considerable national variations. 55 percent of these fields are only requested in a single country.
Different requirements lead to significant effort
According to the study, the countries investigated require an average of 15 registration details per company. The range extends from eleven fields in Belgium and Spain to 21 fields in Sweden. Around 87 percent of the data requested is mandatory.
The analysis critically assesses additional national requirements that go beyond the intended PPWR specifications. Only 27 percent of the recorded data fields are directly provided for in the annexes of the planned PPWR implementing act. 73 percent of the information requested goes beyond this.
The study cites sales data, packaging quantities, product categories, transport information, and national special identification as examples. In the authors' view, such information belongs in later reporting processes rather than in the actual registration.
Amazon criticises lack of digitalisation
The investigation sees additional hurdles in national authentication systems. In Spain, Sweden, Poland and Italy, national electronic identity procedures are required to complete registrations. Other countries, however, rely on e-mail-based procedures.
The study also identifies missing interfaces as a problem. National registers often have neither APIs nor possibilities for the automated verification of registration numbers. This makes it particularly difficult for online marketplaces to carry out compliance checks on large numbers of traders.
Belgium is also cited in the analysis as an example of particularly complex processes, as parts of the registration there continue to take place offline via email and contract signing.
Suggestions for a uniform EU-wide system
Among other things, the authors recommend standardising login and authentication procedures, abolishing duplicate registrations with national registers and system operators, and fully digital registration processes.
Furthermore, the study proposes expanding national registers into central digital data platforms with API access. In the future, according to the authors' vision, online marketplaces could automatically transmit registration data to authorities and system operators, provided traders agree.
Source: Amazon
