Germany EPR Compliance for E-Commerce Sellers 2025: Key Requirements

Germany is one of the EU countries that has implemented an extensive Extended Producer Responsibility (EPR) compliance framework for various categories of products. The nature of EPR requirements demands that a large group of businesses involved with these categories of products establish an EPR compliance system. 

The scope of persons responsible for EPR compliance includes, among others, electronic marketplaces that facilitate third-party supplies to end customers. To move forward, the responsibility also covers fulfillment service providers that are in partnership with the platform, online retailers, and retailers that are paying fees to the platform for using its fulfillment services. 

EPR German Framework 

Extender Producer Responsibility is a concept primarily introduced as an environmental policy that holds producers of selected types of products responsible for waste management throughout the entire product lifecycle. 

The concept producer by the EPR legislation is very extensive, and it covers manufacturers, importers, distributors(sellers) of the products. After the latest legislation, the German EPR framework counts four different categories of products, for which the producers have an obligation to adhere to the EPR regime. 

The definition of the producer according to the EPR framework covers a broad variety of persons that are part of the supply chain for the product categories, which have so far been “determined” by the respective Government, as the ones that have the highest environmental impact that could be and should be regulated. 

One of the most common mistakes made by retailers and platform operators when it comes to understanding EPR legislation is the default perspective that the “producer” equals the manufacturer. This isn’t the case. 

The applicable legislation defines that the producer shall be“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”.

These four product categories are: 

• Packaging 
• Electric and Electronic Equipment(EEE) 
• Batteries 
• Single-Use Plastics(SUP)

The introduction of the EPR German framework has unequivocally added significant responsibility to the e-commerce platforms that operate in the country. Platform operators have been added with additional responsibility to develop a validation and monitoring system concerning the proper EPR compliance of the registered platform sellers(underlying suppliers). 

Distant sellers that use the e-commerce marketplace to sell products that belong to one of the categories that are covered by the EPR mandate, directly to the end customers whose place of residence is in Germany, are responsible to register in the proper EPR register, to provide the EPR number to the platform operator, and to acquires services of the certified EPR service provider. 

How to Stay Compliant

E-commerce marketplace operators and online retailers should be aware of the EPR compliance framework that has been in place in Germany for several years. The businesses that are “labelled” as producers according to the EPR requirements in Germany should get familiar with different rules before the start of their business activity in the country. 

At 1stopVAT, we are actively monitoring EPR developments across Europe, with a particular focus on the responsibilities of e-commerce merchants. If you have any questions regarding the EPR registration process or your VAT compliance responsibilities for your business operations in Italy, please don’t hesitate to contact us. Our tax team would be happy to assist you.

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