The EPR number in EU countries
Extended producer responsibility (EPR) is a key component of environmental policy in the European Union. It requires manufacturers, importers and distributors to take responsibility for the entire life cycle of their products – from production through to disposal. This guide explains what an EPR number is, how it is implemented in Germany as the LUCID number and how EPR registrations work in other EU Member States.
What is an EPR number?
An EPR number is a registration number issued to manufacturers, importers or distributors when they make products available in an EU country that fall under extended producer responsibility. EPR requires companies to bear the costs of collecting, recycling and disposing of their products or packaging. Depending on the country, this primarily affects product categories such as packaging, electrical equipment, batteries, textiles, furniture and toys.
The EPR number serves as proof that a company is registered with the competent national authority or a take-back scheme. It is especially important for online retailers selling through platforms such as Amazon or eBay, as marketplaces may request the EPR number to verify compliance with environmental rules. Without a valid EPR number, sales bans or account suspensions may occur.
The legal framework for EPR has changed significantly in recent years. Depending on the product category, the rules are now based on different legal instruments:
Packaging: Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied directly in all Member States. It replaced the former Packaging Directive 94/62/EC, although certain provisions of that Directive continue to apply during the transition period. Unlike a directive, the PPWR does not need to be transposed into national law; it is supplemented by national legislation.
Batteries: The EU Battery Regulation (Regulation (EU) 2023/1542) has applied to batteries since 2023. It replaced the former Battery Directive 2006/66/EC, which was repealed on 18 August 2025.
Electrical and electronic equipment: The WEEE Directive 2012/19/EU continues to apply to electrical and electronic equipment. It is implemented through national law in each Member State; in Germany, this is the Electrical and Electronic Equipment Act (ElektroG).
Because two of these areas are now governed by directly applicable EU regulations, while electrical equipment remains subject to a directive, EPR numbers and registration processes continue to differ from country to country and between product categories.
We advise you on all matters relating to the VerpackDG/PPWR:
The EPR number in Germany is the LUCID number
In Germany, the EPR number for packaging is equivalent to the LUCID number issued by the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR). Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied directly in all Member States. It regulates packaging requirements and the roles of economic operators.
At national level, the PPWR is supplemented by the Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG), which replaced the previous German Packaging Act (Verpackungsgesetz, VerpackG) on 12 August 2026 and sets out responsibilities, enforcement rules and supplementary provisions.
The obligation to register is determined by the PPWR definition of manufacturer in Article 3(1)(15)(a) to (e). The obligation to register with the ZSVR arises from Section 6 VerpackDG. This includes manufacturers under the PPWR and, under certain conditions, companies that unpack packaged goods. Registration must take place before packaging is made available in Germany.
After registration, you receive your LUCID number. This number consists of the country code “DE” and a 13-digit sequence, and it can be viewed in the LUCID dashboard. In addition to registration, companies must participate in a dual system for packaging subject to system participation in order to finance collection and recovery costs. The LUCID number must be entered in seller accounts on online marketplaces such as Amazon or eBay to demonstrate compliance with packaging rules.
The LUCID Register remains in place. Since 12 August 2026, the ZSVR has also been the competent EU register authority under the PPWR (Article 44(1) in conjunction with Section 6(6) VerpackDG).
EPR numbers in EU Member States
EPR requirements vary across the 27 EU Member States. While the core principles of EPR are similar, registration processes, competent authorities and relevant product categories differ. The following is an overview of EPR systems in selected EU countries.
Belgium: Companies must register with organisations such as Fost Plus or Valipac for packaging. Registration for electrical equipment is required with Recupel, and for batteries with Bebat. There are no de minimis thresholds, so even small quantities require registration. Annual packaging-volume reporting is mandatory.
Poland: Companies placing packaging on the market must register with the BDO database (Baza Danych o Odpadach). The EPR number is issued following registration. Electrical equipment and batteries require registration in a national register. Poland has comparatively low thresholds, and packaging volumes must be reported annually to the competent authority.
Sweden: Companies placing packaging on the market must register with the Swedish Environmental Protection Agency (Naturvårdsverket) or an approved take-back scheme such as FTI. The EPR number is issued after registration. Electrical equipment and batteries require registration with El-Kretsen. There are no de minimis thresholds, and annual packaging reports are mandatory.
Netherlands: Companies finance packaging disposal through a waste-management fee paid to Afvalfonds Verpakkingen where they place more than 50,000 kg of packaging material on the market annually. Companies first placing packaging on the market or disposing of it must register and receive an EPR number. Electrical equipment requires registration with Stichting OPEN.
Denmark: Companies placing packaging on the market must register with Dansk Producentansvar (DPA). The EPR number is issued after registration. Electrical equipment and batteries also require registration with the DPA system. De minimis thresholds apply, for example 500 kg for certain packaging materials, and annual reporting is required.
Finland: Since 1 January 2024, all companies placing packaging on the Finnish market must register with the Pirkanmaa ELY Centre or a take-back system such as Rinki. The EPR number is issued after registration. Electrical equipment and batteries require registration with Elker or SER-Kierrätys. Thresholds apply, including an annual turnover threshold of EUR 1 million.
Czech Republic: Companies placing packaging on the market must register with EKO-KOM, which issues an EPR number. Electrical equipment and batteries require registration with an approved scheme such as ASEKOL. De minimis thresholds apply, and reporting to the competent authority takes place annually.
Hungary: Hungary has de minimis thresholds for packaging volumes, for example 300 kg for certain materials. Companies exceeding these thresholds must register with a take-back scheme such as ÖKO-Pannon and receive an EPR number. Quarterly reporting to the tax authority is also required, and a product fee is charged. Electrical equipment requires registration with a scheme such as Elektro-Coord.
Portugal: Companies placing packaging on the market must register with Sociedade Ponto Verde, which issues an EPR number. Electrical equipment and batteries require registration with ERP Portugal or Amb3E. There are no de minimis thresholds, and annual packaging reports are mandatory.
Greece: Companies placing packaging on the market must register with the Hellenic Recycling Agency (EOAN). An EPR number is issued following registration. Electrical equipment and batteries require registration with a scheme such as Appliances Recycling. Low thresholds apply, and annual reporting is mandatory.
Slovakia: Companies placing packaging on the market must register in the producer register at the Slovak Ministry of Environment and join a take-back scheme such as NATUR-PACK, which issues the EPR number. Separate registers exist for packaging, electrical equipment and batteries. Annual packaging-volume reports are required.
Slovenia: EPR is governed by the Regulation on Packaging and Packaging Waste Management. Companies must register with a take-back scheme such as Slopak, which issues the EPR number, and register in the producer register. There are no de minimis thresholds, and annual reporting is mandatory.
Latvia: Companies placing packaging on the market must register with Latvijas Zaļais Punkts, which issues an EPR number. Electrical equipment and batteries require registration with a scheme such as Zaļā josta. De minimis thresholds apply, and reporting is annual.
Lithuania: Companies placing packaging on the market must register with VšĮ Pakuočių tvarkymo organizacija, which issues an EPR number. Electrical equipment requires registration with EEPA. De minimis thresholds apply, and annual reports are required.
Estonia: De minimis thresholds apply, for example 25 kg of plastic or 50 kg of other materials per quarter. Companies exceeding these thresholds must register with a recovery organisation such as Eesti Taaskasutusorganisatsioon (ETO), which issues an EPR number, and pay taxes to the Tax and Customs Board (EMTA). Electrical equipment requires registration with EES-Ringlus.
Malta: Companies placing more than 100 kg of packaging material on the market per year must register with a take-back scheme such as GreenPak or Green MT, which issues an EPR number. Companies with lower volumes are exempt from registration. Electrical equipment requires registration with the Environment and Resources Authority (ERA). Annual reporting is mandatory.
Cyprus: The Packaging Waste Act governs EPR for household and commercial packaging. Companies must register with Green Dot Cyprus, which issues an EPR number. Thresholds apply, for example two tonnes of packaging material per year, and annual reporting is required. Electrical equipment requires registration with WEEE Cyprus.
France: France has one of the strictest EPR systems in the EU. In addition to packaging, electrical equipment and batteries, EPR also applies to textiles, furniture, toys, sports goods and gardening products. Companies must register with organisations such as CITEO for packaging or ADEME for other categories and receive a unique identifier (identifiant unique) as their EPR number. This number must be stated in contractual documents and on the company website. The Triman marking is also mandatory for packaging.
Austria: For packaging, registration with a take-back scheme such as Altstoff Recycling Austria (ARA) is required. Since 2023, foreign companies must appoint an authorised representative in Austria. The packaging EPR number is issued by the take-back scheme. Electrical equipment and batteries are covered by WEEE and battery rules, with registration through the EAK coordination body.
Spain: Packaging must be registered with Ecoembes or a comparable scheme. An EPR number is issued after registration. Electrical equipment and batteries require registration with the competent authority, for example Fundación ECOLEC. Spain has comparatively low thresholds, which means small retailers may also be required to register.
Italy: Companies placing packaging on the market must register with the CONAI system (Consorzio Nazionale Imballaggi). Electrical equipment and batteries require registration in a national register such as CDCRAEE. Italy plans to expand EPR requirements further in the coming years.
We advise you on all matters relating to the VerpackDG/PPWR:
Conclusion
An EPR number is important evidence for companies selling products in the EU. It helps ensure that companies assume environmental responsibility for product disposal and recycling. In Germany, the EPR number for packaging is the LUCID number. Other countries, such as Belgium, Poland, Sweden and Cyprus, use their own systems and naming conventions.
To avoid sanctions such as fines or sales bans on platforms like Amazon, you should register in the respective national registers in good time and store the relevant EPR number. Thorough research into country-specific requirements and cooperation with specialised service providers can help ensure EPR compliance efficiently.
Because EPR compliance is regulated differently in every country, companies selling in several EU countries must review the specific requirements of each country. Platforms such as the EPR Register provide cross-border support by centrally managing national registrations and issuing a standardised EPR number with a QR seal.