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Marketplaces check EPR registration: what changes this year?

More and more marketplaces are asking sellers to provide a valid EPR or packaging registration number before they are allowed to (continue) selling. This article explains what changes this year and for whom it is relevant.

More and more marketplaces are asking sellers to show a valid packaging registration number before or during the sales process, such as a LUCID number in Germany or a registration with the Dutch registry. This year it is notable that this check is no longer limited to large platforms, but is expanding to smaller and national marketplaces that previously did not ask for proof of registration.

For you as a seller, this means that a missing or expired registration number can this year more quickly lead to your account being suspended or your listing being removed, regardless of whether you previously saw that as someone else's problem. Whether this applies to your situation depends on the countries in which you sell via that marketplace and the type of packaging you use.

Why marketplaces are now checking

The underlying reason is not new: marketplaces can in a number of EU Member States be held jointly responsible when sellers on their platform are not registered for packaging. That liability already existed, but its enforcement shifted this year noticeably from a retrospective spot check to a check beforehand, when creating or renewing a seller account. Platforms typically ask for the registration number itself, not the underlying proof document — the responsibility to keep that number correct and valid remains with the seller.

What specifically changes

Whereas previously a marketplace sometimes made do with a checkbox at registration, sellers this year more often see the platform actually verifying the number against the national register, for example at onboarding, at an annual re-check or after a complaint. If this varies by marketplace and by country, that is a matter of the platform's own policy; the underlying registration obligation does not change as a result, only the extent to which it is enforced.

For whom this matters

This development primarily affects sellers who sell via multiple marketplaces in multiple EU countries, because they may be dealing with a different register and a different number per country. If you sell exclusively through your own webshop without a marketplace, then this specific check does not apply, although the underlying registration obligation for packaging in most cases still applies. If you supply via fulfilment or dropshipping, it is important to establish who in that chain is registered as a party with the marketplace; that is not in every structure automatically the same party as the one actually filling the packaging.

Whether your type of packaging and your role actually fall under a registration obligation, and in which country, cannot be answered in general terms. in a few questions see which role and which register fits you provides for that a first indication per packaging type and per country, without requiring you to have an account.

What you can check this year

If you already have a registration number, it is advisable to check whether that number is still current for all countries in which you sell via marketplaces, and not just for the country where your company is established. If you sell via multiple platforms, the number may need to be entered in a different place in the seller account for each platform; a check by one marketplace tells you nothing about another. In the knowledge base with explanation per topic it is explained how registration obligations can differ by country and when an authorised representative is needed to complete that registration.

If you are uncertain whether a marketplace you work with will actually enforce this requirement this year, the marketplace's own platform terms are the most reliable source; we do not provide an assessment per platform. However, we can guide you in actually completing the registration once it is clear which register applies to you, via guided registration per country.

If you want to get an initial overview of your own packaging and sales channels without having to invest time immediately, the free quick-scan on epria.eu provides an indication per packaging type and country of what applies to you. If you have a specific question after that, you may find the answer in the frequently asked questions on registration and marketplaces possibly already.

This article is general information and not legal advice.