EPR fundamentals
The legal entity responsible for registering and paying EPR fees on packaging, usually the brand owner and otherwise the importer or first seller.
Every EPR regime names the party that carries the obligation, and almost all of them use a fallback hierarchy rather than a single definition. The brand owner whose name appears on the packaging is obligated first. If that brand owner has no establishment in the market, the obligation passes to the importer of record. If neither exists, it lands on the distributor, retailer or online marketplace that first places the goods on the market.
The consequences are practical. A US brand selling into Germany through a local subsidiary is obligated in Germany through that subsidiary. The same brand selling into France direct-to-consumer with no French establishment must appoint an authorised representative. A private-label supplier is generally not the producer because the retailer owns the brand, but a contract manufacturer that sells unbranded goods under its own name usually is.
Marketplace liability has changed the picture again. Several jurisdictions now make the online marketplace responsible for the EPR obligations of third-party sellers that lack local establishment, which means the same tonnage can be claimed by two parties unless the contractual position is documented.
A locally established entity appointed to carry a foreign producer's EPR obligations in a market where the producer has no establishment.
A policy model that makes the producer of a packaged good financially and often operationally responsible for its packaging at end of life.
The company whose brand appears on a packaged product, and the first party in the EPR responsibility hierarchy in nearly every jurisdiction.
A revenue, tonnage or unit level below which a producer is exempt from some or all EPR obligations in a jurisdiction.
Packgine resolves your packaging to component level and applies the rules of every market you sell into.