Under Article 45(7) of the PPWR, a producer selling to EU consumers must give its fulfilment centre its EPR registration number and a self-certification. Article 45(8) then requires the fulfilment service provider to check them. The start date is unsettled: the harmonised national registers do not exist yet. Germany and Austria already have their own fulfilment checks in force.
What must the seller hand over?
Its registration details and a self-certification, when the contract is signed. Article 45(7) of Regulation (EU) 2025/40 applies to producers “offering packaging or packaged products to consumers located in the Union”. They provide:
- the producer’s registration in the Member State where the consumer is located, with its registration number;
- a self-certification that it only offers packaging for which the EPR requirements are met in that Member State.
The fulfilment centre does not register the seller, and Article 45(8) makes the producer answer for the accuracy of the information. Sellers to businesses only are not named in Article 45(7).
Who counts as a fulfilment service provider?
A business that offers at least two of warehousing, packaging, addressing and dispatching, without owning the products. Article 3(11) of Regulation (EU) 2019/1020 sets this test and excludes postal, parcel and freight services.
What does the fulfilment centre have to do?
Make best efforts to check the information, under Article 45(8). It can use an official online database, the public registration list under Article 44(13) or supporting documents. If the information looks wrong, it asks the producer to fix it. If the producer does not, the provider suspends its service for offers to EU consumers until the request is met, and gives reasons. Under Article 45(9), the producer can challenge that decision in court.
When does the check start?
That is unsettled. The text carries no later start date, but the details it asks for are registrations in the harmonised national registers. Those are due within 18 months of an implementing act that had not been adopted by 18 October 2026. The Commission’s small business page says online platforms are not yet required to ask for an EPR number. It says nothing about fulfilment providers. Platforms have their own rule in Article 45(4).
Where do fulfilment checks already apply?
Germany’s VerpackDG bars fulfilment service providers from serving unregistered producers. In Austria, since 1 January 2023, the AWG requires marketplaces and fulfilment providers to ensure compliance or exclude the seller. Each country of storage needs checking for similar national duties.
What would this mean for stock in Germany?
In this illustrative case, a seller outside the EU ships to German consumers from a German fulfilment centre, so it is the producer in Germany. Under VerpackDG § 13(4), the centre may not serve it without a German registration, and § 5(2) requires the seller to name a German EPR representative before selling. Under the PPWR, the seller would also hand over its registration number and a self-certification at signing.
Sources: Regulation (EU) 2025/40 (PPWR), Regulation (EU) 2019/1020, Commission, EPR for packaging for small businesses, Germany, VerpackDG, Austria, AWG 2002
Before stock moves into an EU warehouse, GreenSutra’s PPWR consulting lists the registrations needed. The EU PPWR guide and PPWR checklist place this step.