EPR packaging registration numbers - it's getting crazier and crazier
Summary: The discussion revolves around the new regulations on EPR packaging registration numbers, which will become mandatory from August 2026 for various EU countries. marcels-modellbahn-welt describes the high costs and bureaucratic effort for small retailers. camillehervier expresses skepticism about a possible suspension of the regulations and sees small retailers as being put at a disadvantage in favor of large companies. Several participants, including imperial-modellbau and chrono-shop, discuss the challenges of implementation and the possible impact on international shipping. Some retailers, such as chikara-kiss, are considering limiting shipping to countries without these requirements, while miriam@ebay, an eBay representative, clarifies that the requirements come from the EU Packaging Regulation and not from eBay. Overall, there is frustration about the regulations and their potential burden on small businesses.
People already know the whole thing with notifications and all that from the national packaging law with LUCID, system participation partner, etc.
According to a corresponding eBay message from today, from 12/08/26 EPR packaging registration numbers will also be mandatory in various EU countries. You’ll then need a separate EPR number for each of those countries (where the requirement applies), which must be applied for and stored with eBay. In addition, in some countries, if you don’t do that, the listings for the respective country may once again be excluded. We already know the drill from the OSS procedure...
In its email, eBay refers to its partner lizenzero, which in turn offers a “free” status check in exchange for your name and email address. When I did that, it turned out that I have obligations to fulfill in the following countries:
Germany
Austria
Denmark
Sweden
Norway
Finland
Spain
Portugal
Latvia
Poland
Hungary
Slovenia
France
Greece
Bulgaria
Cyprus
Luxembourg
Lizenzero then offers to handle the packaging hassle for 299 euros/country/year net, and with discounts I came to 4,320.55 euros/year net for the 17 countries (!).
Of course, that’s not all. On top of that, there are the licensing fees themselves, which according to the cost estimate can still amount to up to 347.77 euros/year in Sweden or 300 euros/year in Poland per country.
So in the end it’s somewhere between 5,000 and 10,000 euros per year just so you can keep selling to the beloved EU abroad + Norway. Don’t forget: the EU gives us sooo many advantages!
All this for a few shipments that we regularly send to a handful of international countries. They go on about globalization and all its many benefits. When I see stuff like this now, it really turns my stomach. Bureaucracy and rip-offs times ten. Please don’t be surprised by any election results anymore!
chikara-kiss
·2 hours ago · EditedHello dear everyone,
what really surprises me is that only very few, and mostly the same people, are commenting on this madness!!!!
There should be so many more. Or have they not got this on their radar yet????
In my personal circle of friends, there are very many who want to ignore this!!!!
I myself will NOT be joining in, because I think then the warning letters will come flying in.
I will only supply the countries where there is no obligation!!!!
Why appoint an authorized representative where there is no obligation!!!
A silver lining are the eBay news “Tap into new markets”!!!!
First worldwide and then across Europe!!! The latter is very interesting for us and I very much welcome what eBay is planning.
I am very sure that eBay has now also realized that the EU market will then collapse by 80 %!!!!!
I am very open to any suggestions.
Regards Marco
bikenerd.23
·yesterday at 12:07 PMtypically German, of course the ZVSR comes along today. Contrary to the EU view, we are always manufacturers and producers as soon as we fill.
Nonsense that is
https://www.verpackungsregister.org/ppwr/versand-und-onlinehandel
schrauben-seidel
·yesterday at 2:53 PMWow. Totally wild.
martini.de
·Aug 6, 2026 at 5:02 PMI’m wondering how the relevant countries are supposed to become aware of European sales into their country? The only thing that comes to mind is through the OSS report. Based on that, the countries can extrapolate the revenue and number of packages. Or will UPS, DHL and all the other couriers in future be required to disclose shipments to the EU? Or will eBay report the sales? Is anything known about that?
cosmoretroshop
·Aug 6, 2026 at 5:12 PMI wouldn't think out loud here about how to "circumvent" laws. However, it could be that in a week's time eBay will be requesting the registration numbers from all EU countries (or maybe not). Then that's the end of it.
A comparison between OSS and PPWR? Given the state of the EU and its member states, I think it could even be years before both authorities hear about each other... We live in countries that can't even maintain public infrastructure.
bikenerd.23
·Aug 6, 2026 at 10:00 PMEbay will simply query the EPR numbers. However, not much has happened on the relevant page so far
https://www.ebay.de/help/account/regulatory/understanding-extended-producer-responsibility-ebay?id=5482
gsahamburg
·Aug 6, 2026 at 2:11 PMWhat I've been wondering all this time is, how is it supposed to be checked whether the parcels are sent privately or commercially, or who will take care of that at the post offices?
marcels-modellbahn-welt
OPAug 6, 2026 at 7:38 PMThe shipping providers (Post/DHL isn't the only one, after all) have nothing directly to do with the matter. They are also not legally required to play "henchmen".
gsahamburg
·yesterday at 8:18 AMYeah, everything's kind of crazy somehow.
schrauben-seidel
·2 days agoJust a question about implementation: apart from Germany and France, under "Company details" you can only enter EPR numbers for batteries and rechargeable batteries for all other countries.
Am I overlooking something here, or is this going to be another last-minute action like with the cancellation button?
cosmoretroshop
·Aug 6, 2026 at 10:37 AMKeep your head down until 12/08.
It seems to me that no one really knows anything, and nobody is really interested. Anticipatory obedience here seems only to punish the honest (as usual in this society).
over_dog
·2 days agoHello, because the EU is not able to keep goods that violate European standards away, it just goes after tangible sellers!! Also, millions of packages from Asia arrive in Europe every day and one wonders what is up with all these packages!? By the way, the EU (Ursi) wants to increase the budget as well as staffing in order to kick off even more delightful things!!
Regards
Yes to core-competence-lessness and decision-making dilettantism!!!
chikara-kiss
·2 days ago · EditedHello everyone,
I also did a check with Lizenzero myself and my two main countries are the Netherlands and Italy. It says there is no obligation.
So that means I can keep supplying these two countries, right???
I’m very, very grateful for every comment!!!!
Regards, Marco
P.S. I’m still feeling very, very sick!!!
marcels-modellbahn-welt
OP2 days agoAs far as I understand it, the rule is: If there is no licensing requirement in a country (e.g. because certain minimum quantities that apply there are not reached), then no authorized representative needs to be appointed there either.
Of course, you have to trust that the check at Lizenzero delivers the right result.
bikenerd.23
·2 days agoThe Netherlands and Italy are pretty “lenient” countries when it comes to packaging, but I think the requirement for an authorised representative still applies
https://www.it-recht-kanzlei.de/bevollmaechtigter-verpackungen-eu-ausland.html
As long as eBay doesn’t automatically block you for these countries because of a missing system number - who’s going to stop you?
marcels-modellbahn-welt
OP2 days agoWhat the IT Rechts Kanzlei unfortunately doesn’t write: when the authorized representative obligation does not apply.
It only says: "The obligation does not cease because of small packaging quantities, fewer customers, low turnover, or the size of the company."
In fact, some countries like Sweden and Poland apparently already require significant system participation sums starting from the very first gram. Other countries like Hungary only require marginal sums. Of course, there’s nothing about that at IT Rechts Kanzlei.
From the check at Lizenzero, I understand it this way: In countries where you have to participate in the system, you must appoint an authorized representative. In countries where you do not have to participate in the system (e.g. because you fall below certain quantities there), by reverse conclusion there is no authorized representative obligation.
To me, it wouldn’t make any sense otherwise either (apart from how stupid the whole thing is in general). If there’s nothing to register in a country, what’s the authorized representative for? Twiddling their toes?
bikenerd.23
·2 days agoI see the whole thing pragmatically too, but you're not really asking about the point of it, are you-:)
cosmoretroshop
·2 days agoSame here for me. I haven’t licensed anything, why would I? The thing with the authorized representative is supposedly mandatory everywhere now. But I have the feeling that this “requirement” won’t be checked by anyone.
The Sellernews August 2026 from yesterday don’t seem to give the PPWR any importance. No mention at all!
rolfs-spur-g-modelleisenbahn
·5 days agoHello kkukki20022008 and everyone else,
so over the last few days I’ve once again spent quite a bit of time looking into the whole issue in detail. I went through and compared various portals, like Lizenzero (with whom eBay works together), the own affected country list here on eBay, and the many, many pages on the topic from the IHK. What I noticed is that there are definitely some significant differences between the list here on eBay and Lizenzero as to where you are considered responsible and where you are not.
But..., either way, it’s all very confusing and muddled!
I’ve now mainly gone by the IHK country list and today first excluded all countries from shipping that, in my opinion, are affected and where, if things go really badly (e.g. random checks by customs or who knows what), problems could arise.
And there are a lot of countries! Since I’ve been registered here in Germany with Lucid and Lizenzero for many years, apart from Germany I only still have 7 more countries in my shipping offers. These include, for example, the Netherlands, Belgium, and a few others.
You can always change that again if, in the future, de minimis thresholds or something similar are introduced across the EU after all.
I’m in exactly the same boat as many others here too.
For 20 to 30 packages a year that I ship to other EU countries, I simply can’t afford or justify these outrageously high costs and fees, not to mention all the bureaucracy. It’s just sad..... :-(
cosmoretroshop
·5 days agoThe thing is that Lizenzero has “no plans yet” for some countries. That’s because in these countries it still isn’t known what exactly will be required (Why, anyway?! There are still 10 days left, and complex laws can obviously be implemented within a few minutes *thereseemstobeironyinthesebrackets*).
It’s quite possible that the “plans” for these countries will only be in place at some point later, weeks if not months after you’ve booked everything that was possible.
Apparently, in 10 days all de minimis thresholds will also be scrapped, and, for example, in Ireland you’ll have to get everything underway from the 11th to the 12th.
It’s astonishing that not even experts can really give any information about how this will work (see also eBay’s terseness), and France reacted correctly here by postponing everything to 01.01.27. Maybe that would be a good idea for most of the rest of the EU, or simply introduce de minimis thresholds or flat rates?
All in all, a catastrophe.
bikenerd.23
·4 days agoDoesn't matter anyway
marcels-modellbahn-welt
OP5 days ago@rolfs-spur-g-modelleisenbahn
Which country list from the IHK? They seem to have like 20 country lists on this topic, plus a PDF (title "Handling Packaging in Europe"). If they think I’m going to study the rules in the PDF for every single country separately over a total of 65 pages, where half of it is still incomprehensible and/or unclear, then they’ve got another thing coming.
rolfs-spur-g-modelleisenbahn
·Aug 6, 2026 at 4:21 PMHello marcels-modellban-welt,
yes, exactly, I mean that PDF with the jumble of listed countries.
I naturally didn’t read it word for word, but limited myself to the essential information. Yes, it took quite a bit of time, but I think the info from the IHK is pretty objective. And as already written, it really helped me get, I think, a good comparison.
In any case, like so many other small online retailers, I will no longer ship (and I will no longer sell from now on either), as of 10/08, to most EU countries. :-(
marcels-modellbahn-welt
OPAug 6, 2026 at 7:41 PM@rolfs-spur-g-modelleisenbahn
Awesome, especially when individual countries change their regulations over time. Who’s supposed to notice that?
bikenerd.23
·5 days agoEPR isn't really the fundamental problem, but rather the authorized representative regulation. Suspension was planned and was supposed to be discussed in October, but the EU Council has now removed this topic from the agenda - so nothing more will happen there. The Netherlands and Belgium are supposedly not going to make use of the authorized representative regulation, I read that somewhere at Händlerbund....but those are rumors.
marcels-modellbahn-welt
OP4 days ago@bikenerd.23
As far as I understand it, the EPR is very much part of the problem too.
Even without an authorized representative, packaging waste registrations would have to be carried out in each of the countries listed in the original post. Topping it off with minimum fees of EUR 347.77/year in Sweden or EUR 300/year in Poland.
On top of that, you’d have to register in all the countries concerned with a reporting body like LUCID here in Germany and would receive the system participation number from there. And then, of course, you have to report the corresponding waste quantities annually for each country concerned.
Please provide a source showing that the planned first reading on the suspension in October 2026 was removed from the agenda! I couldn’t find anything on that (meaning the removal from the agenda).
bikenerd.23
·4 days agohttps://ohn.haendlerbund.de/recht/politik-gesetze/entlastung-ppwr-bevollmaechtigte
bikenerd.23
·4 days agoAside from that, the EPR is crazy anyway - I'm registered in the French Leko, but it's not worth it, just because of the bureaucratic hassle. The EU is off the table for me for now
chikara-kiss
·2 days agoHello Rolfs Spur G model railway,
can you tell me/us which 7 countries exactly they are, where there is no obligation???
Many thanks and best regards Marco
rolfs-spur-g-modelleisenbahn
·Aug 6, 2026 at 4:44 PMHello chikara-kiss,
ok, but without any legal basis or binding force whatsoever!
From everything I’ve read and compared, I’ve come to the conclusion that for me I will currently only ship to Germany (because registered and involved here) and to the following countries:
Albania, Belgium, Croatia, Lithuania, the Netherlands, Serbia, and the Czech Republic.
This list may not be final. I also saw that, for example, in the check at lizenzero, Italy is listed as a country where supposedly no obligations exist! But in the IHK country list, it definitely is!
So for now I’m just playing it safe and will keep an eye on the whole thing.
And..., for me it all refers only to the whole packaging mess.
I don’t have anything to do with batteries, accumulators, and electronics anyway.
chikara-kiss
·Aug 6, 2026 at 5:08 PMHello Rolf,
thanks for the reply. Yes, and of course what you said is not legally binding!!
I also have nothing to do with batteries and co. Like with you, it’s only about the packaging madness!!!!
Best regards, Marco
kkukki20022008
·5 days agoHello everyone,
I’d like to ask eBay and also the members here who have already looked into this topic a bit more closely:
Starting on 12/08/2026, do you have to block all EU countries yourself in the shipping/sales settings for which you don’t want or can’t set up an EPR registration? Or will eBay automatically hide the listings for the relevant countries or prevent sales there if no EPR number is stored?
To be honest, I don’t want to register in every EU country and incur additional costs there. At the same time, you read here and there that registration is probably not required in all EU countries, or that there are sometimes exceptions or relief for small businesses.
I’ve also read that it may be possible to use packaging that is already registered or licensed and therefore not have to fulfill certain obligations yourself.
Is that actually true? Or what is the current legal situation?
What I’d especially like to know is how you handle this: do you leave EU shipping enabled for now and wait to see what eBay does automatically, or do you block the relevant countries as a precaution yourself?
Thanks a lot for your experiences and, of course, also for an official response from eBay.
marcels-modellbahn-welt
OP5 days ago@kkukki20022008
How eBay handles that, let eBay answer. I suspect there’s no platform obligation here and that they therefore leave the matter to the merchants.
See my posts in this thread regarding exceptions.
See the graphic diagram of the ZVSR posted in the thread regarding packaging that is already licensed. Accordingly, the producer/first placer on the market has to license it in the respective country. However, there is disagreement about whether, for certain shipping products, the merchant becomes the producer because they use, for example, adhesive tape or film; see the text above on this.
When shipping to another EU country, the merchant is the manufacturer who has to license the packaging, even if the packaging has already been licensed 50 times in another EU country. The only question that would still arise is: What about re-imported packaging? For example, made in Austria, exported to Germany, and re-exported back to Austria. But in case of doubt, that will be hard to prove.
When reusing packaging licensed domestically, there will have been a packaging manufacturer or merchant earlier in the chain (apart from the previously described problem of the uncertainty surrounding the so-called "flexible packaging").
The problem is likely also to be proving the whole thing in an actual case. That will be difficult if you do what is actually sensible and carry out direct recycling, for example by reusing cardboard boxes or sourcing packaging from insolvency assets, warehouse clearances, etc.
The narrow-minded people in politics and the narrow-minded people who write their oh-so-smart articles about it assume that you:
buy your packaging items from a packaging dealer at the material cost price of 2 euros/package
hire a packer at at least minimum wage plus payroll taxes, while preserving their "work-life balance" and also meeting all other bureaucratic requirements and obligations in this context
offer shipping free of charge or at least not at cost-covering prices
offer customers eager to return items free return shipping, worldwide of course, so that eBay can once again present itself as heroic at the expense of sellers
cheerfully take part in everything, applaud, and support the left-wing mob again at the next election too
I honestly wonder: this basically affects the entire EU. Will online merchants from the Eastern European EU countries seriously care about this and go along with it properly and exemplary?
miriam@ebay
Hello @marcels-modellbahn-welt and everyone in the thread! Thank you very much for your contributions to this topic. We have been following the discussion here closely over the last few weeks and have been passing your feedback on internally on an ongoing basis.
We understand the concerns raised and would also like simple and practical solutions wherever possible. We are working on this topic together with the responsible teams. However, possible changes to the legal requirements take time.
One point is particularly important to us: The requirements do not come from eBay, but from the Packaging Regulation (PPWR) of the European Commission. eBay has no influence over these legal requirements. eBay is not introducing any additional requirements of its own, but merely requests the information that sellers are required to provide there, where it is legally mandated, so that eBay can fulfill its legal obligations.
We also know that the country-specific registration routes are not always easy to understand at the moment. Since implementation is still developing in many countries, we unfortunately cannot currently provide a complete country overview. Depending on the country, registration takes place with a national authority or via a Producer Responsibility Organisation (PRO). Together with Interzero, we are working to identify the responsible bodies, official registration portals, and registration routes, and to make this information available step by step on our help pages.
As soon as we have further reliable information, we will share it with you.
Kind regards
Miriam
cosmoretroshop
·2 weeks agoEbay’s information policy is more than poor. Apart from vague announcements and advertising for a "partner" who in most cases can’t do anything at all ("they don’t offer a plan for this country"), basically nothing has come so far.
The fact is that the majority of sellers here on eBay either pay 5-10k in fees to some providers and have to plan for at least 2 weeks of admin work per year to meet the requirements. For eBay, this will most likely mean that a large part of EU business from small and medium-sized sellers will collapse within 3 weeks, and eBay Germany will go from being an EU/worldwide marketplace to a local seller platform on which third-country buyers are still tolerated.
Here, something could have been done in some form to accommodate sellers, even if the marketplace had taken over some of the obligations itself (they do have programmers, or can hire them) - now we can just watch as a not inconsiderable number of shops will shut down, since, for example, 1/3 less turnover does not mean 1/3 less profit, but may decide whether it is even still worth it here.
bikenerd.23
·2 weeks ago...and because of the ZVSR interpretation of the legal situation, that merchants become producers by applying the shipping label, that also kills the local marketplace - at least for the small merchants.
cosmoretroshop
·2 weeks agoLicensed cartons with a printed "producer" are also being sold. The "authority" can’t really do anything about that :D
bikenerd.23
·2 weeks agoI had assumed that too so far-:)
But
https://www.it-recht-kanzlei.de/versandlabel-macht-haendler-zum-karton-erzeuger.html
miriam@ebay
Hello @cosmoretroshop & @bikenerd.23 - Thanks for the feedback. We understand that the new regulatory requirements mean uncertainty and extra work for many sellers. I’ve made sure your latest feedback on this has been passed on to the relevant teams.
Best regards
Miriam
sunrise1605
·1 month agoMaybe people should just complain to the right people, with a list of this whole mess, instead of immediately stubbornly voting for a fascist party.
The people in Brussels probably have no idea what effects their great ideas have.
All theorists and desk jockeys, clueless about online retail, and about KU even less so.
Their ears should be ringing from all the complaints.
What about the relevant associations and representatives in Brussels anyway, no interest in lobbying?
You can also complain to the local state politicians, they should pass it on to Brussels too.
But that should be done on a massive scale, not just Aunt Erna with her crocheted doilies.
marcels-modellbahn-welt
OP1 month ago · EditedSurely we have different views on what a fascist party is. In my eyes, the few that there are in Germany are fortunately to be found under "Others".
"at the appropriate place" - where exactly?
the relevant associations and representatives in Brussels - which ones?
the "local state politicians" - which ones? (apart from the fact that they will refer to the EU)
Of course there is already pushback from lobby associations. The fact that the EU Commission now wants to suspend the authorized representative requirement does not come out of nowhere, but is due to the fact that there was a protest campaign from industry associations.
But the question arises as to how anyone could even come up with the idea of passing something like that, only to fight against it in the end. The savior from the ghosts he himself summoned.
Are they really so incompetent and don't know that they are causing a patchwork because they are requiring every country across the EU to set up EPR rules and introduce the authorized representative requirement? Is it really so hard for them to understand what kind of bureaucratic and financial burden this creates? Don't they in Sweden, Poland and elsewhere know exactly what they are doing when they charge businesses more than 300 euros/year from the first gram of packaging waste onward (plus authorized representative costs)?
In the end, the question of whether they are too stupid or whether they simply don't give a damn (because it's about some "higher" goals) can be left aside. Because in the end it leads to the same result, namely that these people are not suited for their job. And then there is only the option of choosing something other than what is predominantly governing at EU level in this case. We know what the Left-Left-Greens stand for on this issue. We know which party membership card Frau von der Leyen has. And we likewise know that self-proclaimed liberals are not above backing left-ideological clear-cutting operations either (see "Habeck's heating law"). That applies all the more when those liberals are then also led at EU level by a left-wing goat.
One can also simply ask which of the parties on the ballot here and above the 5% threshold are most likely (and seriously) opposed to something like this EPR regulation. That may sting if you have a heart for Ukraine, but unfortunately that's how it is.
"Their ears should be ringing from all the complaints." is exactly what is happening. The citizen expresses their opinion at the ballot box.
Sometimes it takes a bit of time, but you can see what is possible at EU level when you do not bow to the left-wing clan (keyword: deportation centers outside the EU). Would something like that have been possible if people had kept happily and faithfully voting for the Union, FDP, Left-Left-Greens or their EU parliamentary group colleagues? Probably not.
Nevertheless, it would be an important concern to show some parties where the line is drawn with democracy on the far right. But that is not what the (predominant) politician consortium, which sees itself as being in the political center, is interested in. They would rather want a fascist party that they can sell to voters as unelectable because it is far-right. Of course, they would rather keep cuddling up to the left-wing mainstream there and continue the established political cronyism.
One could go into the whole thing in even more depth, but it's slowly getting off topic. I think it's become clear what I mean.
chikara-kiss
·1 month ago · EditedHello fellow sufferers,
it will end up that way, that you’ll then only ship within Germany + worldwide. Even if I were to add 2-3 countries as well, it really isn’t worth it!!!!
The latest news from my IT law firm has confirmed all of this to me.
The comments from imperial-Modellbau, marcels-modellbahn-welt and marco-vintage-bikes were/are very helpful.
If anyone has an idea, or however they may have found a way, they can very, very gladly write to me, etc.
With that in mind........Marco
P.S. I feel very, very sick!!!!!
afrozip
·1 month agoYes, I can very well understand your anger, and it’s no different for me. Unfortunately, the EU is a bureaucratic monster with many lawyers, lobbyists, and people who aren’t even aware of the impact of the regulations that are passed.
In the EU countries where you have no obligations regarding packaging licensing, there are sensibly at least minimum quantities of packaging that you have to reach before you become subject to licensing.
I used to handle my licensing through Landbell, later through Reclay. In Austria, since this year, I have been represented by the German Chamber of Commerce in Austria , which is cheaper than Reclay or Lizenzero. In France it is the company Leko. However, I’ve now reached a point where, for other EU countries, I simply compare the respective annual turnover with the costs. I will inevitably block many EU countries as delivery locations.
Otherwise, all you can do is hope that the people responsible wake up someday.
What about the millions of parcels from China and other countries that flood the EU? I’d be interested to know whether the senders of these parcels have to license their packaging in the EU.
cosmoretroshop
·1 month agoI think this strategy would be the best:
wait and see. So far not even the pros know what’s coming, how it’s supposed to be enforced, or whether everything won’t just get overturned after all. The law was pushed through by lobbyists for big online retail with help from the "garbage disposal maf... industry"
if it becomes necessary to register in San Marino too, as a small online seller (<1,000,000 € annual turnover), you should think about whether you now want to pay, for example, San Marino 500 € a year and also submit paperwork just to make 1000 € a year in turnover there. So make an action plan for what’s worth it and what isn’t, and then remove countries accordingly.
As an aside: it will certainly be fun to see how each and every one of us wants to factor this 5k-10k "flat rate" for delivering into the EU into prices, and how exactly one wants to calculate the additional bureaucratic effort.
Should I, for example, charge 20 € instead of 12 € for package shipping to the EU?
Is the EU Parliament aware that with this trash-on-trash, consumers are the ones paying the bill, and twice over, since many small and medium-sized online sellers will have to shut down and then these people will have to look for "real jobs"?
marcels-modellbahn-welt
OP1 month ago@cosmoretroshop
Just for the record: San Marino is not an EU member. Okay, Norway isn’t either, but it still appears on Licensiero’s obligation list.
As long as you’re not generating significant sales in other EU countries (I’d say at least over €100k) or it’s only a specific EU country, then in my opinion it would hardly be worth it.
I doubt that an increase from 12 to 20 euros would fully offset that. Of the €8 increase, €1.52 VAT comes off first, leaving around €6.50 — and I won’t even start on eBay fees on shipping costs. You’d need to do 1,000 to 1,500 shipments to other EU countries per year just from those additional revenues of around €6.50 to recoup the €5,000 to €10,000 that have to be raised. Who has that many shipments to other EU countries, let alone with such an increase in shipping costs?
In theory, you could exclude countries with very low shipping volumes but licensing obligations. But where do you start and where do you stop?
cosmoretroshop
·1 month agoWell, the “big ones” easily have several thousand shipments to other EU countries per year. You know where you’re shipping to; you have the data from previous years, and then you can make a selection of whom you no longer want to serve.
A price increase is a price increase; you have to calculate and implement that. Some of the customers from the EU will, one way or another, use parcel forwarding shops here in Germany as the delivery address. Some already do that anyway.
This is where the “wheat” will be separated from the “chaff” again: Some will respond “properly” to the new challenges and come out stronger. Others will be overwhelmed and end up hurting themselves by, for example, no longer shipping abroad, and still others will simply give up.
The idea behind this is that in online retail, someone is always making business, and the latter two groups from my list above will leave parts of their share of the pie to others. That will lead to consolidation. That’s how the market works.
sunrise1605
·1 month agoUnfortunately, this market always ends up going in the direction where only a few large ones remain, and they can then set the prices.
cosmoretroshop
·1 month agoYes, that was "unfortunately" my subtext too. Some of us, and this isn’t necessarily the 1 trillion revenue shop with the big A from the big A, adapt, while others give up :)
marco-vintage-bikes
·1 month agoWhat about countries where no obligations apply? Do you also have to pay €299 annually to Lizenzhero then? After successful payment, do you get a code that is stored on eBay or how is that supposed to work?
marcels-modellbahn-welt
OP1 month ago · Edited@marco-vintage-bikes
Where no obligations apply - for me, according to Lizenzhero, these are:
EU:
Malta
Italy
Slovakia
Czech Republic
Holland
Belgium
Romania
Estonia
Lithuania
Croatia
Ireland
Non-EU (was also checked for whatever reason):
Serbia
Switzerland
Great Britain
Since no processing is required in those countries (according to my Lizenzero check), and therefore no authorized representative either, nothing has to be processed there. Accordingly, no fees would be incurred in those countries. Of course, it's possible that something will be introduced there later on.
But the 17 countries mentioned earlier, in which obligations exist according to my Lizenzero check, are enough anyway.
They would handle the processing for each country. For each of the countries with an obligation, you would then receive an EPR packaging registration number; in Germany, this is the LUCID number. This would then presumably have to be deposited with eBay for each relevant country.
If the obligation to appoint an authorized representative were to be dropped, you could also handle the whole circus yourself for each relevant country. Accordingly, you would then have to apply for the EPR packaging registration number yourself in each affected country and submit the quantity report. Even with a processor like Lizenzero, they will periodically ask for the quantities of packaging waste consumed in kg for each affected country. Of course, that also leads to payment for the corresponding waste, whereby, as already explained, some countries such as Sweden and Poland apparently have significant minimum consumption quantities.
marco-vintage-bikes
·1 month agoMany thanks for your assessment.
I have some countries without obligations. How can you enter this on eBay and prove it? This topic is so complicated...
marcels-modellbahn-welt
OP1 month agoWe'll see how this develops.
Even if eBay initially neglects to hide it, at least the cease-and-desist vulture lawyers are likely to have marked 12.08.26 very prominently in their calendars.
bikenerd.23
·1 month agoI understood it that way, that in every country an authorized representative has to be appointed - Lzenzero only checks the EPR obligations, doesn't it.
marcels-modellbahn-welt
OP1 month agoLizenzero checks the obligations ("free" in exchange for providing name and email address along with verifying the latter).
In addition, in the ERP-mandatory countries, Lizenzero handles the processing including authorized representation (for 299,- euros/country/year net). Of course, Lizenzero is not a monopolist. There will certainly be other providers as well.
On top of that come the actual licensing fees of the respective countries. As explained, with Sweden and Poland at the top when it comes to fees - thanks to minimum quantities.
bikenerd.23
·1 month agoSo the countries without obligations still don't have any rules for authorized representatives.....that'll be fun to see how Ebay implements it. I think it will end up like the annoying OSS and margin taxation. Standard procedure for every EU country, and where no EPR is entered, then it gets hidden.
I'm curious
marcels-modellbahn-welt
OP1 month agoIt depends.
The countries without an obligation fail for me, since certain kg limits for packaging material are not exceeded there. Otherwise, they would probably be included too.
The authorized representative requirement applies at least across the EU. That means: if a participation obligation exists in an EU country, then an authorized representative must also be appointed in that country. However, what the EU Commission now wants to suspend until 2035 is the authorized representative requirement, for which the first reading will take place in October 2026. Authorized representative requirements regulated at the national level (Austria) are not intended to be affected by the planned amendment.
bikenerd.23
·1 month agoGreat - thanks for the clarification. But what about the countries that are sloppy about implementing the authorized representatives regulation and haven’t implemented it at all yet? Wouldn’t that be a gray area? Practically as a stopgap until the suspension?
marcels-modellbahn-welt
OP1 month ago@imperial-modellbau
Just to create some general clarity: The EU Commission is planning to suspend the authorized representative requirement for small businesses, but that will hardly be possible by 12/08/2026 (since the 1st reading is only scheduled for October 2026).
Even if the authorized representative requirement is suspended, registration and reporting still remain for every EU country you ship to, as well as, according to Lizenzero, for Norway too. Have fun already with the administration and recording of packaging quantities for each country! According to the cost estimate on Lizenzero, these costs due to "minimum consumption" quantities amount to, for example, 347.77 euros/year in Sweden or 300 euros/year in Poland.
According to the website of the Stiftung Zentrale Stelle Verpackungsregister (they're the ones who manage LUCID), the topic of "first placer on the market" says:
On the topic of who is specifically considered the manufacturer in other EU countries, there is this graphic there:
The "free" check on Lizenzero delivered, for example, these results for Austria and Hungary:
After all, on eBay it's not really possible to narrow down who you're selling to, whether private end consumers or business customers. Quite apart from the fact that I find that discriminatory and therefore don't want it either.
imperial-modellbau
·1 month ago · EditedHello @marcels-modellbahn-welt
well, I'll just wait and see!
On 02.0. I'll be at an info event held by my responsible IHK.
There, hopefully, it will become clear to what extent I am affected myself.
And after that I'll make my decisions!
imperial-modellbau
·1 month agoHello @marcels-modellbahn-welt
are you maybe the manufacturer or first distributor?
If not, then this doesn’t concern you at all, and if in doubt you can have the number given to you by the respective manufacturer!
Even as a manufacturer it doesn’t concern me, since my items do not fall under EPR - so the whole thing only affects me very peripherally! ;-)
teilemichel_de
·1 month agoAs a parcel sender, you are considered the party placing shipping packaging and padding material on the market and are fully affected
kometenhuhn
·1 month agoIn future, for pure domestic shipping, this should be exempt from 12 August onwards. However, this applies exclusively to Germany. The dual system would then also no longer apply.
teilemichel_de
·1 month agoYou're misinformed, everything stays as it was and will be tightened up
kometenhuhn
·1 month ago · EditedI don't believe that - according to the IT law firm in Munich, it is as follows
"According to new EU interpretation rules on the Packaging Ordinance, retailers are not exempt from packaging-law obligations for shipping packaging
that they source from within the country and
which they only distribute to end consumers within the country
as of 12/08/2026, as an exception, if
the packaging is marked/branded with the retailer's name, brand or logo, or
the packaging is delivered to the retailer in individual parts that still need to be assembled.
Otherwise, for domestic shipping packaging, an exemption from packaging obligations will apply as of 12/08/2026, according to the current status."
This means that for purely domestic shipping, the obligations no longer apply, provided the boxes are already complete and you are not branded.
It is different as soon as the goods are shipped to another EU country. This applies exclusively to domestic shipping, with the above-mentioned requirements.
imperial-modellbau
·1 month agoHello @teilemichel_de
No, you don't count as one - because the key term is first placer on the market - and we small retailers are not that!
Because that is the packaging supplier!
So if you don't manufacture and sell packaging yourself, or if you don't first place electrical appliances, batteries, cars and tires, and more recently also textiles, on the market, then in my view you can sit back and relax.
At least that's how I understood it!
sunrise1605
·1 month agoInitial distributor also refers to B2B, right?
Because that’s always the disputed question (also with WEEE, for example).
Initial distributor actually refers to the first placing on the market for the consumer.
marcels-modellbahn-welt
OP1 month agoPlease do not confuse the term "end consumer" with the term "consumer" under the German Civil Code!
I would like to refer once again to the Linzenzero questions for e.g. Hungary:
To put it simply, end consumers are those who dispose of the packaging and do not reuse it. That is why this also affects the B2B area.
For example, this is how it says in an article by Matthias Giebel, which can be found on the bp consultants website, right in the opening sentence:
Regardless of that, at eBay we don't know whether the goods are going to a consumer (B2C) or an entrepreneur (B2B). The purchase is open to both - you do not have to state in what capacity you are placing the order. It is also not possible for eBay sellers to exclude B2C or B2B.
mmstore74
·1 month agoHello everyone,
I don’t want to get political here, but seriously, we have famine, wars, pensioners who have to collect bottles, and aside from our broken roads, dilapidated schools, etc., and these people who make endless amounts of money are worrying about some packaging guidelines, etc., which is absolutely insane.
How can it be that a small retailer has to bleed while privately you’re allowed to send tons of stuff, that contradicts everything, and are they really that bored?
chrono-shop
·1 month agoThey want to force the small merchants to give up; there's no other way to explain it anymore.
camillehervier
·1 month agoYou can’t sum it up better than that. Apparently, there’s supposed to be a first reading in the EU Parliament in October (on the 10th, if I remember correctly) on whether the madness with the authorized representatives will be suspended until 20235. But that remains unlikely at best. And if the reading should pass (again, unlikely), then further readings and decisions will follow. Results are not expected until mid/end of 2027. Until then, you pay as a trader. Or just ship only within Germany and to third countries. And even if the suspension came, the individual countries could decide for themselves (as is already the case in Austria, for example).
The EU has no interest whatsoever in small intra-EU trade. It’s simply being crushed. And the big players are happy about that.
marcels-modellbahn-welt
OP1 month ago · EditedDon't know if you're allowed to link externally here. But you can find relevant articles on Google.
According to Verpackungsgesetz-Dot-Com, the first reading for the suspension is planned for 05/10/2026.
They should just do this packaging crap along Danish lines: the packaging manufacturers/importers (and by that I mean the actual manufacturers/importers!) pay a packaging tax. The money is then distributed among the EU countries accordingly. And after that, let these troublemakers leave EU citizens alone with their mental packaging waste.
kometenhuhn
·1 month ago · EditedAccording to the proposal, it is probably supposed to affect only larger companies.
here’s an excerpt of what was decided in June
"Update from June 2026: Exemption only for small businesses?
As part of the consolidation procedure for the content of the easing provisions, the EU Parliament proposed at the end of May a change to the personal scope of the exemption from the obligations to appoint authorized representatives.
The EU Parliament takes the view that the exemption in the area of batteries and packaging should apply only to micro and small enterprises, i.e. those
with a maximum annual turnover of 10 million euros and
a maximum number of 49 employees"
Source is the it-recht-kanzlei in Munich
camillehervier
·1 month agoSo far, this is all very speculative. As it stands, from August onwards you’ll have to be able to name the relevant authorized representatives if you want to trade commercially on the respective sales platforms and ship to other EU countries (whether you’ll actually do that is a completely different question - regardless of that, the authorized representative has to be specified). Otherwise, you won’t be shown to potential customers in the countries concerned anymore. Very simple.
You could also sum it up like this: It’s going to get extremely expensive. And a small merchant simply can’t afford that.
What’s left? Only selling in Germany (and only with “German” and new packaging material, otherwise you’ll still have to license it). And otherwise reaching out to customers outside the EU. But thanks to the world situation, that clientele is getting smaller and smaller.
vergaserland
·2 weeks agoHello
Any grand statements about how everything is crap won't get anyone here anywhere. I think, like me, most people here are small merchants and they're hit hardest of all. I found something that might help a lot of people. Haven't found anything concrete yet, but there is supposed to be a simplified regulation for micro-businesses. Under 10 employees and under 2 million in revenue — does anyone know more about that?
vergaserland
·2 weeks agook found
Yes: micro-enterprises with fewer than 10 employees and an annual turnover of at most €2 million or total assets of at most €2 million are not considered producers in certain cases within the meaning of the PPWR. For example, they are not required to create technical documentation for packaging. This obligation is instead taken on by the supplier based in the EU. There are also exceptions for micro-enterprises in the requirements for reusable packaging and in the ban on certain single-use packaging.
However, there is no exception from extended producer responsibility (EPR): micro-enterprises must also fulfill their producer obligations in all EU countries to which they sell — for example by appointing an authorized representative in each country where they are not themselves established.
ok unfortunately nothing changed with registration
cosmoretroshop
·2 weeks agoThe authorized representative could be overturned in October (first reading) in the "EU Lobbystadel" (Parliament).
As it stands, 15-20 countries have no interest in implementing the whole thing, either by setting high "de minimis thresholds" or simply dragging their feet on everything.
As usual, Germany and France are pushing ahead especially hard (suspicious minds will think the worst).
Germany wants to make every retailer into a producer across the board, since the retailer sticks their label (address label!) on the packaging, with significant tightening and documentation requirements as far as cartons etc. are concerned, and also with imaginary fines.
France seems to change direction every few weeks, especially since their "parcel tax mess" (was it 3 € per non-EU parcel that comes to France) has totally failed, because the Chinese, for example, simply send containers to, say, Amsterdam and they are opened there and then single shipments are sent on to France. At first they also wanted to "postpone it by several months" and then suddenly, two days ago, came the reports that they too are demanding strict rules and immediate implementation.
In summary:
75 % of EU countries don't care about implementation at all, or they understand that this is lobbying by big companies to wipe out the "small" retailers.
15 % are trying to seal off their markets and are excessively making it harder to sell into their countries from within the EU.
10 % (D,F) apparently desperately need money, extra bureaucracy, and want to see as many livelihoods in online retail fail as possible
The numbers are rough estimates, and the justifications are my own exaggerated take.
0 % of EU countries care about the environment. We have to be realistic here. We read that 7000 people have already died in D this year as a result of the heat/climate change (30k across Europe) and we shrug.
That "onlineshop24" on eBay (name used as an example) with 100k annual revenue and 100 kg of cardboard "trash" into the EU (of which almost everything is licensed, recycled and recyclable) now has to pay 5000 € per year to "save the environment" is, in my view, not the "solution" to environmental problems.
Actionism driven by greed for money, at the expense of the little guys, to distract from the real problems.
vergaserland
·2 weeks agoAs for the label and how it defines the manufacturer, the Händlerbund is currently suing against it. At least