Research from Amazon reveals the complexity of navigating registration rules across EU Member States and advocates for online marketplaces playing a role in providing the necessary data.

By law, businesses must register for Extended Producer Responsibility (EPR) in every country where they operate. Online marketplaces must also verify the registration status of their sellers before permitting sales.

However, the registration process is complex and fragmented. Amazon has identified 64 unique registration fields across ten EU countries, with each nation requiring an average of sixteen fields. 55% of those fields are thought to be country-specific, while 83% are required by only three countries on average.

Among the unique registration fields, only 17 are mandated in the draft Packaging and Packaging Waste Regulation Implementation Act Annex I. In other words, 73% of current requirements are not legally required across the continent, with each EU country found to request an average of 8 non-mandated fields.

Amazon cautions that producers are being asked for excessive, ‘reporting-stage’ data at registration – packaging volumes, material breakdowns, transport company details, hazardous waste classifications, storage methods, and financial turnover – when many companies do not yet have this information.

Depending on the country, Amazon finds that some packaging registration processes can take between two and six weeks. Some could take longer if the producer needs an authorized representative contract with service providers first.

In multiple Member States, only the producer or an authorized representative can complete the registration process. It is considered a costly process – especially if the seller is operating across several countries and categories.

Registration is also expensive for non-resident producers, who must appoint an authorized representative in each country and product category. The complexity can also raise issues for businesses without their own compliance or legal teams.

Rules around authorized representatives themselves vary across EU regulations, Amazon explains. The EU Battery Regulation requires all distance sellers, both EU and non-EU, to appoint an authorized representative; yet the Packaging and Packaging Waste Regulation only applies the rule to EU distance sellers, leaving non-EU producer rules at the discretion of individual Member States.

Each Member State has its own interpretation of the laws, which fragments the process further. Some countries also introduce their own formalities; Amazon points to Italy as an example, where formal mandates are required for authorized representative appointments – increasing the cost and complexity of the process.

Multiple authentication systems are currently in operation. National electronic ID systems are required to access and complete the registration process in Spain, Sweden, Poland and Italy; others use email-based authentication, with Belgium requiring offline registration via email, manual forms, and signed contracts. These differences introduce technical barriers for cross-border sellers and restrict digital scalability, respectively.

Countries like Italy, Spain and Poland enforce a two-step process for dual registration with a national government registry and a Producer Responsibility Organization. Amazon warns that processes like these increase the length and administrative burden of the registration stage.

It adds that registration portals are often available only in local languages, which makes the process more difficult for international businesses.

“For a business trying to sell across all 10 major EU markets, fragmented requirements create a compliance maze that demands navigating 10 different systems, each with unique processes, timelines, costs, and technical requirements,” Amazon summarizes.

“Businesses must master disparate portals, incompatible authentication systems, and divergent data requirements across member states. This makes compliance a resource-intensive burden that disproportionately impacts smaller participants.”

With the Packaging and Packaging Waste Regulation requiring the European Commission to establish harmonized registration and reporting formats, Amazon calls upon policymakers to develop infrastructure that facilitates efficient data flow between systems, countries, and even waste streams – including packaging.

By introducing API access to digitized and interoperable national registers, Amazon expects Member States to simplify the exchange of registration and reporting data between registries, producers, online marketplaces, and fulfilment service providers. Standardized login processes, unified data fields, and automated data sharing are expected to streamline navigation, avoid duplication, and lessen administrative burden.

Additionally, online marketplaces already utilize ‘Know Your Customer’ processes to acquire much of the producer identification data required at registration. With the necessary systems in place (and the necessary consent and validation), Amazon argues that online marketplaces can submit information directly to registries – relieving the burden on small producers, Producer Responsibility Organizations, and other authorities.

“Online marketplaces present a proven pathway to scale compliance support,” Amazon explains. “In France, Italy, Spain, and Belgium, they already act as EPR intermediaries for reporting and eco-fee payment.

“Extending this intermediary model to registration, while preserving AR frameworks for other obligations, would enable marketplaces to help producers meet core EPR obligations. This approach improves compliance and waste reporting accuracy, streamlines eco-fee collection, all while lowering administrative burden for producers and authorities alike.”

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