# Check your PPWR and EPR position when selling into the EU for free. > Free preliminary assessment for cross-border EU packaging EPR: identify your likely EPR Producer route, countries that require verification and your next three compliance checks. Canonical: https://beyogluprofessional.com/assessment Tell us where the selling company is established, which EU countries you sell to and how the transaction actually works. **You do not need to know the legal terminology.** The assessment uses those commercial facts to indicate the likely EPR Producer route, which country obligations need verification and your next three steps. It is not legal advice; it is a verifiable working plan. ## In short **“I export from outside the EU” does not by itself determine your PPWR/EPR role.** What matters is which legal entity sells, the EU country the product reaches, whether the customer is the final user or an independent importer/distributor, and who first makes the packaged product available in that country. Own-brand, marketplace and dropshipping facts complete the picture. ## We will derive the legal route. If you use more than one sales model, choose the dominant route or the mixed option. The result is only as precise as the information you provide. ### 1. Where is the company making the sale established? Use the legal entity that accepts the order and issues the invoice. - Company established in Türkiye - Company established in another non-EU country - Separate legal entity / subsidiary established in the EU - Only a branch, warehouse or VAT registration in the EU - I do not know which company should be assessed ### 2. Which EU countries receive your packaged products? Select every destination where the product is shipped or the final customer is located. Austria (AT), Belgium (BE), Bulgaria (BG), Croatia (HR), Cyprus (CY), Czechia (CZ), Denmark (DK), Estonia (EE), Finland (FI), France (FR), Germany (DE), Greece (GR), Hungary (HU), Ireland (IE), Italy (IT), Latvia (LV), Lithuania (LT), Luxembourg (LU), Malta (MT), Netherlands (NL), Poland (PL), Portugal (PT), Romania (RO), Slovakia (SK), Slovenia (SI), Spain (ES), Sweden (SE) ### 3. How do you sell to the EU customer? Choose the actual commercial route, not a legal label. - Direct to the final user through our own website - To the final user through Amazon, Etsy, eBay or another marketplace - B2B sale to an independent EU importer / distributor - We use more than one model ### 4. Is the product or packaging sold under your own name or brand? This can affect the technical PPWR role; it does not determine the EPR Producer by itself. - Yes, under our own name / brand - No, we resell another brand - Both - Not sure ### 5. Where is the product physically dispatched from? Stock location does not determine the legal role by itself, but it helps establish the transaction route. - Stock / warehouse in Türkiye - EU fulfilment centre / warehouse - Supplier in China or another country ships directly to the customer - More than one stock / dispatch model ### 6. Is there an independent importer or distributor in the EU buying the goods in its own name? A carrier or customs broker is not automatically an independent commercial importer. - Yes, an independent importer / distributor buys the goods - Our own EU subsidiary receives the goods in its own name - No, we sell directly to the final user - I do not know who holds the importer role ## 01 · LIKELY ROLE ### First identify which legal entity is actually making the sale. EPR Producer analysis follows the legal entity carrying out the transaction, not merely a trading name. Identify which entity accepts the order, invoices the customer and places the goods on the EU market. ### An EU branch or VAT registration is not by itself a separate EU company. The first assessment should follow the establishment of the parent company. If you have a separately incorporated EU subsidiary, assess that entity separately. ### An independent EU importer / distributor may carry the Producer role. In this B2B route it would be incorrect to automatically classify the non-EU seller as the EPR Producer. Verify who buys the goods, who first places them on the relevant market and the contractual chain. ### There is a high likelihood that you are the EPR Producer in the destination countries. Direct supply by a business established outside the EU to a final user in another Member State can fall within the PPWR Producer definition. Verify the actual Producer, registration, EPR system and representation route separately in every selected country. ### More than one Producer route may apply. Direct-to-final-user sales and B2B sales through an independent importer may produce different results. Treat each sales model as a separate transaction route. ### The selling EU legal entity may be the EPR Producer depending on the destination country. Identify where the separately incorporated EU company is established and in which other Member States it sells to final users. Cross-border EPR must be assessed separately when establishment and destination differ. ### Verify the transaction route before determining Producer status. The information provided is not sufficient for one reliable Producer conclusion. Clarify the selling legal entity, customer and first placing-on-the-market relationship. ## 02 · LIKELY COUNTRY OBLIGATIONS Registration, EPR system participation and representation are verified separately for each destination country. - REGISTRATION: Registration / register: check - EPR SYSTEM: PRO / EPR system: check - EPR REPRESENTATIVE: Verification required ## 03 · NEXT 3 STEPS Resolve these in order. ### STEP 01 · Verify the EPR Producer role for one transaction route. Confirm the selling legal entity, buyer and first placing-on-the-market route with the Producer Status Checker. [Check Producer status →](https://beyogluprofessional.com/tools/producer-status-checker) ### STEP 02 · Open the actual EPR route for each selected country. Verify registration, the official system/PRO, national transition status and other country obligations separately. [Check country obligations →](https://beyogluprofessional.com/tools/eu-country-obligation-checker) ### STEP 03 · Check the EPR Authorised Representative requirement country by country. For third-country sales, do not assume that one EU-wide representation result applies everywhere. [Check representation route →](https://beyogluprofessional.com/tools/epr-ar-checker) ## Why do we ask these questions? The real transaction — not your label — determines the legal route. ### COMPANY · Where is the company established? A separately incorporated EU subsidiary is not the same as a branch or VAT registration. ### CUSTOMER · Final user or independent importer? Direct-to-consumer sales and B2B sales to an independent EU distributor may not create the same Producer route. ### COUNTRY · Which Member State receives the product? PPWR is a common framework, while packaging-EPR operations are still checked country by country. ## Frequently asked questions ### Is this result legal advice or an official decision? No. It is an operational preliminary assessment generated from the commercial facts you provide. Final Producer status and national obligations must be verified against the actual transaction, contractual structure and current official sources. ### Can I be the EPR Producer if I sell directly from Türkiye to an EU consumer? Yes. The PPWR Producer definition includes cross-border routes in which a business established in a third country can make packaging or packaged products available for the first time directly to a final user in another Member State. ### Does selling under my own brand automatically make me the EPR Producer? No. Your name or brand may matter to the technical PPWR manufacturer analysis, while EPR Producer status is determined separately through the destination country and the actual sale / placing-on-the-market route. ### Does selling through Amazon or Etsy change the legal result? A marketplace is part of the sales channel. First determine the actual Producer and national EPR obligation. A marketplace request for a registration number or other evidence does not replace the underlying national compliance. ### Does an EU warehouse or VAT number automatically make my company EU-established? Not automatically. Commission guidance distinguishes a separately incorporated EU company from a branch or tax registration. The real legal-entity structure must be checked. ## Regulatory note Regulatory logic last reviewed: 31 August 2026 This assessment produces general scope/triage using Regulation (EU) 2025/40 Article 3(1)(15), Article 44 and Article 45 together with Commission Guidance dated 10 June 2026. Country-specific registration, PRO/EPR system, EPR Authorised Representative, tariff, tax and deadline results must be verified separately in the relevant national source. - [Regulation (EU) 2025/40 ↗](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng) - [Commission Guidance C/2026/3084 ↗](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C_202603084) ## LLM discovery - llms.txt: https://beyogluprofessional.com/llms.txt - llms-full.txt: https://beyogluprofessional.com/llms-full.txt - Markdown: https://beyogluprofessional.com/assessment/index.md