DIRECT-TO-CONSUMER · EU27 WORKFLOW

Selling packaged goods directly to EU end users? Build the compliance route before you ship.

A direct cross-border sale can make the foreign seller itself the packaging EPR Producer in the destination Member State. The correct workflow then runs country by country: identify the Producer, resolve EPR representation, use the current national register and EPR system, prepare packaging data, handle fulfilment-provider information, reporting, regulatory funding and evidence.

EU27PPWR · 12.08.2026Browser-local onlyRegulatory review: 08.09.2026

Start / continue DTC work →Open Workspace →

Direct answer

What changes when you sell directly to the EU end user?

Under PPWR Article 3(15)(c)–(d), a manufacturer, importer or distributor established in one Member State or a third country can become the Producer when it makes packaged products available for the first time directly to end users in another Member State. That DTC route can therefore place the destination-country packaging EPR work on the foreign seller rather than on a later EU reseller.

Producer status follows the actual transaction, not the factory, brand or VAT registration by default.
For a Producer established in another Member State, Article 45(3) currently requires an EPR authorised representative in the destination Member State.
For a Producer established in a third country, the destination Member State may require an EPR authorised representative; the national operating route must be verified.
An own webshop is not automatically the provider of an online platform for Article 45(4)–(6).
A qualifying fulfilment service provider has a separate Article 45(7)–(8) information and verification workflow.

DTC

First decide whether the transaction is truly direct-to-consumer.

Use this checklist when the selling entity itself supplies packaged goods directly to an end user in the destination Member State. If an independent importer or reseller makes the first national supply, the Producer analysis can change. Marketplace intermediation also needs its own platform evidence workflow.

✓ Own webshop or other direct-order channel → continue with the DTC checklist.

↔ Independent importer/reseller before the end user → review the general EU Market Entry workflow.

↔ Marketplace or mixed route → separate the direct and marketplace transactions before closing Producer status.

Article 45(7)–(8)

Fulfilment service provider is a separate legal test.

For PPWR Article 45, the definition comes from Regulation (EU) 2019/1020: the provider must offer at least two of warehousing, packaging, addressing and dispatching, without owning the goods. Postal, parcel-delivery and freight-transport services are excluded from that definition.

If the provider qualifies, the Producer must provide the Article 45(4)(a)–(b) registration information and self-certification when the service contract is concluded; the provider then makes best efforts to assess whether the information is reliable and complete.

Do not label every carrier or 3PL an FSP. Record the actual services, ownership position and whether the provider is only a postal/parcel/freight operator.

Workflow

Nine DTC work records, in dependency order

The checklist keeps legal qualification, registration, EPR-system participation, packaging data, fulfilment-provider evidence, operation and final proof separate. One registration number never closes the whole country file.

01Route

Confirm the direct-to-consumer route

Record the selling entity, direct-sales channel, end-user type and whether an independent importer/reseller enters the chain first.

Why: The cross-border Producer rule depends on the actual transaction.
Evidence: DTC route assessment and sales-channel record.

02Producer

Determine the packaging EPR Producer

Identify the legal entity that is the Producer for the actual transaction and destination country.

Why: Producer is not automatically the manufacturer, brand owner or warehouse operator.
Evidence: Producer assessment and reasoning.

03Representation

Resolve EPR authorised representation

Apply Article 45(3) and the current destination-country procedure to the actual Producer and establishment facts.

Why: EU-established cross-border Producers and third-country Producers do not follow exactly the same statutory wording.
Evidence: Conclusion, mandate and acceptance/registration evidence where applicable.

04Register

Complete destination-country producer registration

Use the current national registration infrastructure for the correct Producer and keep the official record.

Why: Registration is distinct from PRO/system participation, reporting and payment.
Evidence: Registration number plus authority/public-register evidence.

05EPR system

Connect the applicable packaging EPR system / PRO

Join the collective or individual route required for the packaging stream and destination country.

Why: A registration number does not prove participation in the required EPR system.
Evidence: Contract, member ID, certificate or equivalent participation evidence.

06Packaging data

Prepare destination packaging data

Build component, material, weight, destination and reporting-period data that can support the national declaration route.

Why: DTC sales still have to be measured and attributed to the correct country and reporting period.
Evidence: Packaging ledger, source weights and reconciliation record.

07Fulfilment

Resolve the fulfilment-service-provider information route

Determine whether the provider meets the legal FSP definition and, if it does, provide the Article 45 information and retain the provider-side evidence.

Why: Article 45(7)–(8) applies separately from online-platform duties.
Evidence: FSP qualification record, information pack and acceptance/verification evidence where available.

08Operate

Set reporting, regulatory funding and payment controls

Build the declaration calendar, contribution workflow, prefunding/payment controls and recurring evidence process for the country.

Why: Operational EPR continues after registration and system onboarding.
Evidence: Calendar, filing receipts, invoices and payment evidence.

09Launch gate

Close the DTC evidence file and launch gate

Reconcile the Producer decision, representation, registration, system, packaging data, FSP route, reports and payments before treating the destination as ready.

Why: Operational readiness requires the work and its proof to exist.
Evidence: Country evidence-file reference, final review date and launch-gate conclusion.

Start / continue DTC work →

EU27

EU27 destination layer

The DTC rule starts at EU level, but registration, EPR-system participation and operating evidence remain Member-State specific. The country layer below uses the reviewed 5 September 2026 operating dataset and preserves critical review blocks where a current official route cannot yet be relied on.

EU27 dataset: 2026-09-05

Country	Authority / body	Current register / route	EPR system / PRO	Review state	Official source
AustriaAT	BMLUK / EDM	EDM / ZAReg	Collection & recovery systems	Operating route	EDM — Austrian packaging / producer-responsibility infrastructure ↗Country guide →
BelgiumBE	Interregional Packaging Commission (IRPC/IVCIE)	EPRiBEL / PRO registration	Fost Plus (household); Valipac (industrial/commercial)	Review current route	Interregional Packaging Commission — Belgian packaging EPR ↗Country guide →
BulgariaBG	MOEW / competent environmental authorities	Current national waste / EPR administrative systems	Licensed packaging recovery organisations	Operating route	MOEW — Packaging waste / producer-responsibility framework ↗Country guide →
CyprusCY	Department of Environment	Article 44 packaging register portal not publicly identified at 5 Sep 2026 — verify the Department of Environment route before activation	Green Dot Cyprus historical collective route — published operating licence stated validity to 30 Jun 2026; fresh renewal/re-approval evidence required before reliance	Fresh official verification required	Green Dot Cyprus — Operating Licence (published validity to 30 June 2026) ↗Country guide →
CzechiaCZ	Ministry of Environment / authorised packaging system	EKO-KOM client/system records; national producer obligations	EKO-KOM	Operating route	Czech Ministry of Environment — Packaging obligation holders ↗Country guide →
GermanyDE	ZSVR	LUCID Packaging Register	Dual systems	Operating route	ZSVR — LUCID registration and packaging obligations ↗Country guide →
DenmarkDK	Dansk Producentansvar (DPA) / Danish EPA	National Producer Register (DPA)	Collective schemes	Operating route	DPA — Packaging producer responsibility ↗Country guide →
EstoniaEE	Climate Ministry / Packaging Register	PAKIS (current packaging register)	TVO and other PROs	Operating route	Estonian Climate Ministry — Extended Producer Responsibility ↗Country guide →
SpainES	MITECO	Registro de Productores de Producto (RPP) — Packaging Section	Collective EPR schemes (SCRAP)	Operating route	MITECO — RPP Packaging Section ↗Country guide →
FinlandFI	Pirkanmaa ELY / national producer-responsibility authority	Producer records via producer organisation / Rinki	Finnish Packaging Producers; Sumi	Operating route	Rinki — Finnish packaging producer responsibility ↗Country guide →
FranceFR	ADEME / competent ministry	SYDEREP / IDU	Citeo, Adelphe, Léko and approved schemes by stream	Review current route	ADEME — REP producer / IDU public data ↗Country guide →
GreeceGR	Hellenic Recycling Agency (EOAN)	National Producer Register (EMPA)	HERRCO / approved systems	Operating route	EOAN — Hellenic Recycling Agency ↗Country guide →
CroatiaHR	Environmental Protection and Energy Efficiency Fund (FZOEU)	RPPO	FZOEU system / authorised schemes	Operating route	FZOEU — Register of Producers with Extended Responsibility (RPPO) ↗Country guide →
HungaryHU	National Waste Management Authority / MOHU	Authority registration + MOHU Partner Portal / OKIR workflow	MOHU concession system	Operating route	MOHU — Hungarian EPR system ↗Country guide →
IrelandIE	Department of Climate / local enforcement	Current approved-body / producer-responsibility route	Repak	Operating route	Ireland — Extended Producer Responsibility guidance ↗Country guide →
ItalyIT	MASE / CONAI system	CONAI membership / declaration systems	CONAI + material consortia	Operating route	MASE — PPWR producer-status self-assessment / national transition ↗Country guide →
LithuaniaLT	Environmental Protection Department / EPA	GPAIS / GII register	Licensed producer/importer organisations	Review current route	GPAIS — Lithuanian product, packaging and waste accounting system ↗Country guide →
LuxembourgLU	Environment Agency	Environment Agency EPR registration / approved-organisation route	Valorlux / applicable approved organisation	Operating route	Luxembourg Environment Agency — Extended Producer Responsibility ↗Country guide →
LatviaLV	State Environmental Service (VVD)	No separate PPWR/EPR packaging producer number currently issued; current operator/tax route continues	Producer responsibility systems / Natural Resources Tax route	Operating route	VVD — Packaging producers and obligations ↗Country guide →
MaltaMT	Environment & Resources Authority (ERA)	National Register of Producers of Packaging	GreenPak / GreenMT / applicable authorised scheme	Operating route	ERA — Packaging and Packaging Waste ↗Country guide →
NetherlandsNL	ILT / national EPR framework; Verpact operationally	Verpact producer/importer declaration system	Verpact	Review current route	Verpact — Dutch packaging producer/importer obligations ↗Country guide →
PolandPL	Marshal offices / Ministry climate systems	BDO	Packaging recovery organisations / self-compliance routes	Review current route	BDO — Polish waste / producer register ↗Country guide →
PortugalPT	Agência Portuguesa do Ambiente (APA)	SILiAmb producer / packager register	Licensed management entities	Operating route	APA — Producer registration / SILiAmb ↗Country guide →
RomaniaRO	Environmental Fund Administration (AFM) / environmental authority	AFM online declaration systems	OIREP organisations	Operating route	AFM — Environmental Fund online declaration system ↗Country guide →
SwedenSE	Swedish Environmental Protection Agency	EPA producer-responsibility e-service	Approved producer responsibility organisations	Operating route	Swedish EPA — Producer Responsibility for Packaging ↗Country guide →
SloveniaSI	ARSO	Evidence of Producers — Packaging	Packaging waste management schemes	Operating route	GOV.SI / ARSO — Evidence of Producers: Packaging ↗Country guide →
SlovakiaSK	Ministry of Environment / ISOH	ISOH list of packaging producers	Authorised PROs (OZV)	Operating route	ISOH — Register of Packaging Producers ↗Country guide →

Workspace

One compliance cart for every checklist

Your DTC progress is saved to the same browser-only Workspace used by the EU Market Entry Checklist. The sitewide dock shows active checklist work from every public page, and the full Workspace lets you return to the next open task.

No DTC form entry is sent to Beyoğlu Professional from this public checklist.

Start / continue DTC work →Open Compliance Workspace →

Sources

Primary legal and operating sources

The page separates binding EU rules, Commission guidance and country operating sources. Proposed legislation is labelled as a proposal, not current law.

Current PPWR textRegulation (EU) 2025/40 · Articles 3, 44, 45 Commission PPWR guidanceC/2026/3084 · 10.06.2026 FSP legal definitionRegulation (EU) 2019/1020 · Article 3(11)Article 45(3) suspension proposal2025/0395(COD) · ongoing proposal, not adopted law 2025/0395(COD)2025/0395(COD) · ongoing proposal, not adopted law

AEO

Questions businesses ask

Does selling through my own webshop make me an online-platform provider under PPWR Article 45?

Not merely because you operate your own webshop. Article 45(4)–(6) targets providers of online platforms within the scope of the Digital Services Act provision cited there. Your own direct-sales route still needs Producer, registration, EPR and any applicable fulfilment-provider analysis.

If I ship from a fulfilment warehouse in the EU, does the warehouse become the Producer?

Not automatically. Producer status follows Article 3(15) and the actual first making-available transaction. The warehouse location can matter operationally, but it does not replace the Producer analysis.

Do I need an EPR authorised representative in every EU country?

For a Producer established in one Member State and caught by Article 3(15)(c) or (d), Article 45(3) requires an EPR authorised representative in each other Member State where it first makes packaging or packaged products available. For third-country Producers, Article 45(3) allows Member States to require an EPR authorised representative, so the national route must be verified.

Is a parcel carrier a fulfilment service provider?

Not on that fact alone. The referenced EU definition requires at least two of warehousing, packaging, addressing and dispatching without ownership of the goods, and excludes postal, parcel-delivery and freight-transport services.

Supporting tools

Producer Status Checker →EPR AR Checker →Packaging Weight Calculator →Compliance Deadline Calculator →

This checklist is a regulatory work-preparation tool. A completed task or READY result does not itself prove registration, authority acceptance, PRO participation, filing, payment or legal compliance. Retain the underlying official evidence and obtain professional advice where the facts or national procedure are uncertain.