# PRO / EPR System Participation Pack

It is a preparation and evidence record for the relationship through which a packaging EPR Producer fulfils applicable national producer-responsibility obligations through a Producer Responsibility Organisation, collective scheme, national system, consortium or another lawful route. The correct route depends on the Member State and packaging stream.

> Generating this pack does not create membership, submit an application, sign a contract, pay a fee, link a national register or prove that participation is active.

Canonical: https://beyogluprofessional.com/templates/pro-system-participation

## Current EU-law layer

### PPWR Article 46 allows collective fulfilment through an authorised PRO — and Member States may make it mandatory.
Regulation (EU) 2025/40 Article 46(1) provides that Producers may entrust an authorised producer responsibility organisation with carrying out EPR obligations on their behalf. It also permits Member States to make that entrustment mandatory. The engine therefore resolves the national route instead of assuming that PRO membership is always optional or always compulsory.

Annex IX Part A also requires the registration information to state how the Producer meets Article 45 responsibilities, including a certificate issued by the PRO where Article 46(1) applies. A real participation certificate is therefore a distinct evidence object, not a label created by this tool.

Official source: https://eur-lex.europa.eu/eli/reg/2025/40/oj

## EU27 participation routes

### Austria (AT)
- Route: Approved organisation / collective route required
- Authority/system: EDM / national packaging framework
- Operating model: Collection and recovery system participation; operator contract/licensing route
- Current state: current
- Research records: 17
- Primary source: https://www.ara.at/en/licensing-service-for-packaging/
- Note: Keep system licensing, quantity reporting and any pre-licensing declarations separate from producer/AR registration.

### Belgium (BE)
- Route: Approved organisation / collective route required
- Authority/system: Interregional Packaging Commission / recognised organisations
- Operating model: Household and commercial/industrial packaging may use different organisations
- Current state: current
- Research records: 10
- Primary source: https://www.fostplus.be/en/members/become-a-fost-plus-member
- Note: Resolve household versus commercial/industrial scope before selecting Fost Plus, Valipac or another lawful route.

### Bulgaria (BG)
- Route: Organisation or lawful individual route
- Authority/system: Bulgarian packaging-waste framework
- Operating model: Recovery organisation contract or lawful individual fulfilment route
- Current state: current
- Research records: 12
- Primary source: https://www.ecobulpack.bg/en/information-for-companies/
- Note: Do not treat an operator application as an active contract. Contract annexes and reporting/payment evidence remain separate.

### Cyprus (CY)
- Route: Approved organisation / collective route required
- Authority/system: Green Dot Cyprus / competent authorities
- Operating model: Membership registration, agreement and recurring declaration relationship
- Current state: current
- Research records: 7
- Primary source: https://greendot.com.cy/
- Note: Membership, declaration and operating-licence references are separate evidence types.

### Czechia (CZ)
- Route: Organisation or lawful individual route
- Authority/system: EKO-KOM / Ministry of Environment
- Operating model: Collective-compliance contract or lawful individual route
- Current state: current
- Research records: 11
- Primary source: https://www.ekokom.cz/en/clients/how-to-join-the-system/
- Note: Official EKO-KOM registration/contract documents control for that route; counter-signature and participant certificate must not be inferred from producer signature.

### Germany (DE)
- Route: Approved organisation / collective route required
- Authority/system: ZSVR / LUCID + approved system operator
- Operating model: System participation agreement plus matching LUCID data reporting
- Current state: current
- Research records: 5
- Primary source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting
- Note: LUCID registration is not system participation. Operator confirmation and LUCID data linkage are distinct evidence events.

### Denmark (DK)
- Route: Approved organisation / collective route required
- Authority/system: DPA + collective scheme
- Operating model: Producer-register scheme request followed by scheme acceptance
- Current state: current
- Research records: 8
- Primary source: https://producentansvar.dk/en/products-and-responsibility/packaging/
- Note: Selected scheme is not officially connected until the register/scheme acceptance flow completes.

### Estonia (EE)
- Route: Organisation or lawful individual route
- Authority/system: Packaging Register / recovery organisations
- Operating model: Registration plus recovery-organisation or lawful self-fulfilment route
- Current state: current
- Research records: 8
- Primary source: https://pakis.envir.ee/pakis/main/welcome
- Note: Keep written representation, register filing, organisation relationship and excise/reporting evidence separate.

### Spain (ES)
- Route: Organisation or lawful individual route
- Authority/system: MITECO RPP + authorised individual/collective EPR systems
- Operating model: RPP registration plus individual SIRAP or authorised collective SCRAP participation
- Current state: current
- Research records: 10
- Primary source: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/prevencion-y-gestion-residuos/registro-productores-producto-seccion-envases.html
- Note: When a collective SCRAP route is used, retain the real adhesion/participation certificate and RPP linkage; SCRAP selection alone is not registration.

### Finland (FI)
- Route: Approved organisation / collective route required
- Authority/system: Rinki / producer organisations; Åland separately
- Operating model: Producer-organisation contract for mainland Finland; separate Åland regime when applicable
- Current state: current
- Research records: 11
- Primary source: https://rinkiin.fi/en/producer-responsibility/join-a-producer-organisation/finnish-packaging-producers-ltd/
- Note: Resolve mainland Finland versus Åland and ordinary packaging versus deposit packaging before onboarding.

### France (FR)
- Route: Approved organisation / collective route required
- Authority/system: ADEME / approved eco-organisations
- Operating model: Stream-specific eco-organisation membership and IDU/SYDEREP linkage
- Current state: transition
- Research records: 7
- Primary source: https://clients.citeo.com/en/public/registration/type
- Note: Select the correct REP stream and approved eco-organisation; household and professional packaging routes must not be collapsed.

### Greece (GR)
- Route: Approved organisation / collective route required
- Authority/system: EOAN / HERRCO and approved systems
- Operating model: EMPA registration followed by system participation contract
- Current state: current
- Research records: 4
- Primary source: https://www.herrco.gr/
- Note: EMPA producer registration is a prerequisite/evidence layer separate from the participation contract and recurring declaration.

### Croatia (HR)
- Route: National authority / central system route
- Authority/system: FZOEU / RPPO
- Operating model: National RPPO/Fund workflow with stream-specific obligations; DRS branch where applicable
- Current state: current
- Research records: 8
- Primary source: https://rppo.fzoeu.hr
- Note: Do not invent a private-PRO membership where the national Fund/RPPO workflow controls; beverage DRS has a separate pre-market branch.

### Hungary (HU)
- Route: National authority / central system route
- Authority/system: Waste Management Authority / MOHU
- Operating model: Authority registration plus MOHU Partner Portal/EPR relationship
- Current state: current
- Research records: 9
- Primary source: https://mohu.hu/hu/partnerportal
- Note: Treat authority registration, MOHU account, reporting and payment as distinct states; do not manufacture a membership certificate.

### Ireland (IE)
- Route: Organisation or lawful individual route
- Authority/system: Local authority / Repak; Re-turn for DRS
- Operating model: Repak membership or lawful self-compliance, with a separate DRS branch
- Current state: current
- Research records: 8
- Primary source: https://repak.ie/for-business/members/
- Note: Major-producer route, membership classification and DRS obligations require separate assessment.

### Italy (IT)
- Route: Consortium / central system architecture
- Authority/system: CONAI + material consortia / competent ministry
- Operating model: CONAI membership and material-consortium/CAC mechanics; PPWR register transition separately tracked
- Current state: current
- Research records: 7
- Primary source: https://www.conai.org/imprese/servizi-gestione-adempimenti-consortili-e-opportunita-imprese/soggetti-obbligati-e-modalita-di-adesione/adesione-e-termini-generali/
- Note: Do not model Italy as a generic one-PRO selector. CONAI, material consortium and future PPWR register states are distinct.

### Lithuania (LT)
- Route: Organisation or lawful individual route
- Authority/system: AAA / GPAIS + licensed organisations
- Operating model: GII/GPAIS registration plus licensed organisation or lawful individual fulfilment
- Current state: current
- Research records: 10
- Primary source: https://www.gpais.eu/en/web/guest/viesi-savado-duomenys
- Note: Foreign-subject onboarding and DRS/USAD branches may add separate evidence.

### Luxembourg (LU)
- Route: Approved organisation / collective route required
- Authority/system: Environment Administration / Valorlux
- Operating model: Packaging-system relationship plus national reporting obligations
- Current state: current
- Research records: 8
- Primary source: https://www.valorlux.lu/
- Note: DigiDot or marking functionality is not participation proof. Retain contract/account evidence separately.

### Latvia (LV)
- Route: Organisation or direct statutory/tax route
- Authority/system: State Revenue Service / packaging management systems
- Operating model: Management-system contract or direct natural-resources-tax route where applicable
- Current state: current
- Research records: 9
- Primary source: https://www.vid.gov.lv/lv/dabas-resursu-nodoklis
- Note: The engine must allow a lawful tax/direct route instead of forcing a PRO selection.

### Malta (MT)
- Route: Approved organisation / collective route required
- Authority/system: ERA / authorised recovery schemes; BCRS for DRS
- Operating model: ERA registration plus authorised scheme participation where required
- Current state: current
- Research records: 9
- Primary source: https://era.org.mt/topic/packaging-and-packaging-waste/
- Note: ERA registration, scheme permit status, scheme membership and BCRS participation are separate records.

### Netherlands (NL)
- Route: National authority / central system route
- Authority/system: Verpact / national packaging framework
- Operating model: Central packaging-fee/reporting system with PPWR register transition tracked separately
- Current state: transition
- Research records: 7
- Primary source: https://www.verpact.nl/en/administration
- Note: Do not treat future PPWR producer-register mechanics as already completed by present Verpact administration.

### Poland (PL)
- Route: Organisation or lawful individual route
- Authority/system: BDO / Marshal offices + recovery organisations
- Operating model: BDO registration plus recovery-organisation or self-compliance/payment route
- Current state: current
- Research records: 8
- Primary source: https://www.biznes.gov.pl/pl/portal/ou170
- Note: BDO registration does not by itself prove transferred recovery obligations or payment compliance.

### Portugal (PT)
- Route: Approved organisation / collective route required
- Authority/system: APA / SILiAmb + licensed SIGRE management entities
- Operating model: Producer registration plus licensed management-entity participation
- Current state: current
- Research records: 9
- Primary source: https://apambiente.pt/residuos/registo-de-produtores-de-produtos
- Note: Official APA/SIGRE models and entity documents control over generic Beyoğlu forms.

### Romania (RO)
- Route: Organisation or lawful individual route
- Authority/system: AFM + authorised OIREP
- Operating model: AFM obligations plus OIREP transfer contract or lawful direct fulfilment
- Current state: current
- Research records: 10
- Primary source: https://www.afm.ro/
- Note: OIREP authorisation/annual endorsement and the producer's actual transfer contract are separate facts.

### Sweden (SE)
- Route: Approved organisation / collective route required
- Authority/system: Naturvårdsverket + approved producer responsibility organisations
- Operating model: Producer registration plus approved PRO relationship; deposit branch where applicable
- Current state: current
- Research records: 10
- Primary source: https://www.naturvardsverket.se/en/services-and-permits/e-services/e-services-for-producer-responsibility/
- Note: Verify that the organisation is approved for the relevant packaging route; Returpack/Pantamera remains a separate deposit-system branch.

### Slovenia (SI)
- Route: Organisation or lawful individual route
- Authority/system: ARSO / approved collective systems
- Operating model: Producer register plus collective or individual fulfilment route
- Current state: transition
- Research records: 10
- Primary source: https://www.gov.si/zbirke/storitve/evidenca-proizvajalcev-embalaza-in-plasticni-proizvodi/
- Note: Keep foreign-producer registration, collective contract and national implementation transition as separate states.

### Slovakia (SK)
- Route: Approved organisation / collective route required
- Authority/system: ISOH / Ministry + OZV
- Operating model: Producer registration plus authorised producer-responsibility organisation relationship
- Current state: current
- Research records: 6
- Primary source: https://www.slov-lex.sk/
- Note: ISOH producer registration and OZV participation are separate evidence layers.

## Legal-status boundaries

- I understand that generated does not mean submitted, signed, operator-accepted, registered or active.
- I understand that generic XLSX, CSV, XML and JSON exports are portable records, not official national submission formats.
- I will use the official authority/operator form or portal where the selected country route requires it.

## Lifecycle

- Route Assessed
- Operator Selected
- Individual Route
- Application Prepared
- Application Submitted
- Agreement Issued
- Producer Signed
- Operator Accepted
- Payment Pending
- Participation Confirmed
- Certificate Issued
- Register Linked
- Active
- Renewal Reporting Cycle
- Amended Switched
- Terminated
- Archived

## Evidence model

- **Producer registration proof:** Authority/register evidence. This is not automatically PRO participation proof.
- **Application / onboarding proof:** Submission receipt, portal reference or application acknowledgement.
- **Agreement / membership document:** The actual operator/system contract, membership terms or equivalent legal relationship.
- **Operator acceptance / countersignature:** Evidence that the receiving organisation accepted the producer relationship.
- **Contribution / payment evidence:** Invoice, payment receipt or contribution record. Payment alone does not prove active participation.
- **Participation certificate / confirmation:** Certificate, confirmation or participant record actually issued by the organisation/system.
- **National register linkage:** Evidence that the national register reflects the organisation/system where the workflow requires linkage.
- **Reporting account evidence:** Portal account, reporting account or recurring declaration relationship.
- **Official form / portal record:** Official national/operator form or portal evidence that supersedes a generic template.
- **Termination / scheme-switch evidence:** Replacement, termination, switch or deregistration evidence for lifecycle changes.

## How to use

1. **Resolve the national route** — Determine whether the country uses an approved organisation, central authority/system, consortium, lawful individual route or direct statutory route.
2. **Keep registration separate** — Record the national producer registration independently from the system relationship.
3. **Record the actual organisation** — Capture the organisation, approval reference, stream, application and agreement identifiers.
4. **Advance lifecycle only on evidence** — Do not mark operator acceptance, certificate issuance, register linkage or active participation before the event actually occurs.
5. **Retain evidence** — Store contract, acceptance, certificate, payment and register-link evidence with provenance and SHA-256 hashes.
6. **Use official receiving formats** — Where an authority or operator publishes a form, portal process or official dataset, use it instead of treating the portable export as the official submission.

## Natural questions

### Is producer registration the same as PRO participation?
No. Registration and participation are separate compliance events. Some national workflows link them, but one does not automatically prove the other.

### Does choosing a PRO mean I have joined it?
No. Selection may be followed by application, agreement, signature, operator acceptance, payment, certificate issuance or national-register linkage before participation is operationally active.

### Does a LUCID number prove German system participation?
No. German producer registration in LUCID and system participation/data reporting are separate obligations and evidence layers.

### Can one PRO cover all EU Member States?
Do not assume so. Packaging EPR participation is implemented through national systems and authorised organisations. The valid organisation, stream and evidence must be resolved per country.

### Does paying an invoice prove participation?
Not necessarily. Payment proves a financial event. Active participation may still require an accepted agreement, certificate, account activation or register linkage.

### Can I comply individually instead of joining a PRO?
Only where the national law and the selected packaging stream permit an individual or direct route. The engine only presents that route where the country adapter allows it.

### What evidence proves participation?
Evidence may include an accepted contract, participant/member number, operator certificate or confirmation, payment record, reporting account and national register linkage. The exact combination is country-specific.

### Is this pack an official national form?
No. It is a preparation/evidence tool. An official authority or operator form, portal process or schema takes precedence whenever one exists.