Short answer: Extended producer responsibility (EPR) laws make the company that puts packaged goods on a market responsible for the packaging waste. If you ship orders to customers in the EU, most member states treat you as the producer, which means registering with the national packaging scheme, reporting packaging volumes, and paying eco-fees. There is no single EU registration; Germany, France, Spain, and others each run their own system with their own deadlines and fees. Ignoring it risks blocked shipments, marketplace delisting in some countries, and fines that scale with unreported volume.
Why a US brand counts as the producer
EPR assigns responsibility to whoever first places the packaged product on the national market. When you ship direct to a consumer in Germany, there is no EU importer between you and the customer, so you are the one placing it on the market. Your 3PL does not absorb this; the warehouse that picks and packs is not the producer either. The obligation follows the seller. This surprises US brands because nothing about the transaction feels like manufacturing, but the law cares about who introduced the packaging into the country, not where the company is headquartered.
Which countries actually enforce it
Germany is the famous one: the packaging law requires registration in the LUCID registry before you ship a single parcel, and marketplaces check registration numbers. France runs its own scheme with its own declarations and a unique identifier. Spain, Austria, and others have their own systems with different material categories and fee structures. The pattern is fragmentation: every country its own registry, its own reporting calendar, its own definition of what counts. Start with the countries where you have real volume, because registering everywhere on day one is expensive overkill for most brands.
What registration and reporting involve
Registration itself is usually straightforward: company details, estimated packaging volumes by material, and a local authorized representative in some countries. The ongoing work is the reporting: periodic declarations of how much cardboard, plastic, glass, and other materials you shipped, with fees calculated per kilogram. Keep packaging data from your 3PL; without weight and material breakdowns per shipment, the declarations become guesswork. Many brands use a compliance service provider to handle the filings across countries, which is worth it once you are in more than two or three markets.
What happens if you ignore it
Consequences escalate. At the mild end, you are simply non-compliant and accumulating back fees. Germany can block your listings on marketplaces that verify LUCID numbers. Customs in some countries can hold commercial shipments lacking producer registration. Fines exist and they are calculated to hurt: they scale with the packaging you should have reported. The fix is to register before you are caught, because voluntary registration with back declarations is far cheaper than registration after an enforcement notice.
Does using a 3PL in the EU change anything?
Not the core obligation. If your 3PL only stores and ships your goods, you remain the producer. The 3PL becomes relevant only if it imports goods in its own name and sells to you, which is not the standard DTC fulfillment arrangement.
What about the UK?
The UK runs its own EPR scheme, separate from the EU systems. If you sell into both, you register in both. The UK thresholds and reporting work differently, so do not assume EU registration covers Britain.
How much do the fees cost?
For a small brand it is typically hundreds to low thousands of euros per country per year, driven by packaging weight. The registration and representative fees often exceed the eco-fees at small volumes, which is why prioritizing your top markets first makes sense.
Do customers really get charged twice when IOSS fails?
They get charged VAT at delivery even though they paid it at checkout, which feels like double charging. Legally the delivery charge is the import VAT and the checkout charge was supposed to cover it through IOSS. The brand should refund one of the two; eating the delivery surcharge is almost always cheaper than the chargeback and the lost customer.
How long does re-registration take?
With a new intermediary and clean records, days to a couple of weeks depending on the member state. If the revocation followed an audit finding, expect the tax authority to resolve the assessment first, which can take months. This is why the checkout switch matters: you need a compliant way to sell EU orders during the gap.
Can I keep using the old IOSS number while appealing?
No. A revoked number fails validation at import regardless of any appeal. Continuing to put it on declarations just creates more parcels that arrive with surcharges. Appeals run in parallel with re-registration; they do not pause the operational problem.