Custom EPR registration software for every EU country
Since August 2026, you cannot access the market without EPR registration, and that registration applies per Member State where you sell. This is not an administrative formality to be sorted out afterwards: sales platforms check for it and block offers without a valid number. If you supply eight countries, you have eight registrations and eight reporting cycles.
Why this differs by country
Extended producer responsibility is regulated at European level but implemented nationally. Each Member State has its own registers, its own waste streams, its own fees and its own reporting deadlines. Packaging, electronics, batteries and textiles are separate streams, each with its own registration, and that multiplies: eight countries times four streams is thirty-two obligations.
Since 12 August 2026, you must also appoint an authorised representative in each Member State where you sell without being established there. This is an appointment with formal status, not a service provider you simply hire. And mind the sequence: in Germany, registration in the packaging register must be carried out by your own company; the authorised representative cannot take that over on your behalf.
In practice, things go wrong with volumes. You must report, per country and per stream, how much material you have placed on that market, in kilograms and by material type. That data sits in your sales records and your packaging specifications, but rarely in the same form. Anyone compiling it manually each year is working from estimates and cannot substantiate them in an audit.
How we build this
The combination of country and stream is the unit. Everything hangs on it: the registration number, the authorised representative, the fee and the reporting date.
For each country and each stream: are you obliged to register, what is your number, who is your authorised representative, and when must you report. Without that overview, you don't know what you're missing.
What went to which country, and how much packaging material was attached to it. That is a calculation drawing on two sources that rarely line up.
Weight per material type per product. This is the dull part, and it is precisely the part on which the substantiation rests.
Each country has its own rhythm and its own deadline. You cannot keep track of dozens of them with a shared calendar.
What the software actually does
The register of obligations supports the whole. What else you need depends on how many countries you supply and how many streams you touch.
Registrations per country and per stream
Number, status, authorised representative and validity, in one place. This is also what a sales platform will ask from you before it admits your offer.
Packaging specification per product
Weight per material type, recorded against the product rather than in a loose spreadsheet. This is where every substantiated report begins.
Volume per country from sales
What went to which market, multiplied by the specification. A retrospective estimate is not substantiation in an audit.
Reporting deadlines monitored per country
Each country on its own schedule. The system warns you in advance and keeps track of what has been submitted and what has not.
Substantiation retained per report
Which data was included in last year's report. In an audit or a correction, that is the question, and you cannot reconstruct it from your current position.
Connecting to your sales systems
Orders, countries and items come from your webshop or ERP via integrations. A second administration is guaranteed not to drift out of step.
Who we build for
How many obligations you have depends on where and what you sell. Four situations.
Webshops shipping to multiple countries
This is where it bites hardest: every country you ship a parcel to is a market in which you must be registered. Platforms check for this and block offers without a valid number.
Producers with their own brand
You are the producer within the meaning of the regulations, even when someone else sells the product. Your packaging specification then becomes the basis for the reporting across your entire chain.
Importers and distributors
Whoever places a product on a market first is the responsible party. That shifts with your terms of supply, and that is exactly where the discussion arises.
Electronics, batteries and textiles
Alongside packaging, there are separate waste streams with their own registers. See also WEEE reporting and collection administration.
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Registers, fees and reporting deadlines change by country and by year. Everything in this should be configurable and stored per reporting year.
Why Appfront
Country times stream is the unit
We build the register around that combination. A list of registration numbers without the stream attached leaves exactly the gaps you are looking for.
The volume must come from your sales
We calculate it from orders and item specifications. An annual estimate is not evidence when you are audited.
Dozens of deadlines are not a calendar task
We track reporting deadlines per country in the system, because keeping them by hand does not scale beyond one or three countries.
We do not build your legal position
Whether you are obliged to register in a country and who counts as the producer there is a legal question. We build the implementation around that outcome.
Security and privacy
An EPR administration reveals in which countries you sell how much, and how that relates to your margins. That is commercially sensitive information. We set access by role and by entity, give an authorised representative or service provider only the country for which they act, and log every inspection.
On the reporting side, reproducibility matters most. In the event of a correction or an audit, you must be able to show which data was included in the report for a given year, even if your item file has changed since. We therefore freeze the underlying data for each report, and a correction is recorded as a visible correction alongside the original report. How we handle security ourselves is set out in our information security policy; reports from outside come through our CVD policy.
Frequently asked questions about EPR abroad
Yes. Extended producer responsibility is regulated nationally: each Member State has its own registers and its own procedures. Registration in the Netherlands does not cover your sales in Germany or France. In addition, each country requires a separate registration per waste stream.
If you sell into a Member State where you are not established, you must appoint an authorised representative there to fulfil the obligations on your behalf. That obligation applies from 12 August 2026. Pay attention to the order per country: in Germany, registration in the packaging register must be carried out by your own company and the authorised representative cannot take that over.
Then you have no market access. Sales platforms check for a valid registration number and block listings without one. In addition, national authorities can enforce. So it is not a risk that only becomes visible during an inspection, but something that immediately halts your sales.
Record how much packaging material each product contains per material type, then multiply that by the quantity sold into each country. Setting this up takes effort, but it becomes almost fully automatic afterwards. An estimate after the fact is common practice, yet it is also the weakest point in most files.
The Packaging and Packaging Waste Regulation sets requirements for the packaging itself: recyclability, recycled content and labelling. This page covers the registration and reporting obligations that sit alongside it. They do share the underlying data on materials and weights.
That is one of these obligations, but for your home market. For textiles we have a separate page on reporting volumes and recycling rates. The structure is similar; the fees and deadlines differ.
Usually, yes, and it is the only workable route. Country, product and quantity are already there; what is missing is the material specification per product. We retrieve the first and build the second, so the submission becomes a calculation rather than a reconstruction.
That depends on the number of countries and streams, the size of your item catalogue and whether integrations are needed. The obligations register with deadline monitoring is usually quick to put to use and removes the biggest risk; the volume calculation takes more effort. We give you a reasoned estimate after the discovery phase.
Do you know in which countries you have a gap?
Take the countries you sold to last year and list your registration number per stream next to them. Every empty cell is a market where you may already no longer sell. We build this as a standalone application and as part of a broader custom software project.