As the European Union pushes ahead with packaging regulation and extended producer responsibility (EPR) obligations, businesses operating across borders continue to face a highly fragmented compliance environment that risks increasing costs and administrative burden.
A new analysis highlighted by Amazon argues that packaging registration processes across EU member states remain inconsistent despite growing regulatory alignment efforts, creating operational complexity for producers and online sellers seeking to serve multiple European markets.
Under current rules, companies are generally required to register for EPR obligations in every EU country where they place products on the market, while online marketplaces must verify that sellers have completed those registrations before allowing sales to proceed.
According to the analysis, registration requirements vary significantly across jurisdictions. Reviewing ten EU member states, Amazon identified 64 distinct registration fields, with an average of around sixteen data points requested per country. More than half of those requirements were country-specific, while only a limited subset aligned with the draft implementation framework linked to the EU’s Packaging and Packaging Waste Regulation (PPWR).
The company argues that producers are increasingly being asked to provide information at registration stage that may not yet exist operationally, including packaging volumes, material composition details, logistics information, waste classifications, storage practices and financial turnover metrics.
Registration Timelines And National Differences Add Pressure
The practical impact extends beyond paperwork.
Amazon notes that registration processes can require between two and six weeks depending on the country involved, with additional delays possible where businesses must first appoint authorised representatives before completing registration. In some jurisdictions, only producers themselves or formally appointed representatives are permitted to complete the process.
The burden is amplified for companies selling into multiple markets and product categories, particularly non-resident producers that may need separate authorised representation structures in each country and category.
Amazon also points to regulatory inconsistencies between EU frameworks. For example, rules governing authorised representatives differ between packaging and battery legislation, while member states continue to interpret implementation requirements individually. Additional national formalities can further increase complexity and cost.
Authentication Systems Remain Fragmented
Digital infrastructure remains another source of friction.
The analysis highlights that registration mechanisms differ widely between member states. National electronic identity systems are required in countries including Spain, Sweden, Poland and Italy, while others rely on email-based approaches. Belgium is cited as maintaining offline processes involving email exchanges, manual forms and signed documentation.
Several countries additionally require dual registration processes involving both government registries and Producer Responsibility Organisations, extending timelines and creating duplicate administrative steps. Language localisation of registration portals further complicates access for international operators.
Amazon argues that, taken together, these requirements create what it describes as a compliance maze for businesses attempting to trade across major European markets, particularly for smaller organisations without dedicated legal or compliance functions.
Push For Harmonized Data Infrastructure
Looking ahead, Amazon says implementation of the Packaging and Packaging Waste Regulation presents an opportunity to reduce administrative duplication.
The company is calling for harmonised registration and reporting formats supported by interoperable digital infrastructure and API-enabled national registers. In its view, standardised login systems, unified data fields and automated data exchange could simplify compliance workflows and improve reporting quality across producers, marketplaces and authorities.
Amazon further argues that online marketplaces already collect substantial producer identification data through existing Know Your Customer processes and could potentially support registration activities directly where legal frameworks allow. The company points to existing intermediary roles already operating in countries including France, Italy, Spain and Belgium for EPR reporting and eco-fee management as evidence that broader compliance support models may be scalable.
