Free PPWR-EPR tool

Are you the EPR Producer for this sale?

Q: If my Turkish company sells directly to a German end user, who is the EPR Producer?

For that direct packaged-product sale into Germany, the Turkish selling company is the EPR Producer under the cross-border end-user route.

Q: If my Turkish company sells to a German importer or reseller, who is the Producer?

When the German buyer purchases the product and makes it further available in Germany, that destination-country operator is the company to assess as the German EPR Producer for the transaction.

Q: Does Amazon FBA, a warehouse or a carrier change the result?

Not when the intermediary only provides logistics or fulfilment and does not buy and resell the product in its own name. The commercial sales chain remains decisive.

Q: Does an EU VAT number or branch make a non-EU company EU-established?

No. A VAT registration or a branch without separate legal personality does not by itself create a separately incorporated EU legal entity for this analysis.

Q: Is the EPR Producer the same role as the PPWR manufacturer?

No. PPWR technical manufacturer duties and packaging-EPR Producer responsibility are separate legal roles and must be assessed separately.

Choose the EU country where the packaging becomes waste, identify the selling legal entity and describe the buyer and commercial supply chain. The checker returns YES, NO or UNDETERMINED for that sale and destination.

FreeNo account requiredEU27Transaction-basedRegulatory logic reviewed 31 August 2026

Check one sales chain

Run the checker separately for each destination Member State and each materially different sales chain.

Which EU country is this sale going to?

Select the Member State where the packaging from this sale is used and becomes waste.

Where is the selling legal entity established?

Use the company that invoices the buyer or is the seller under the sales contract.

What will the destination-country buyer do with the product?

A business buyer is still an end user when it does not make the product further available in the form supplied.

Is your company the direct commercial supplier to that buyer?

A warehouse, carrier, customs broker or fulfilment provider is not a reseller when it does not buy and resell the goods in its own name.

This decision tree covers sales and grouped packaging of packaged products. Transport packaging, service packaging, primary-production packaging and the unpacking route require a separate PPWR Producer assessment.

Decision logic

The checker follows the transaction in the destination Member State.

The same product can pass through several companies. The Producer result follows the company that first makes the packaged product available under the relevant destination-country transaction route.

Brand ownership and technical PPWR manufacturer status are not used as substitutes for this packaging-EPR Producer test.

Seller established in the destination country

Article 3(1)(15)(b)

The company is the Producer when it first makes the packaged product available from within and on the territory of that Member State.

Direct cross-border sale to an end user

Article 3(1)(15)(d)

A company established in another Member State or a third country is the Producer when it first supplies the packaged product directly to an end user in the destination Member State.

Sale to a destination-country reseller

Commission Guidance 2026

When the destination buyer buys and resells the packaged product, that destination-country operator is the company to assess for first making available there.

Professional buyer as end user

Article 3(1)(23)

A legal person is an end user when it uses the product in its professional activity and does not make it further available in the form supplied.

Branch or VAT registration

Commission Guidance 2026

A branch without separate legal personality or a VAT registration is not treated as a separately incorporated EU legal entity for this establishment test.

Next step

After Producer status, open the country obligations.

Registration, EPR system or PRO, EPR Authorised Representative, fees, reporting and evidence are verified separately for the selected Member State.

STEP 02

EU Country Obligation Checker

Open registration, EPR-system, representation, reporting and evidence work for the selected Member State.

Check country →STEP 03

Packaging Weight Calculator

Convert packaging components and sales quantities into material-specific kilograms.

Calculate packaging →STEP 04

EPR Cost Estimator

Use verified country fee datasets and packaging quantities to structure regulatory cost.

Estimate cost →

Frequently asked questions

The transaction facts that change the Producer result

If my Turkish company sells directly to a German end user, who is the EPR Producer?

If my Turkish company sells to a German importer or reseller, who is the Producer?

Does Amazon FBA, a warehouse or a carrier change the result?

Does an EU VAT number or branch make a non-EU company EU-established?

Is the EPR Producer the same role as the PPWR manufacturer?

This checker applies the packaged-product sales routes in Regulation (EU) 2025/40 Article 3(1)(15)(b) and (d), the end-user definition in Article 3(1)(23), and European Commission guidance C/2026/3084 dated 10 June 2026. It does not decide national registration, PRO or EPR-system, EPR Authorised Representative, fee, filing, payment or deadline requirements. Regulatory logic last reviewed: 31 August 2026. Regulation (EU) 2025/40 · Commission Guidance C/2026/3084