Extended Producer Responsibility (EPR) shifts the end-of-life cost for products from municipalities to the companies that introduce them to the market. For the publishing industry, this includes not just books and magazines but all associated packaging, from shipping cartons to plastic wrap. The EU’s Packaging and Packaging Waste Directive 94/62/EC established this framework, making compliance a legal requirement for market access.

The rules apply to every company placing packaged goods on the market, impacting thousands of publishers, importers, and online retailers selling cross-border into the EU. Ignoring these duties is not an option, as enforcement is tightening across all 27 member states. The complexity of varied national laws requires a clear strategy, and for a complete analysis of your EPR obligations, immediate attention is necessary.

These foundational rules are now evolving, demanding even greater diligence from every publisher.

The upcoming Packaging and Packaging Waste Regulation (PPWR) replaces the original 1994 directive, creating more harmonized and stricter rules across the EU. It introduces binding targets for all member states, including a 5% reduction in packaging waste per capita by 2030 compared to 2018 levels. For publishers, this signals a clear need to minimize packaging materials from the outset.

The PPWR sets ambitious recycling targets that directly affect paper products and their packaging. By the end of 2025, member states must achieve a 75% recycling rate for paper and cardboard. This figure rises to 85% by the end of 2030, putting pressure on producers to use materials that are easily recyclable.

Here are key requirements under the new PPWR:

• All packaging must be designed for recyclability, meeting performance grades of at least 70% by 2030 to be allowed on the market.
• Minimum recycled content targets for plastic packaging will be enforced, impacting any poly bags or shrink wrap used.
• Standardized labeling, including QR codes, will become mandatory to help consumers with sorting.
• Unnecessary packaging will be restricted, forcing a re-evaluation of shipping practices.

Many businesses are unaware that these regulations will apply just 18 months after the law officially enters into force in late 2024. Understanding how to ensure your supply chain is compliant is a critical step that must be taken now.

Beyond the EU-wide framework, individual countries have already implemented robust enforcement mechanisms.

Germany’s Packaging Act (Verpackungsgesetz or VerpackG) is one of Europe’s most stringent EPR implementations. It applies to anyone selling to German end consumers, including publishers shipping directly from abroad. The law mandates a 3-step compliance process: registration, system participation, and data reporting.

First, you must register with the ‘Zentrale Stelle’ Packaging Register (ZSVR) in the public LUCID database—a process that must be completed before a single item is shipped. Failure to register can trigger fines of up to €100,000 per case. After registration, you must license your packaging volumes with a dual system provider, which organizes the nationwide collection and recycling of your materials.

The financial consequences of non-participation in a dual system are even more severe, with potential fines reaching €200,000. Marketplaces like Amazon and eBay actively verify LUCID registration numbers and will block listings from non-compliant sellers. To register your shipping materials correctly is a non-negotiable prerequisite for accessing Germany’s 83-million-person market.

Germany is not the only country with such demanding rules; France presents its own set of challenges.

France has one of the most comprehensive EPR frameworks in Europe, covering not only packaging but also printed graphic papers. This includes nearly all paper products under 224 g/m², such as catalogues, flyers, and manuals. Since January 1, 2023, the EPR schemes for household packaging and graphic papers have been merged into a single system to improve efficiency.

Compliance in France requires several actions:

1. You must register with an approved Producer Responsibility Organisation (PRO), such as CITEO, for both packaging and paper.
2. You receive a Unique Identification Number (UIN) which must be displayed on your website and contractual documents.
3. All household products and packaging must bear the Triman logo and sorting instructions (Info-tri).
4. You must report the tonnage of materials you place on the French market and pay the corresponding eco-contributions.

There is no minimum volume threshold for paper; the obligation starts from the very first item placed on the market. Companies that have not yet taken action must contact a service provider like Deutsche Recycling immediately to manage these complex, country-specific obligations and avoid penalties.

The consequences of inaction across these jurisdictions are severe and multifaceted.

The risks associated with ignoring EPR duties extend far beyond financial penalties. For the publishing industry, non-compliance can lead to a complete halt of distribution in key European markets. As seen in Germany, failure to meet VerpackG requirements can result in an immediate distribution ban.

Beyond the legal and financial threats, there is significant reputational risk. With sustainability being a growing concern for consumers, being identified as a non-compliant company can damage your brand’s image. All EPR registrations in Germany, for example, are publicly listed in the LUCID database, creating full transparency.

The administrative burden of managing registrations, data reporting, and fee payments across multiple countries is a drain on resources that detracts from your core business. A single error in reporting can trigger audits and penalties. The only way to achieve 100% legal conformity and peace of mind is to partner with a specialist. If you need to comply with the German Packaging Act or other EU laws, the time to act is now.

A dedicated compliance partner can transform this complex burden into a streamlined process.

Managing EPR compliance across Europe requires constant monitoring and expert knowledge. Deutsche Recycling offers a full-service solution designed to handle every aspect of your obligations. We take on the administrative load, ensuring you meet every legal requirement in every country you sell to, guaranteeing 100% compliance.

Our process is designed for efficiency and clarity. We start by analyzing your specific obligations based on the materials you use and the countries you ship to. We then manage all necessary registrations with national authorities and PROs, secure your EPR numbers, and handle all ongoing data reporting and fee submissions on your behalf. This frees up your team to focus on publishing and sales, not regulatory paperwork.

By centralizing your compliance, you eliminate the risk of costly errors and ensure uninterrupted access to the entire EU market. Do not wait for a warning letter or a sales ban to disrupt your business. Contact Deutsche Recycling today for an individual consultation and let our experts manage your EPR compliance swiftly and professionally. This is the fastest way to secure your legal standing and continue your business without interruption.