Packaging EPR in Spain, the Netherlands and Austria for Online Sellers

Most guides to packaging EPR stop at Germany and France. If your Shopify store also ships to Spain, the Netherlands or Austria, each runs its own register, schemes and rules for sellers based abroad. This guide covers those three, using only what their ministries and national bodies publish. It assumes you already know the basics from our PPWR guide for Shopify sellers. If you also ship to Germany or France, see LUCID registration step by step and Citeo and Triman for online sellers.

This is general information, not legal advice. Check your own situation with the national authority or a qualified adviser.

The common starting point

Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) applies. Its producer definition covers a seller established in another Member State or outside the EU who makes packaged products available for the first time in a Member State “directly to end users”, whatever the selling technique. A Shopify checkout is a distance sale, so a parcel to a Spanish, Dutch or Austrian consumer usually makes you the producer of that packaging there.

There is no single EU register, so you deal with each country’s system. Here is how the three compare.

	Spain	Netherlands	Austria
Where producers register	Packaging section of the Registro de Productores de Producto (MITECO)	Verpact, the Dutch producer organisation	Collection and recovery system (licensing); representatives via EDM
Scheme membership	An authorised SCRAP (collective EPR system)	Verpact	A licensed Sammel- und Verwertungssystem
Seller abroad shipping to consumers	Must appoint an authorised representative in Spain	EU sellers: no local representative; non-EU: other rules apply	Foreign distance sellers must appoint a Bevollmächtigter
Volume threshold for registering	None stated for registration	Register only above 50,000 kg a year (not for deposit or single-use plastic packaging)	None stated
Annual report	Before 31 March for the previous year	Declaration to Verpact	Representative reports quantities

The rest of this post explains each row and links to the source.

Spain

Who is obligated

Spain’s Ministry for the Ecological Transition (MITECO) published an interpretative note on the producer definition under the PPWR, version 2, dated 13 August 2026. It says that where Royal Decree 1055/2022 refers to a “productor de producto”, this should be read as the producer defined in the PPWR.

For a seller established in another Member State or outside the EU who sells packaged products directly to end users in Spain, the note is clear: that seller is the producer, and must appoint an authorised representative in Spain to meet the producer’s obligations. The representative registers the producer and reports on its behalf.

If you already have a Spanish subsidiary, you do not need a separate representative. A branch without its own legal personality is not enough.

Registration

Registration happens in the packaging section of the Registro de Productores de Producto, through MITECO’s electronic office. For a company based outside Spain, the note lists these steps:

1. Get a Spanish tax ID (NIF). For a foreign legal entity it starts with the letter N and is requested from the Spanish tax agency through a representative with a Spanish NIF or NIE.
2. Get a digital certificate for that NIF, naming a representative with a Spanish NIF or NIE. That person acts as your authorised representative for EPR and for the register.
3. Register in the packaging section. The representation can also be set up through the government’s electronic power of attorney register (REA).

When you register, you attach a certificate from the SCRAP you belong to. Article 15 of Royal Decree 1055/2022 requires that certificate, and gives you a registration number. MITECO publishes registered producers, and the note tells marketplaces to check your NIF, company name and registration number against that public information.

Joining a SCRAP

If you meet your EPR obligations collectively, the note says you must join one of the SCRAPs authorised in Spain for packaging. You can also let your SCRAP register and report for you, by granting it power of attorney through the REA.

Reporting

After registering, you report each year the packaging you placed on the Spanish market. Article 16 of Royal Decree 1055/2022 sets the deadline: before 31 March of the year after the one you report. There are two procedures, a full one and a simplified one. The note explains that the simplified declaration currently applies below 15 tonnes, as set by the Royal Decree, until the EU implementing act on reporting is adopted. Article 17 also asks producers to give their collective scheme the data it needs before 28 February.

The Netherlands

Who is obligated

In the Netherlands, producer responsibility for packaging is run by Verpact, the producer organisation formerly called Afvalfonds Verpakkingen. Its page for sellers new to packaging EPR says that as soon as you supply packaged products to Dutch consumers, “even if you are based abroad”, you are in principle required to register with a producer organisation such as Verpact. If you sell through a platform such as Amazon and the packaging comes from you, you are the producer, not the platform.

The 50,000 kg threshold

Verpact’s news item on the situation since the PPWR (17 August 2026) says you only need to register with Verpact if you place more than 50,000 kg of packaging on the Dutch market per calendar year. The government’s business.gov.nl packaging page uses the same 50,000 kg figure for paying the packaging waste management contribution.

The exemption has limits. Verpact says it “does not apply to deposit packaging and single-use plastics (SUP)”: for those you must always register, whatever the quantity.

Count everything used to supply products to Dutch end users in a year: Verpact lists boxes, film, filling material, labels and shipping packaging.

Authorised representative

According to Verpact, companies based in the EU do not need to appoint a local representative in the Netherlands and can register directly. For companies outside the EU, Verpact says “additional rules apply” and asks you to contact it.

Verpact also notes that the PPWR’s requirement to appoint an authorised representative in each country “may yet be scrapped”, with a decision expected by the end of 2026. EU-based companies that are not required to register do not need a representative for EPR purposes either.

Registration and declaration

You register with Verpact and file declarations in its portal, PackTool, which is being replaced by VerpactPortal. A registration is tied to your legal form, so changing legal form means a new registration. Verpact also asks producers to check that their 2026 declaration still reflects their situation, because the PPWR shifts some reporting obligations.

Austria

Who is obligated

The Austrian government’s business service portal (USP) states the core rule on its page about packaging obligations for companies: companies that place household or commercial packaging on the market must participate in an approved collection and recovery system. This is called licensing, and the fees depend on the type and weight of packaging. Participants must confirm it to their customers in a binding statement, for example on the delivery note or invoice.

Foreign distance sellers must appoint a representative

Austria is stricter than the Netherlands for sellers abroad. The USP page on authorised representatives for packaging says that since the start of 2023, foreign distance sellers are obliged to appoint a Bevollmächtigter (authorised representative). This covers sellers without a seat or branch in Austria who deliver packaging, or goods in packaging, to private end consumers in Austria through distance selling.

The representative must:

• be a natural or legal person with a seat in Austria and an Austrian address for service
• take responsibility for complying with Austrian administrative rules
• be appointed through a certified power of attorney in German or English that states the scope, the representative’s consent and their right to sign contracts on your behalf

The representative takes over your obligations under the Waste Management Act and the Packaging Ordinance, and must report the quantities of packaging you place on the market.

Registration through EDM

The USP page describes the procedure:

1. The representative registers on edm.gv.at, the federal environmental data system.
2. They submit the power of attorney to the ministry (BMLUK) through EDM.
3. If the check is positive, the ministry marks them as an authorised representative in the register of plant and person master data.
4. The Environment Agency registers you, the foreign seller, and gives the representative access to your data.

Since 1 January 2023, Austria’s rules for online marketplaces and fulfilment providers also make marketplaces exclude sellers who don’t comply. On your own Shopify store nobody runs that check for you.

The USP pages on packaging obligations and representatives were last updated on 1 January 2026, before the PPWR applied. Check with the BMLUK whether anything has changed for your case.

What about Italy?

We left Italy out of this guide on purpose. CONAI’s page on who must join currently says foreign companies “are not obliged to join CONAI, but they may do so voluntarily”, and that sellers using e-commerce platforms may use simplified procedures agreed between platforms and EPR systems. The official sources we could check do not yet set out how PPWR registration and authorised representation work for a foreign online shop selling directly to Italian consumers, so we will not guess.

A checklist for these three countries

1. Count parcels and weigh their packaging by country. Use a full year of shipped orders, including the shipping box or mailer, filler and tape.
2. Spain: get a Spanish NIF and digital certificate, appoint a representative, join a SCRAP, register in MITECO’s packaging section, and report before 31 March.
3. Netherlands: check whether you exceed 50,000 kg a year, or use deposit or single-use plastic packaging. If either applies, register with Verpact. Outside the EU, ask Verpact which rules apply to you.
4. Austria: appoint a Bevollmächtigter, license your packaging with a collection and recovery system, and let the representative report the quantities.
5. Keep the evidence. Save the order counts and packaging weights behind each figure you report.

Common pitfalls

• Assuming your German or French registration covers other countries. Registration is per country; there is no single EU number.
• Forgetting the shipping box. Spain’s note covers transport packaging delivered directly to end users, and Verpact lists shipping packaging and filling material in the weight you count.
• Reading the Dutch threshold as a full exemption. It does not cover deposit or single-use plastic packaging.
• Treating Austria’s representative as optional. It is optional for some foreign businesses, but not for distance sellers delivering to private consumers.

FAQ

Do I need an authorised representative in Spain if I sell from another EU country?

Yes, if you sell packaged products directly to end users in Spain and have no Spanish subsidiary. MITECO’s note says such a seller must appoint an authorised representative in Spain, who registers you and reports for you.

I ship a few hundred parcels a year to the Netherlands. Do I have to register with Verpact?

Verpact says you only need to register if you place more than 50,000 kg of packaging on the Dutch market a year. Deposit packaging and single-use plastics are the exception: for those you register whatever the quantity. Sellers outside the EU should ask Verpact which additional rules apply.

Can I sell to Austrian consumers without an Austrian representative?

Not if you are a distance seller without a seat or branch in Austria. The Austrian government’s business portal says foreign distance sellers delivering to private end consumers are obliged to appoint a Bevollmächtigter.

Getting the weights per country

Every one of these countries asks for packaging weights by destination, and those numbers come from your orders. StoreFleet: Packaging EPR is a free Shopify app, currently in review for the Shopify App Store, that turns shipped orders into kilograms of packaging by destination country and by the PPWR material categories. It has dedicated exports for Germany (LUCID) and France (Citeo) only. It does not produce Spanish, Dutch or Austrian filing formats, and you still register and declare yourself. See also packaging weight per material from Shopify orders.