Shipping across a border can create obligations
For many online sellers the first contact with EPR comes from a marketplace request for a registration number, or from a customer asking how packaging obligations are covered. By then, products are usually already on the market.
Cross-border distance selling commonly makes the seller the obliged producer in the destination country, for the product itself and for the packaging used to ship it.
The streams that usually apply first
- Packaging: the boxes, filling material and tape used to fulfil orders, plus the packaging around the product
- EEE/WEEE: any electrical or electronic equipment sold
- Batteries: sold separately, supplied with a product or built into it
- Non-packaging products: Slovakia only, where the product group is covered
A workable sequence
- Establish in which countries you are the obliged producer
- Determine which streams apply to your catalogue in each country
- Check whether an authorised representative is required
- Register and arrange scheme participation before further shipping where required
- Set up records now, because reporting will require historical quantities
Selling through a marketplace does not remove the duty
Marketplaces have their own obligations, including verification duties towards sellers. That does not generally transfer the seller's own producer obligations to the platform.
The precise interaction differs between Slovakia and the Czech Republic and should be confirmed per market rather than assumed.