What Is EPR?

EPR, or Extended Producer Responsibility, makes a producer pay for a product or its packaging after customers discard it. The producer may need to register, report how much material it sells, and fund waste collection. This short, practical guide focuses on packaging EPR because every shipped order uses packaging. The local law names the party with the duty.

How EPR obligations work

A program's producer test determines whether the brand owner, importer, direct seller, or packer must register. The term "producer" means the party with the legal duty. It may refer to a business that never made or touched the product.

Run this check for each order route:

1. Destination: List the customer's state or country.
2. Product packaging: Record the brand owner and importer of record.
3. Shipping packaging: Record the business that packs the parcel.
4. Program match: Compare those facts with the official producer definition and PRO register.

Keep proof for each answer. A brand license shows the owner, customs papers name the importer, and a packing invoice identifies the shipper. Use these records when applying the program's order.

A covered business usually joins a Producer Responsibility Organization (PRO). It reports packaging by material and weight, then pays the local fee. Each market may require its own registration number and fee.

Ask the supplier for the material and weight of each package type. Then total those amounts by destination for the report. Keep the supplier file with the sales records used for each filing.

Your supplier agreement should name each role. A payment clause may require one business to reimburse the other. The program's legal definition still determines the producer. Repeat this check beside your review of dropshipping legality for every market.

If the official definition leaves two roles in conflict, collect the supplier agreement, invoices, and shipping records. Give them to a local EPR adviser.

Where EPR is already active

Packaging EPR is collecting fees in Oregon, while Regulation (EU) 2025/40 now applies across the European Union. Oregon requires covered producers to join an approved PRO, report supply data, and pay membership fees. Fee collection began on July 1, 2025.

Oregon's small-producer exemption covers annual revenue below $5 million. It also covers sales below one metric ton in the prior calendar year. Apply these Oregon thresholds only to that program.

A covered producer that fails to register can face fines of $25,000 per day.

An appeal is pending, but Oregon can keep enforcing the law. Complete the current registration, reporting, and fee steps while that case continues.

The EU regulation has applied since August 12, 2026. A covered distance seller must appoint an EPR representative where it has no local base. The duty applies to direct consumer sales, with registration handled by each member state.

Before allowing sales, Article 45 requires online marketplaces to collect the seller's registration details and self-certification. Marketplaces must make a reasonable effort to judge whether that information is complete and reliable. A marketplace may register or report for a producer only with written authority.

For other states, record the local EPR rule apart from eco-friendly sourcing standards. Apply the thresholds of each destination separately.

EPR vs. de minimis threshold and HS codes

EPR pays for packaging waste after sale, while de minimis thresholds and HS codes govern customs treatment at the border. An HS code classifies the product for customs.

A de minimis threshold can affect how customs treats a low-value parcel. The destination's EPR rule determines who funds packaging waste.

EPR needs a separate producer check because it asks who supplied packaging. Customs looks at the product and its declared value.

A customs receipt proves that the parcel passed the border process. A PRO receipt proves that the named producer completed a separate EPR step. Keep both records with the order route they cover.

Suppose a supplier sends a packaged gadget straight to your customer. The parcel can use the right code and clear customs after all duty is paid. Your store may still need an EPR registration if the destination law treats it as the producer.

Before vetting a supplier, ask who owns the brand, imports the goods, and adds the shipping box. Track the customs code and EPR producer in separate fields. Record both results before the first shipment into every active sales market. The destination's producer definition determines who must register.

FAQ

Does EPR apply to a one-person dropshipping store?

EPR can apply to a one-person store when the program's producer definition covers it. Some programs exempt small producers, but the thresholds and conditions are specific to each jurisdiction.

Who pays when a supplier ships to the customer?

The destination program's producer hierarchy names the party that pays. The same hierarchy applies when a supplier fulfills the order.

What happens if a seller ignores EPR registration?

A noncompliant seller can face program enforcement, fines, or marketplace restrictions. The remedy depends on the jurisdiction, and Oregon may also seek to stop sales of covered products into the state.