Managing overlapping EPR deadlines across 3+ countries

Compliance with one country's EPR system is manageable. Compliance across five countries simultaneously — with different PROs, different registration systems, different data formats, different deadlines, and different fee structures — is where brands start making mistakes.

Here's how to build a system that doesn't rely on memory.

The problem with multi-country EPR

Each country has:

• Its own registration portal (LUCID, Citeo, Verpact, Fostplus, ARA, etc.)
• Its own data format requirements (some require polymer sub-categories, others don't)
• Its own annual reporting deadline (roughly Q1, but the exact dates vary)
• Its own invoice timing (Q1–Q2, often with advance payment schedules)
• Its own PRO contact and account manager

The interactions between these create complexity. For example:

• Germany requires data by March, but your Austrian report requires gram-level data that you haven't fully aggregated yet
• Belgium's January 2026 requirement for 7 plastic sub-categories means you need more granular data than you collected in your standard Shopify export
• Italy requires separate filings to multiple material consortia (COMIECO for paper, COREPLA for plastics)
• France requires an authorised representative for non-EU brands, which adds another relationship to manage

Without a system, something slips. A late filing in Germany doesn't result in an immediate fine, but it does put you on the ZSVR's radar.

Step 1: Build a master compliance register

Start with a spreadsheet that captures every obligation across every market. The columns:

| Country | PRO | Registration number | Annual filing deadline | Invoice expected | Advance payment due | Renewal needed? | Last filed | Next action |

|---------|-----|--------------------|-----------------------|-----------------|--------------------|--------------------|-----------|-------------|

| Germany | Landbell | DE1234... | 28 Feb | March | July (est.) | No | Jan 2025 | File by Feb 2026 |

| France | Citeo | FR5678... | 31 March | April | N/A | No | Feb 2025 | File by Mar 2026 |

| Netherlands | Verpact | NL9012... | 28 Feb | Q2 | N/A | No | Jan 2025 | Declaration by Feb 2026 |

| Belgium | Fostplus | BE3456... | 31 March | Q2 | N/A | No | Feb 2025 | File by Mar 2026 |

| Austria | ARA | AT7890... | 28 Feb | Q1 | N/A | No | Jan 2025 | File by Feb 2026 |

| Italy | COMIECO (paper) | IT1234... | 31 March | Q2 | N/A | No | Feb 2025 | File by Mar 2026 |

| Italy | COREPLA (plastic) | IT5678... | 31 March | Q2 | N/A | No | Feb 2025 | File by Mar 2026 |

This register is your source of truth. Update it after every filing and every invoice payment.

Step 2: Standardise your data collection before year-end

The biggest operational challenge in multi-country EPR is that Q1 reporting requires data from the previous calendar year — and most brands don't realise they need specific data until they're trying to file.

Run a December data preparation process:

By 15 December each year:

• Export full-year Shopify orders by shipping country (you can update January figures in early January)
• Pull packaging data sheet (your record of which component, which material, what weight)
• Calculate preliminary kg per material per country for all markets
• Identify any gaps: are you missing Austria's gram-level breakdown? Do you have Belgium's plastic sub-categories?
• Flag any packaging changes made during the year that affect material categories

This December exercise means January is about filing, not data collection.

Step 3: Account for Belgium's 2026 data requirement change

From August 2026 (affecting your 2026 data, filed in early 2027), Belgium's Fostplus requires packaging data broken down into 7+ plastic sub-categories, not just "plastics."

If your Shopify and warehouse processes currently record all plastics as a single category, you need to update your data model. Specifically, you need to know for every plastic packaging component:

• PET (polyethylene terephthalate) — bottles, clamshells
• HDPE (high-density polyethylene) — jugs, bottles, caps
• LDPE (low-density polyethylene) — bags, films, polybags
• PP (polypropylene) — tubs, caps, pouches
• PS (polystyrene) — rigid foam, clear rigid
• PVC (polyvinyl chloride) — some films, blisters
• Other/mixed plastics

Update your packaging data sheet to include polymer type for every plastic component. Your packaging supplier should be able to tell you the polymer type of anything they make.

Step 4: Manage your PRO relationships

You'll have relationships with:

• 1 German PRO (Landbell, Grüner Punkt, Zentek, or others)
• 1 Citeo contact (France) — possibly also Citeo Pro for B2B
• 1 Verpact contact (Netherlands)
• 1 Fostplus contact (Belgium)
• 1 ARA contact (Austria)
• 1–3 CONAI consortium contacts (Italy, by material)
• 1 Ecoembes contact (Spain)

Each relationship involves:

• An account login (keep a password manager)
• An account manager contact (keep their email/phone)
• Annual fee negotiations (larger producers) or set rates (smaller producers)
• Portal access for filing and invoice download

Best practice: Appoint one person in your organisation as EPR owner, or one external compliance service. Do not spread PRO management across multiple people — continuity matters when you're maintaining multi-year relationships and renewal history.

Step 5: Set calendar reminders, not just to-do lists

The filing calendar from an earlier article is the foundation, but reminders need to be automated. Manual to-do lists get buried.

Recommended reminders:

| Date | Reminder |

|------|----------|

| 1 December | Start year-end data collection |

| 15 December | Complete preliminary packaging volume calculation |

| 10 January | File Austria ARA annual report |

| 20 January | File Germany (Landbell/other PRO) data |

| 31 January | File Netherlands Verpact declaration |

| 28 February | Germany final filing deadline; Netherlands deadline |

| 15 March | File France Citeo, Belgium Fostplus |

| 31 March | Italy consortia, Spain SRAP filing deadline |

| 15 April | Review and pay all PRO invoices |

| 15 May | Germany VE (large producers only — >80,000 kg) |

| 1 October | Begin preliminary data review for advance payments (FR, BE) |

Set these as recurring annual calendar events with email notifications. Add a second notification 2 weeks before each deadline.

Step 6: Track invoice payments and credits

PRO invoices accumulate across Q1–Q2 every year. Keep a payment register that records:

• Invoice date and invoice number
• PRO and market
• Amount invoiced
• Payment due date
• Amount paid and date paid
• Any credits or adjustments applied

If your volumes were lower than estimated advances, you'll receive credits against the following year. Track these — they affect next year's cash flow.

The authorised representative complication

Non-EU brands (UK, US, Australian, etc.) selling into the EU often need authorised representatives — EU-based entities who formally take on EPR compliance responsibilities on the brand's behalf.

Germany and France formally require this for non-EU brands. Other markets may require it in practice if you can't register directly without a local entity.

Managing multiple authorised representatives means:

• Multiple contracts (one per representative, potentially one per market)
• Multiple fee arrangements (representatives charge for this service)
• Clear mandates defining what each representative is responsible for
• Annual renewal of mandate letters

Most compliance consultancies and EPR service providers offer authorised representative services. For brands in multiple markets, using a single provider who covers multiple markets reduces friction.

What good looks like: the mature multi-country EPR operation

When this is working well:

• You have a master compliance register current to within 30 days
• Your packaging data sheet is updated every time you change a supplier or spec
• Data collection starts in December, not January
• All filings are submitted 2 weeks before deadline (not on the deadline)
• Invoices are reviewed against your own calculations before payment
• One person owns it and can brief others if they're unavailable
• You have a single document showing all your registration numbers (for marketplace compliance)

When it's not working well:

• You're scrambling for packaging weights in January
• An invoice arrives that's 50% larger than expected and you don't know why
• A marketplace suspension in Germany reveals your LUCID number expired without you noticing
• You get an email from the ZSVR in February asking for updated data

The difference is a system built in Q4, not reactive firefighting in Q1.

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For the full compliance calendar breakdown, see Annual vs quarterly reporting: the EPR compliance calendar for EU brands.