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Requirement · EPR-03

Check the producer's registration and EPR self-certification against an official database or the public register, require correction where the information looks inaccurate, incomplete or out of date, and suspend the service until it is corrected, giving reasons.

Fulfilment service providers must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 45(8), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 12 August 2026 (Art. 71). as of 2026-08-18
  • It names one industry by name: Retail. as of 2026-08-18
  • Compliance is checked by fulfilment provider due diligence, per producer contract. as of 2026-08-18
Addressee Fulfilment service providersAct Regulation (EU) 2025/40, base actArticle Art. 45(8)Class Businesses

What changes

Logistics and fulfilment operators, made responsible for policing their customers' EPR compliance and required to cut off service where it fails.

The rule

New — no predecessor
Trigger

concluding a contract with a producer offering packaging to EU consumers

Obligation

Check the producer's registration and EPR self-certification against an official database or the public register, require correction where the information looks inaccurate, incomplete or out of date, and suspend the service until it is corrected, giving reasons.

Who is affected

Addressee
Fulfilment service providers
Class
Businesses
Sectors
Names Retail and distribution · Reaches Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products, Food, drink and tobacco, Waste and landfill
Applies
From 12 August 2026 (Art. 71)

Burden drivers

D1 · D3 · D5 — 3 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

the fulfilment service provider shall, through the use of any freely accessible official online database or online interface made available by a Member State or the Union or by means of the publicly available registration list under Article 44(13) of this Regulation or requests to the producer to provide supporting documents from reliable sources, make best efforts to assess whether the information referred to in paragraph 7 of this Article is reliable and complete. For the purposes of this Regulation, producers shall be responsible for the accuracy of the information provided. Where the fulfilment service provider obtains sufficient indications or has reason to believe that any item of information referred to in paragraph 7 obtained from the producer concerned is inaccurate, incomplete or not up-to-date, that fulfilment service provider shall request that the producer remedies that situation without delay or within the period set by Union or national law, as applicable. Where the producer fails to correct or complete that information, the fulfilment service provider shall swiftly suspend the provision of its service to that producer in relation to the offering of packaging or packaged products to consumers located in the Union until the request has been fully complied with. The fulfilment service provider shall provide the producer with the reasons for the suspension.

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