Extended producer responsibility for packaging (PACK)
Extended producer responsibility (EPR) applies in many countries when shipping packaged watches. What does this mean for sales on Chrono24? In this article, you will find out which requirements you have to fulfil depending on the destination country – from registration and licensing to labels and certificates.
No action is necessary at present. If documents are required, we will contact you and guide you through the process. The EPR articles provide a concise overview of extended producer responsibility legislation, so you are well informed in advance.
Please note: We cannot offer legal advice. The information provided here is for general guidance only.For specific advice on how to apply the packaging laws in your individual case, we recommend that you contact qualified legal counsel. Chrono24 is entitled to request evidence of compliance with your EPR obligations at any time. As a dealer, you must ensure that you have all the necessary registrations and evidence so that your listings remain active.
“The term extended producer responsibility” (EPR) refers to international regulations that oblige producers and retailers to ensure the environmentally-friendly design, use, and disposal of their products throughout the entire product life cycle. EPR covers various product categories that are regulated differently depending on the country; for example, packaging (PACK), batteries (BATT), and electrical and electronic equipment (EEE). If you sell products in EU countries and place packaging – including shipping packaging – on the market, you may be obliged to register and ensure that your packaging is collected and recycled via an approved system (packaging licensing). In some EU countries, we as a marketplace are legally obliged to ensure that our dealers comply with the respective EPR requirements for packaging (PACK). In this article, you will find information on the registration and licensing of packaging as part of extended producer responsibility (EPR) as well as country-specific information for the EU countries in which we currently have to monitor compliance with EPR requirements.
Who is affected?
As packaging is always used when shipping goods, the regulations on extended producer responsibility for packaging affect all dealers on Chrono24 who offer their products in EU countries.
Which packaging is affected?
The requirements apply to all packaging arising from sales or shipping, including:
- Shipping packaging (e.g., cardboard boxes, padded envelopes, filling material)
- Outer packaging or inserts that are delivered together with the product
- Product packaging where applicable (e.g., cases, boxes, protective packaging for watches)
It does not matter whether the packaging is new or reused – any packaging that is put into circulation is subject to this obligation.
What does this mean for me as a dealer on Chrono24?
Below you will find an overview of the central EPR obligations for packaging (PACK) in connection with the sale of products on Chrono24.
The requirements that apply to you depend, among other things, on the country in which you put packaging into circulation and where your company is based.
If your company is based in the EU destination country:
- Obligation to register: You must register with the relevant national packaging register (e.g., LUCID in Germany, ADEME/SYDEREP in France, VKS in Austria, RPP in Spain).
- Licensing / system participation: You must conclude a contract with an approved dual system or eco-organization (e.g., Der Grüne Punkt, Lizenzero, Citeo, Interzero, Ecoembes).
- Quantity reporting: You must regularly report the quantities of packaging placed on the market to the packaging register and the dual system.
If your company is not based in the EU destination country:
- Authorization: In EU countries in which you have neither a registered office nor a branch, you may have to appoint an authorized representative to assume your obligations under extended producer responsibility for packaging (PACK) in the country; for example, registration, licensing, and official communication.
- An authorized representative may be a natural or legal person resident in that country or a corresponding service provider approved by the national authority.
- The appointment of an authorized representative is currently still voluntary in some EU countries, but is expected to become mandatory throughout Europe from August 2026.
Information that Chrono24 requires from you: For some EU countries – currently Germany, France, and in specific cases Spain – we require evidence of your EPR registration and licensing.
- EPR number (e.g., LUCID, UIN, or RPP)
- Additionally for certain countries: Annual proof of packaging licensing (e.g., Participation certificate)
- If applicable (depending on the location of your company), name of your authorized representative and proof of authorization
Note: For other countries, for example Austria, these certificates only need to be sent to us upon request.
Country-specific information
Sale of items in or to Germany, thus bringing packaging into circulation in Germany
If your company is based in Germany and considered a producer:
Requirements:
- Register in the LUCID Packaging Register, which is operated by the Central Agency Packaging Register (ZSVR).
- Sign up with a dual system of your choice (e.g., Der Grüne Punkt, Lizenzero) to license your packaging.
- With this contract, you contribute to the costs of collecting, sorting, and recycling your sales packaging.
- You acquire a license for the quantities that you expect to place on the market in the current calendar year.
- Regularly report your packaging quantities placed on the market in Germany both to the LUCID Register and your dual system.
Information that Chrono24 requires from you:
- EPR number (LUCID)
- Annual proof of packaging licensing (e.g., "Participation certificate" from Lizenzero)
Tip: Take advantage of the Chrono24 partner offer and secure a discount on packaging licensing from Lizenzero.
If your company is based outside of Germany:
Note: Appointment of an authorized representative under the German Packaging Act (VerpackG) is currently still voluntary. As a foreign company without a registered office or branch in Germany, you can currently fulfil your obligations independently or voluntarily appoint an authorized representative based in Germany to take on these obligations for you. From August 2026, the appointment of an authorized representative will be mandatory for foreign companies under the Packaging and Packaging Waste Regulation (PPWR). Requirements without an authorized representative: Register in the
- LUCID Packaging Register, which is operated by the Central Agency Packaging Register (ZSVR).
- Sign up with a dual system of your choice (e.g., Der Grüne Punkt, Lizenzero) to license your packaging.
- With this contract, you contribute to the costs of collecting, sorting, and recycling your sales packaging.
- You acquire a license for the quantities that you expect to place on the market in the current calendar year.
- Regularly report your packaging quantities placed on the market in Germany both to the LUCID Register and your dual system.
Information that Chrono24 requires from you:
- EPR number (LUCID)
- Annual proof of packaging licensing (e.g., "Participation certificate" from Lizenzero)
Tip: Take advantage of the Chrono24 partner offer and secure a discount on packaging licensing from Lizenzero.
Requirements with an authorized representative:
- Register in the LUCID Packaging Register, which is operated by the Central Agency Packaging Register (ZSVR).
- Appoint an authorized representative based in Germany who will assume the legal obligations arising from the German Packaging Act (VerpackG) for you in Germany.
- Your authorized representative concludes the packaging licensing with a dual system on your behalf and carries out the quantity reports.
Information that Chrono24 requires from you:
- Name of the authorized representative
- Evidence of authorization (e.g., contract)
- Annual proof of packaging licensing (e.g., "Participation certificate" from Lizenzero)
- EPR number (LUCID)
Sale of items in or to France, thus bringing packaging into circulation in France
If your company is based in France:
Requirements:
- Register with an approved eco-organization for packaging (e.g., Citeo, Léko) and get a packaging license.
- The eco-organization registers your company in the French ADEME/SYDEREP register.
- After successful registration, you will receive your EPR number (UIN – Unique Identification Number) from the eco-organization. This is awarded separately for each product category (e.g., electrical equipment, packaging, batteries).
Information that Chrono24 requires from you:
- EPR number (UIN for the "Packaging" category)
Note: We regularly check the validity of your EPR number in the SYDEREP system.
If your company is based outside of France:
Note: The appointment of an authorized representative for packaging within the scope of extended producer responsibility (EPR) is currently voluntary. As a foreign company without a registered office or branch in France, you can currently fulfill your obligations independently or voluntarily appoint an authorized representative based in France to assume these obligations for you.
From August 2026, the appointment of an authorized representative under the Packaging and Packaging Waste Regulation (PPWR) will be mandatoryfor foreign companies. Requirements without an authorized representative:
- Register with an approved eco-organization for packaging (e.g., Citeo, Léko) and get a packaging license.
- The eco-organization registers your company in the French ADEME/SYDEREP register.
- After successful registration, you will receive your EPR number (UIN – Unique Identification Number) from the eco-organization. This is awarded separately for each waste category (e.g., electrical equipment, packaging, batteries).
Information that Chrono24 requires from you:
- EPR number (UIN for the "Packaging" category)
Requirements with an authorized representative:
- Appoint an authorized representative based in France to assume the legal obligations under the EPR legislation for packaging (PACK) for you in France.
- Your authorized representative arranges packaging licensing on your behalf with an approved eco-organization (e.g., Citeo, Léko) and provides you with your EPR number (UIN – Unique Identification Number for the category "packaging") from the ADEME/SYDEREP register.
Information that Chrono24 requires from you:
- Name of the authorized representative
- Evidence of authorization (e.g., confirmation)
- EPR number (UIN for the "Packaging" category)
Note: We regularly check the validity of your EPR number in the SYDEREP system in both cases (with and without an authorized representative).
Sale of items in or to Austria, thus bringing packaging into circulation in Austria
If your company is based in Austria:
Requirements:
- If you sell items in or to Austria and thus place packaging on the market, you are considered a primary obligated party and must license this packaging.
- Take out a packaging license with an approved collection and recycling system (e.g., Interzero, ERP Austria, ARA, Reclay Systems). A list of approved recycling systems can be found here.
- The collection and recycling system enters your company in the register of the Austrian Packaging Coordination Office (VKS).
- After successful registration, you will receive your EPR number (6-digit VKS number) from the collection and recycling system.
Information that Chrono24 requires from you: No direct information required.
Note: You are contractually obliged to provide your EPR number to Chrono24 upon request.
If your company is based outside of Austria:
Requirements:
- As a foreign company without a registered office or branch in Austria, you must appoint an authorized representative based in Austria to assume the legal obligations arising from the Austrian Packaging Ordinance on your behalf.
- Your authorized representative arranges packaging licensing on your behalf with an approved collection and recycling system (e.g., Interzero, ERP Austria) and provides you with an EPR number (6-digit number from the Austrian Packaging Coordination Office – VKS).
- More information on the authorized representative can be found here.
Information that Chrono24 requires from you: No direct information required.
Note: You are contractually obliged to provide Chrono24 with your EPR number, the name of your authorized representative, and evidence of authorization upon request.
Sale of items in or to Spain, thus bringing packaging into circulation in Spain
If your company is based in Spain:
Requirements:
- Sign up with an approved take-back system for packaging (e.g., Ecoembes or Procircular).
- Register with the Registro de Productores de Productos (RPP).
- After successful registration, you will receive your EPR number.
Information that Chrono24 requires from you: No direct information required.
Note: You are contractually obliged to provide your EPR number to Chrono24 upon request.
If your company is based outside of Spain:
Requirements:
- In order to fulfill your EPR obligations in Spain, you need a Spanish NIF (Número de Identificación Fiscal). If you do not have one, you can apply for one from Gestoraz.
- As a foreign company without a registered office or branch in Spain, you must appoint an authorized representative based in Spain to assume the legal obligations arising from Spanish waste legislation on your behalf. You can request this service via AuthoriseMe, for example.
- Your authorized representative completes registration in the producer register (RPP) and licensing via an approved take-back system (e.g., Ecoembes, Procircular). Once you have successfully registered, you will receive your EPR number.
Information that Chrono24 requires from you:
- Name of the authorized representative
- Evidence of authorization (e.g., confirmation)
- EPR number
Frequently asked questions (FAQ)
A dual system is a company approved by the authorities that organizes the collection, sorting, and recycling of packaging. Retailers and producers conclude a contract with a dual system to license their packaging. In this way, they contribute financially to the environmentally-friendly disposal and recycling of the packaging they put into circulation. Well-known dual systems include Der Grüne Punkt (DE), Citeo (FR), Ecoembes (ES), and Lizenzero (DE).
Yes, separate registration and system participation is required for each country to which you sell items if you are considered a producer there.
Foreign retailers without a registered office or branch in the respective target country must generally appoint an authorized representative based in this country to fulfil their obligations under extended producer responsibility (EPR). This authorized representative – a natural or legal person based there – acts on behalf of the retailer and takes on tasks such as:
- Registration in the national packaging register
- Submission of legally required quantity reports
- Communication with the relevant authorities
This ensures that even retailers without a local registered office properly fulfill their EPR obligations and comply with the legal requirements in the respective country.
As a dealer on Chrono24, you must ensure that you fulfill all legal obligations regarding extended producer responsibility (EPR). If you do not comply with these requirements, your listings will be considered non-compliant.
In this case, Chrono24 may have to block or remove listings for the target markets in which you do not meet the requirements in order to comply with the law.
Depending on the country, fines or sales bans may also be imposed.
More information on EPR
- Extended producer responsibility for the sale of items with batteries (BATT) – Country-specific information
- Extended producer responsibility for the sale of electrical and electronic equipment (EEE) – Country-specific information
- General information on extended producer responsibility (EPR) on Chrono24
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