EPR explained: what small fashion brands selling in Europe need to know

If you run a small fashion brand in Europe, you may have recently come across three letters that weren't part of your vocabulary when you started designing clothes: EPR.

Extended Producer Responsibility, or EPR, sounds like the kind of regulation only large companies should have to worry about. In reality, it can apply to businesses of almost any size—and if you sell products online across European borders, things can get complicated surprisingly quickly.

A dress might be made from organic cotton, produced locally and shipped in recycled cardboard. But the moment that parcel reaches a customer, the box, label, tape and protective packaging eventually become waste.

EPR is essentially about answering one question:

Who should pay for dealing with that waste?

Increasingly, Europe's answer is: the company that puts the packaging on the market.

what is EPR?

EPR stands for Extended Producer Responsibility.

The principle is relatively simple. Instead of making municipalities and taxpayers responsible for the entire cost of collecting, sorting and recycling packaging, producers contribute towards managing the waste generated by the products and packaging they place on the market.

For fashion brands, EPR can apply to several different waste streams depending on the country, including packaging, textiles, footwear, batteries and electronics.

For most small fashion and accessories brands selling online, packaging EPR is the most immediate concern.

Think about everything surrounding an online order:

• cardboard shipping boxes

• paper envelopes

• plastic or compostable mailers

• tissue paper

• protective packaging

• product boxes

• bags and other packaging supplied with the product

Under the EU's new Packaging and Packaging Waste Regulation (PPWR), the rules cover packaging regardless of the material from which it is made.

So using recycled cardboard rather than plastic is a positive environmental choice—but it doesn't automatically remove your EPR responsibilities.

why does EPR exist?

Packaging is a much bigger environmental problem than it might appear when you're looking at a single cardboard box.

According to EU data cited in the new PPWR, around 40% of plastics and 50% of paper used in the EU are used for packaging, while packaging accounts for approximately 36% of municipal solid waste.

EPR follows what is known as the polluter pays principle.

If businesses contribute towards the cost of managing the waste they create, there is also an economic incentive to use less packaging, choose materials that are easier to recycle and design packaging more efficiently.

On paper, it makes sense.

The problem appears when a system designed around millions of tonnes of packaging meets a designer sending 30 parcels abroad each year.

the complicated part: selling to another EU country

This is where many independent brands get caught out.

Being registered for packaging EPR in your home country does not necessarily mean you're covered everywhere in Europe.

Imagine you're an independent Dutch jewellery brand.

You send:

20 orders to customers in the Netherlands.
10 to Belgium.
5 to Germany.
3 to Denmark.

Those might feel like 38 very small sales from one tiny European business.

From an EPR perspective, however, you may be placing packaging onto several different national markets.

Depending on the applicable national rules, this can create registration, reporting or producer responsibility obligations in those countries.

That's particularly relevant for direct-to-consumer e-commerce, where a brand can start selling internationally without ever physically establishing itself abroad.

"producer" doesn't necessarily mean manufacturer

This is another source of confusion.

When people hear producer responsibility, they naturally assume it refers to whoever manufactured the cardboard box or made the clothing.

That's not necessarily how EPR works.

For packaging, the relevant "producer" can be the economic operator that first makes the packaged product available in a particular national market.

The PPWR establishes rules intended to identify one responsible producer for each packaging unit.

So you can be a one-person fashion label that manufactures absolutely no packaging yourself and still potentially be considered a producer for EPR purposes.

what does a fashion brand actually have to do?

This is where there isn't one universal answer.

Depending on the country, type of packaging and quantities involved, businesses may need to:

Register as a producer.
Some countries operate national packaging registers where businesses placing packaging on the market must register.

Report packaging quantities.
Brands may have to declare how much paper, cardboard, plastic, glass or other packaging they introduce to the market.

Join a Producer Responsibility Organisation (PRO).
In some systems, companies fulfil all or part of their responsibility through an organisation that finances the collection and recycling of packaging waste on their behalf.

Pay EPR contributions.
Fees can depend on the material, weight and recyclability of packaging, although minimum or administrative fees can also exist.

And this is exactly why EPR can become disproportionately complicated for micro-businesses.

A brand might send only a few kilograms of cardboard into another country during an entire year, yet still need to understand whether registration or administrative obligations apply there.

aren't small businesses exempt?

Sometimes, but don't assume that they always are.

Some national EPR systems contain thresholds, simplified declarations or exemptions for smaller producers. Others can require registration even when the actual quantity of packaging is extremely small.

And importantly, an exemption from fees does not necessarily mean an exemption from registration or reporting.

This is one of the biggest mistakes small businesses can make when researching EPR.

Instead of only asking:

"Do I have to pay EPR fees?"

ask three separate questions:

Do I have to register?
Do I have to report?
Do I have to pay?

The answers aren't always the same.

EPR is changing under the new EU packaging regulation

The European Union is trying to make packaging rules more consistent through the new Packaging and Packaging Waste Regulation (EU) 2025/40, commonly known as the PPWR.

The regulation entered into force in 2025 and establishes rules covering the entire lifecycle of packaging, including sustainability, labelling, waste prevention and Extended Producer Responsibility. It also requires Member States to maintain producer registration systems and sets out EPR responsibilities for packaging producers.

One of the PPWR's broader goals is precisely to reduce the fragmented rules that create barriers to trade within the EU.

But harmonisation doesn't mean every national system suddenly becomes identical.

Brands selling across borders still need to understand how EPR is implemented in the countries where they sell.

what about the EPR authorised representative requirement?

This has been one of the most controversial parts of the new rules for small cross-border businesses.

Article 45(3) of the PPWR originally requires certain producers selling packaging or packaged products into another Member State to appoint an authorised representative for EPR there.

For a multinational company, appointing representatives across Europe may simply become another compliance cost.

For a micro-brand making a few thousand euros per year, paying representatives in multiple countries could make selling into those markets economically impossible.

Recognising the administrative burden, the European Commission proposed suspending the application of this requirement until 1 January 2035.

The distinction matters: the proposal concerns the authorised-representative requirement. It does not mean EPR itself disappears or that businesses can ignore existing national packaging obligations.

what EPR means for sustainable fashion

There is a slightly uncomfortable irony here.

Many independent brands already operate in ways the fashion industry desperately needs more of.

They produce smaller quantities. They avoid enormous inventories. They reuse materials. They ship relatively few products. And because every euro matters, they often avoid unnecessary packaging naturally.

Yet compliance systems can impose costs that don't scale neatly with environmental impact.

A brand sending 15 kg of cardboard into a market is clearly not creating the same waste problem as a corporation introducing thousands of tonnes.

But if both businesses need registrations, accounts, declarations and external compliance services, the administrative burden per product can be dramatically higher for the smaller one.

Good environmental regulation needs to recognise that difference.

sustainability shouldn't stop at the product

EPR isn't the most exciting side of running a fashion brand.

Nobody starts designing jewellery because they dream of maintaining packaging spreadsheets.

But understanding what happens after a product leaves your studio is increasingly becoming part of responsible fashion.

The principle behind EPR is important: businesses should think about the entire lifecycle of what they put into the world.

The challenge now is making sure the system achieves that goal without making the European single market unnecessarily inaccessible to the smallest businesses trying to do things differently.

At Closet.eco, we work with independent European designers, many of them micro-businesses navigating these requirements for the first time. We believe sustainability should include not only better materials and responsible production, but also transparency about the less glamorous parts of fashion, from packaging and logistics to the regulations shaping how small brands can sell across Europe.

Because building a more sustainable fashion industry isn't just about changing what we make.

It's also about changing the system around it.