Expanding into another EU country
What changes per country, and what does not
| Stays the same | Changes per country |
|---|---|
| Your EU Responsible Person under GPSR. One mandate covers all 27 member states. | EPR registration for packaging. Every country has its own register, its own scheme and its own number. |
| Your technical documentation and Declaration of Conformity. | The language of the safety information and warnings on your product and packaging. |
| CE marking and the product safety requirements themselves. | VAT registration, if you hold stock there or exceed a threshold. |
| Your Article 17 packaging representative, if you have appointed one. | Whether you need an EPR representative established in that country. |
That right-hand column is the work. The left-hand column is why expansion is still worth doing.
The order to do it in
Start with the items that depend on someone else, because those are the ones that decide your launch date.
- EPR registration. One to four weeks per country, longer where a local representative has to be appointed first. Start here.
- VAT registration, if applicable. Two to eight weeks depending on the country, and it does not run in parallel with everything else because you often need it before you can hold stock.
- Labelling in the local language. One to two weeks, but it can mean reprinting, so decide early whether you use a multilingual label from the start.
- Marketplace fields. Same day, once the numbers exist. This is the step everyone starts with and it is the one that has to come last.
The mistake we see most often is a seller who switches on a new marketplace, gets the listing blocked within days for a missing EPR number, and then discovers the registration takes a month.
Planning a launch date?
Do you need a representative in that country?
This is the question that has changed most recently, and the answer depends on where you are established.
- Established in the EU and selling cross-border directly to consumers in another member state: under Article 45(3) of the PPWR you must appoint an authorised representative for extended producer responsibility in each of those countries. This follows directly from the regulation.
- Established outside the EU: it depends on national law in each country. Germany and Spain require it. Others do not, or have not decided yet.
- Selling only in your own country: you register yourself and no representative is involved.
This is separate from the packaging representative under Article 17, which covers documentation and works EU-wide with a single mandate. Two different roles, two different scopes.
VAT and stock
The short version: you need a VAT number in every country where you hold stock, and in countries where your distance sales exceed the threshold.
The complication is Pan-European FBA. Your stock is moved between fulfilment centres by Amazon, which means countries can be triggered without you deciding to sell there. Check where your inventory has actually been before you assume you only owe VAT in one place.
We handle VAT registration in the Netherlands, Germany, France, Italy and Belgium, and can arrange other countries. If you import into the EU yourself you also need an EORI number.
One market for products. Twenty-seven for packaging waste.
We handle the national side so your launch date is based on lead times rather than hope.
EPR registration and annual declarations, directly for France and Germany.
A check of your labelling against the local language and market requirements.
VAT and EORI registration where you need it.
A realistic timeline per country, so you know when you can be live.
Frequently Asked Questions
Common questions about selling in a new EU country.
No. There is no EU-wide EPR registration. Every country has its own register and its own number, and marketplaces check them per country.
Usually three to six weeks, driven by the EPR registration and, where it applies, VAT. The marketplace side is same-day once the numbers exist.
Not necessarily the whole thing, but safety information and warnings must be in the language of the country you sell to. Many sellers move to a multilingual label to avoid reprinting each time they add a country.
Considerably. Your stock moves between countries, so more EPR registrations and potentially more VAT positions apply than you chose deliberately.
For product rules yes, for packaging waste not necessarily. Under Article 45(3) of the PPWR an EU seller shipping cross-border directly to consumers needs an EPR representative in each of those countries.