Packaging EPR for Estonian and Baltic online shops selling abroad

The basic rule: the destination decides

Under the EU's PPWR, producer responsibility arises in the member state where the packaging becomes waste. If you ship directly to an end user in Germany, you are the producer in Germany for that parcel, and German rules apply to it. The same logic applies to France, Austria and every other EU country.

What stays in Estonia

Packaging you place on the Estonian market falls under the Estonian Packaging Act (pakendiseadus). You declare it in the national packaging register PAKIS, and most sellers hand their recovery duties over to a recovery organisation (taaskasutusorganisatsioon) by contract.

For packaged goods sold abroad, the Estonian packaging guide states that Estonian recovery requirements and packaging reporting don't apply, and warns that other countries may have their own producer responsibility rules. Latvian and Lithuanian shops follow their own national rules at home; the destination principle is the same.

Your Estonian packaging contract doesn't cover parcels to Germany, and a German LUCID registration doesn't cover parcels to Estonian customers. Each market has its own registration.

Selling to Germany from Estonia

1. Appoint an authorised representative in Germany. Since 12 August 2026, producers established abroad without a German branch need one when they sell directly to end users in Germany. This includes companies from other EU countries.
2. Register in LUCID in your company's name, with the same data as in your marketplace account: registry code, VAT (KMKR) number, address.
3. License your shipping packaging with a dual system, through your representative.
4. Report your quantities in LUCID.
5. Enter your LUCID number on Amazon, Etsy or eBay if you sell there.

The EU is discussing whether to suspend the representative rule for EU-based producers that place small quantities in another member state. As of the date above, this is a proposal, not law. Until it is adopted, plan for a representative.

Other EU countries

• France: an eco-organism, an IDU number and a French representative. See France.
• Austria: an authorised representative and a licence with a collection and recovery system. See Austria.
• Netherlands, Belgium, Ireland: thresholds and rules differ. See Netherlands and Belgium and Ireland.
• Finland, Latvia, Lithuania, Poland and the rest: each has its own national scheme. We check it before quoting.

Pilot. Placedon is run by an Estonian company, NooraNoir OÜ, and works in Estonian, Russian and English. We're launching, and we are going through our own shop's packaging registration right now. One country costs €249 one-time + €19 / month; the first 20 clients keep these prices for 12 months. Ask us to check your case.