Selling in three EU countries means, on the packaging-compliance front, managing three different systems with logics, frequencies and formats that don't line up. Extended Producer Responsibility (EPR) is a common European principle — whoever places packaging on the market funds its collection and recycling — but each state has translated it into its own rules. Germany, Italy and France are the most relevant example for an e-commerce business.
This is the pillar guide: it puts the three countries side by side, highlights what they have in common and where they diverge, and points to the detailed guides dedicated to each market. If you sell on Shopify in several countries and want the big picture before getting into the details, start here.
The common ground: no minimum threshold
Let's start with what the three countries share, because it's also the most underestimated aspect: none of the three has a minimum threshold below which you are exempt. In Germany, Italy and France the obligation kicks in from the very first unit placed on the market.
It's a frequent mistake to think "I'm too small, it doesn't apply to me": from a regulatory standpoint, even a single cross-border order makes you a producer under the respective laws. The size of the business changes the frequency and the costs, not the existence of the obligation.
Where the three countries diverge
Past the common ground, the differences are substantial. We group them into the four dimensions that matter most in daily practice: frequency, declaration format, penalties and structural quirks.
Frequency: three different rhythms
- Germany: the frequency is not fixed by law, it depends on the agreement with the chosen dual system and can be annual, quarterly or monthly. LUCID aligns with that cadence.
- Italy: mandatory quarterly the first year, then variable (annual, quarterly or monthly) based on the amount of Environmental Contribution declared the previous year.
- France: annual, the simplest — one declaration a year, at the start of the year on the previous year's data.
Format: XML file versus online form
Here there's a sharp split that weighs heavily on the operational work:
- Germany: you work with an XML file, to upload to the LUCID portal and, separately, in the dual system's format (formats that across different dual systems are not identical).
- Italy and France: no file. Everything is filled in online, respectively on dichiarazioni.conai.org and on Citeo's Espace Client.
The practical consequence is that the ideal tool must do two different things depending on the country: generate a correct XML for Germany and provide the totals ready to type for Italy and France.
Penalties: three different logics
- Germany: a fixed absolute cap — up to €200,000 and an immediate distribution ban, with marketplaces required to block unregistered sellers.
- Italy: mostly proportional to the contribution due — €5,000 for failure to enrol (up to €46,500 for packaging producers) and a penalty of 50% of the sums due, rising to 150% for repeated declaration breaches.
- France: calculated per undeclared tonne or unit — up to €7,500 per tonne (art. L541-10-11) and up to €30,000 for failure to join / missing IDU (art. L541-9-5).
One important caveat: the three penalty systems are not directly comparable on the same basis. Germany has a fixed absolute cap, Italy is mostly proportional to the contribution due, France is calculated per undeclared tonne or unit. Comparing the maximum amounts alone risks comparing different quantities.
Structural quirks
Each system has a distinctive trait worth knowing:
- Germany: the double obligation — the same data declared to both the dual system and LUCID — and the distinction between Planmengenmeldung (forecast quantities) and Istmengen (actual quantities).
- Italy: the simplified procedures for importers, based on the value of goods (e.g. 0.09% for non-food products) as an alternative to weight-based calculation.
- France: the €80 flat rate for those placing fewer than 10,000 UVC a year, with a simplified declaration.
The comparison table
Here are the three countries in a single view. It's the summary to keep within reach.
| Germany (LUCID) | Italy (CONAI) | France (Citeo) | |
|---|---|---|---|
| Minimum threshold | None | None | None |
| Frequency | Variable (per dual-system contract) | Quarterly year 1, then variable | Annual |
| Declaration format | XML file (direct upload) | Online form only | Online form only |
| Portal | LUCID + dual system | dichiarazioni.conai.org | Espace Client |
| Maximum penalty | €200,000 + distribution ban | €46,500 (failure to enrol) · 150% of the contribution (repeated untruthful declaration) | €30,000 (no IDU) · €7,500 per undeclared tonne |
| Quirk | Double obligation (dual system + LUCID), Plan/Istmengen | Flat-rate procedure for importers | €80 flat rate below 10,000 UVC |
What managing multiple countries together means
For anyone selling in two or three of these markets at once, the complexity isn't just the sum of the individual rules: it's that the same Shopify orders must be re-read through three different lenses. The same parcel shipped to a German, Italian or French customer generates obligations calculated on different bases and formats — weight by material everywhere, but also UVC for France, an XML file for Germany, totals to type for Italy and France.
Doing it by hand, on separate spreadsheets for each country, is the perfect recipe for errors and for hours lost at the end of the period. It's precisely the scenario EPR Pack Report was built for: starting from your real Shopify orders, it calculates the weights by material and — where needed — the count in UVC, automatically distinguishing by destination country, and prepares the output in the right format: the XML for LUCID and the dual system in Germany, the ready totals for the Italian and French portals.
Where to start if you sell in multiple countries
If you've just discovered you're subject to these obligations in several markets, the practical order to proceed is fairly linear:
- Map the countries you actually ship to. There's no need to register everywhere in theory: start with the markets you have real orders to. Shopify's history tells you straight away.
- Register where needed. In Germany that means LUCID plus a dual system; in Italy enrolment with CONAI; in France registration with Citeo. These are one-off steps.
- Set up packaging tracking. This is the recurring part: weight by material everywhere, plus UVC for France. Better to automate it from the start than to reconstruct it at the end of the period.
- Mark the deadlines. Different cadences by country: annual in France, quarterly the first year in Italy, variable in Germany. A simple calendar reminder avoids most problems.
The most common mistakes
Three traps recur often among merchants new to EPR. The first is believing you're too small: there's no minimum threshold, the obligation kicks in from the first unit. The second is stopping at registration, forgetting that the real task is the periodic quantity declaration — in Germany, even doubled. The third is underestimating transport packaging: in e-commerce the shipping box, the filler and the tape are often the largest share of weight, yet they're the first to slip past an estimate made from memory.
The detailed guides, country by country
This overview is here to orient you. For the operational details of each market — registrations, exact deadlines, practical steps — we have a dedicated guide:
- 🇩🇪 LUCID and VerpackG: the complete EPR compliance guide in Germany — registration, dual system, Plan/Istmengen, fines up to €200,000.
- 🇮🇹 CONAI for e-commerce: the packaging declaration in Italy — frequency, the dichiarazioni.conai.org portal, simplified procedures for importers.
- 🇫🇷 Citeo and EPR in France — Espace Client, UVC, the €80 flat rate and the new B2B stream from 1 July 2026.
In short
Three countries, one common principle (extended producer responsibility) and three different implementations. No minimum threshold in any of the three: if you ship, you declare. Germany is the most structured and the strictest on penalties; Italy has the most articulated frequency; France is the most straightforward, with a flat rate designed for the small.
The common thread, for Shopify sellers, is that everything starts from the same data — the weight and number of packaging units placed on the market, by country — and that handling it by hand across several jurisdictions quickly becomes unsustainable. Automating that calculation is the simplest way to stay compliant wherever you sell, always remembering that the declaration and final legal responsibility remain yours: the tool supports the calculation, it does not replace the obligations.