Distance Selling: Your Duties Live at the Delivery Address
Registration, representative and fees in each member state you deliver to - the distance seller's full position, the de-minimis reality, and the three legitimate strategies for the tail.
The short answer
Distance selling collapses the distance between a warehouse and twenty-seven jurisdictions: under the framework, packaging supplied to end users in a member state by distance sale is placed in that state, and the seller owes the state's EPR position there - registration (with an authorised representative where the seller is not established in that state), declarations and fees on the packaging it sends, in the state's own categories. There is no European passport for the duty and no general volume below which the map shrinks to the home market; national reliefs exist in places but are national, specific and evidenced - the small-producer guide's discipline.
This guide sets the seller's position and the strategies that make it affordable.
The mechanics per state: representative, register, report
Per destination state the seller needs three artefacts: a representative where required (the EPR mandate of the roles station - a compliance appointment, distinct from the conformity representative), a registration in the state's producer register or scheme, and a reporting rhythm feeding placed quantities from the order data (units by packaging type per destination - which means the shop's data model must know its packaging per SKU and its deliveries by state, the reporting pipeline of the EPR station running on e-commerce rails). Sellers discover the data requirement last and suffer it longest: build the SKU-packaging-state cube into the shop's reporting from the start, because reconstructing it from invoices is the tail strategy's most expensive hour.
The three strategies, reprised for the channel
The member-state station's tail strategies take channel form. Industrialise: a representative network plus automated declarations from the cube, with the matrix's tail rows maintained centrally - the default for a serious D2C brand. Consolidate: sell through channels that carry the duty - marketplaces' arrangements where the framework places verification (and in defined cases the duty) on the platform, or distributors as importers of record for the markets they serve. Exit: close delivery to states whose fixed cost exceeds their margin, implemented in the shop's shipping zones as a deliberate act. The channel's version of the fourth, illegitimate strategy - ship everywhere, register at home, rely on smallness - is precisely what marketplace verification and the registers' data-sharing are built to find, and the platforms find it before the authorities do.
The B2B distance note
Distance sales to business customers follow the placing logic with the commercial-packaging variations of each state (industrial and commercial streams have their own schemes and, in several states, their own registers' sections). B2B sellers should not read the consumer framing of this station as their exemption: the packaging they ship - grouped, transport, the product's own - is placed, registered and fee-bearing in the destination state's commercial stream, and the customer contracts increasingly ask for the registration evidence in onboarding. The cube does not care whether the address is a home or a warehouse; neither does the register.
The map is the strategy
Distance sellers experience the framework as a map question before any other: which states, at what fixed cost, against what margin. Answer it deliberately, in the shipping-zone settings where the answer becomes real, and revisit it whenever the representative market reprices or a marketplace changes the duty's location. The sellers who struggle are never the ones who chose a small map; they are the ones who never noticed they had chosen the large one.
The home-market illusion
One illusion deserves burial before the framework's registers do it: the home-market illusion, in which a seller's domestic registration and domestic success are felt to radiate compliance across the map the courier covers. They do not; the register at the delivery address is the whole law there, and it has never heard of the seller's home position. Sellers who bury the illusion early buy their representatives in calm markets. The rest buy them in the week a platform suspends the account, at the same price, with worse company.
Primary sources on the record
- Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste, Official Journal text on EUR-Lex.
- European Commission, packaging waste topic page - guidance and act progress.
- Regulation (EU) 2019/1020 of 20 June 2019 on market surveillance and compliance of products, text on EUR-Lex - the surveillance framework, including fulfilment service providers.
- Regulation (EU) 2023/988 of 10 May 2023 on general product safety, text on EUR-Lex - the online marketplace duties that sit beside the PPWR.
Legal status: Article 45 of Regulation (EU) 2025/40 (EPR for distance sellers). Application position for this topic: Framework applies from 12 August 2026; national registers live today.