Do private-label and imports trigger EPR duties?
TL;DR: Usually yes—if you own the brand or import into Germany, you are the first distributor and must register, participate in a dual system, and report.
Related questions
- What is the LUCID forecast (HPM1) and who must file it?
- How do I create the LUCID forecast (HPM1) with EPR One?
- What data does EPR One include in forecast vs actuals (HJM1) and intra-year (HNM1)?
- What counts as consumer sales packaging vs shipping packaging under VerpackG?
- Does dropshipping or 3PL change my EPR obligation?
- Do returns and cancellations reduce reportable mass?