Can I sell while my EPR registration is pending?

No. Legally, a seller must be registered before it sells into a country, so goods wait while the EPR registration is pending. The law requires registration before packaging, electronics or batteries are placed on a country's market (Regulation (EU) 2025/40, Article 44(4); Directive 2012/19/EU, Article 16(1); Regulation (EU) 2023/1542, Article 55(2)), and marketplaces check the numbers. The one compliant route meanwhile is a buyer who acts as importer of record and takes on the obligation. Eldris issues no provisional number.

What the law requires before the first sale

Each stream's law requires the producer to be registered in a country before it places goods on that market. A seller that sells directly to end users in a country where it is not established is the producer there. A pending file is not a registration, so the first sale waits for the number.

The duty sits in a different act for each stream. For packaging it is Regulation (EU) 2025/40, Article 44(4), read with the producer definition in Article 3(1)(15). For electrical and electronic equipment it is Directive 2012/19/EU, Article 16(1). For batteries it is Regulation (EU) 2023/1542, Article 55(2). Registration is national and runs stream by stream. A German packaging registration does not cover France, and it does not cover the batteries in the same box.

The sales channel does not change the duty. A marketplace listing and your own website are treated alike once the goods reach an end user in that country. Sellers often ask whether they may start while the file is in progress, or only once the number has been issued. The articles answer it: the registration comes first, then the goods. A business established in the country is a producer too, when it first makes the goods available there.

What marketplaces check, and what happens without a number

Each Amazon marketplace in the EU checks the registration numbers of its own country, stream by stream. Amazon.de asks for a LUCID packaging number, a WEEE-Reg.-Nr. and a battery registration before electronics can list. Where a number is missing, Amazon suspends or delists the listings.

Amazon.fr asks for a Unique Identification Number for each stream, Amazon.it for an Italian EPR registration number and Amazon.pl for a BDO number. Since 12 August 2026 the PPWR has extended verified packaging registration to every EU member state. The Amazon EPR requirements page sets out what each marketplace verifies.

Amazon.de blocked listings of sellers without a LUCID number in 2022 and delisted sellers without German WEEE registration in 2023. On 18 August 2025, Amazon deactivated battery offers without registration in Germany, the Netherlands, Poland and Sweden. Temu and TikTok Shop enforced the same deadline. Seller accounts with repeated violations face permanent deactivation. National regulators can fine as well; in Germany the fines are set out in ElektroG, section 45. What happens once a listing is blocked, and how it is restored, is covered in the guide to blocked Amazon listings.

What a pending EPR registration is, and is not

Paying for a registration starts the file; it does not register you. Eldris usually submits within 48 hours of payment and your product information, and the file then waits with the authority. You are registered when the authority or scheme issues the number.

Eldris does not issue a provisional number of its own. Each registration number is issued by the country's authority or scheme, and Eldris then issues its certificate for that registration. Both reach your portal market by market. Until then, a portal that shows your steps as complete means the file is queued with the authority. It does not mean you are registered.

The order of events explains the wait. After payment you upload six documents, including a signed power of attorney for each country. Eldris submits once the file is complete, and the authority or scheme then checks it and issues the number in its own time. A seller who has just paid and wants to ship is at the first of these steps. For that country and stream, the goods wait for the number. Countries and streams where you already hold a number carry on as before.

The buyer as importer of record: the one compliant route

If your timetable cannot wait, the one compliant route is for your buyer to import the goods as importer of record. The buyer then takes on the producer obligation in that country, and must itself be registered there before it places the goods on the market.

This route moves the obligation; it does not remove it. A business established in the country that first makes the goods available there is a producer under Regulation (EU) 2025/40, Article 3(1)(15). It registers for each stream it places on that market, under the same articles that apply to you. What changes is your position: you sell to that business, not to end users there.

The details decide whether the route fits. Who is named as importer on the customs declaration, where the buyer is established and where the goods end up all matter. Selling only to businesses does not settle the question on its own. Describe the set-up by replying to your quote or in the chat before you pay, and Eldris confirms whether the registration is yours to hold. The route does not change marketplace sales to end users: there, you remain the producer, whatever the channel.

When a marketplace deadline comes before the number

Say so before you pay, by replying to your quote or in the chat, with the market and the date. Eldris then compares the date with that line's average time to register. A deadline raised after payment cannot move the authority's timetable.

The average time to register for every country and stream is on the pricing page. It is counted from the day Eldris has your complete documents and signed power of attorney. It is an average from recent registrations, not a guarantee. What sets the pace in each country is explained in the guide to registration times.

Where the average is longer than the time you have, the choices are plain. You can hold back sales of that stream into that country while the EPR registration is pending. You can supply a buyer who imports as importer of record and holds the registration. Or you can move the launch date. Because the clock starts only when the file is complete, sending your documents promptly is the part of the wait you control. This answer sits with the others sellers ask on the EPR questions page.

Frequently asked questions

Is proof of submission enough to start selling?

No. The law requires registration before goods are placed on a country's market, and a submitted file is not yet a registration. The number a marketplace checks is issued by the country's authority or scheme, and Eldris then issues its certificate for that registration.

Does Eldris issue a provisional or temporary number?

No. Eldris issues no provisional number of its own. Registration numbers come from each country's authority or scheme. Once a number is issued, Eldris issues the certificate for that registration, and both appear in your portal.

Should I stop selling into a country until the number arrives?

Yes, for that country and that stream, unless a buyer imports the goods as importer of record. Registrations you already hold elsewhere are unaffected, because each country and each stream is registered separately.

Does Amazon Pay on Behalf let me sell while I wait?

No. Pay on Behalf handles eco-contributions in some countries, but it does not register you with the national authority or give you a WEEE producer number. It does not meet the registration duty under ElektroG or the equivalent national law.

Who registers if my buyer is the importer of record?

The buyer, for each stream it places on that market. It is then the producer there and must hold its own registrations before it sells the goods on. Describe the set-up before you pay, and Eldris confirms whether the registration is yours or your buyer's.

Can Eldris make an authority issue the number sooner?

No. Once a file is submitted, the authority or scheme sets the pace. Eldris chases the file as part of the service and shows each country's state in your portal. The averages on the pricing page are not promises of a date.