KontorBund — Explainer When the marketplace asks for your number
Last checked 8 September 2026
kontorbund.com/explainers/marketplace-registration-number.html

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When the marketplace asks for your number

Last checked8 September 2026

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The short version

A marketplace has to obtain your registration number and a self-certification before it may let you sell (Art. 45(4)), and then make best efforts to assess that what you gave it is complete and reliable (Art. 45(6)). The number it needs is for the member state the customer is in, not the one you are in. A fulfilment provider must run the same check and suspend you if it fails. And there is one thing a platform genuinely can do for you, which almost nobody asks for: pay your EPR fees under written mandate.

Correction, 8 September 2026

We had the paragraph number wrong. Until today this site cited Art. 45(6) PPWR for the duty on a marketplace to obtain your registration number before letting you sell. That duty is in Art. 45(4). Art. 45(6) is the next step — the platform's obligation to make best efforts to assess whether what you gave it is complete and reliable. Two paragraphs, two different duties, and we had merged them. The error was on the Germany desk, the Austria desk and the Library card, and is corrected on all of them. Nothing about what you owe changes; the citation does. If you quoted us to a platform, quote Art. 45(4).

Why they suddenly want a number

Nothing about your business changed. What changed is that on 12 August 2026 the marketplace acquired a duty of its own, and the cheapest way for it to discharge that duty is to make it your problem in an onboarding form.

The words are worth reading, because they explain the tone of the email you got. Art. 45(4) makes the platform obtain, prior to allowing those producers to use their services, your registration number in the member state where the consumer is located, and a self-certification that you comply there. Not after your first sale. Not within a reasonable period. Prior.

Art. 45(4) — obtain, before onboarding: The platform must get (a) your registration under Art. 44 in the member state where the consumer is, with the registration number, and (b) a self-certification from you that you meet the EPR requirements there.
Art. 45(5) — the automated route: A member state may provide that automated reconciliation against its national register is used to verify what you supplied. Germany has run exactly this since 2022 under § 7a VerpackG: the ZSVR gives marketplaces daily-updated register access and your entry is checked against it automatically.
Art. 45(6) — assess, before onboarding: Having received it, and still before letting you use the service, the platform "shall make best efforts to assess whether the information received is complete and reliable". This is the paragraph that turns a rejected-but-valid number into a support ticket.
Art. 45(7)–(9) — and again for fulfilment: A fulfilment service provider must collect the same information when it contracts with you, make best efforts to check it, and ask you to fix anything inaccurate, incomplete or out of date. If you do not, it shall swiftly suspend the service and tell you why. Art. 45(9) gives you a right to challenge that in a court of the member state where the provider is established.

Per member state, not per platform. The number the platform needs is your registration in the country the customer is in — so one marketplace account can require twenty-seven different numbers, and typically asks for them one country at a time as you enable shipping there. This is the single most common misunderstanding: people supply their home registration and assume it travels. It does not.

What a platform can do for you — and what it cannot

This is the part people get wrong in the other direction, usually while arguing that the platform ought to be handling all of it. One thing genuinely can be handed over, and it is not the thing most people ask about.

The task Can the marketplace do it? Basis

Pay your EPR financial contributions Yes, on the basis of a written mandate Art. 45(4), second subparagraph — the obligations in Art. 45(2), which are the cost ones, "may, on the basis of written mandate, be met by the provider of the online platform, on behalf of the producer"

Register you in the national register No — unless it is your appointed representative or your PRO, and the state allows that route Art. 44(2) and 44(3). See where registration can be delegated

Report your packaging quantities No, on the same footing as registration Art. 44(7) — you, your EPR representative, or your PRO

Be your authorised representative Only if you appoint it as one, in writing, and it agrees Art. 45(3) — a written mandate, per member state

Excuse you from any of it because you only sell there No Nothing in the Regulation makes selling through a platform a compliance position

The task	Can the marketplace do it?	Basis
Pay your EPR financial contributions	Yes, on the basis of a written mandate	`Art. 45(4)`, second subparagraph — the obligations in `Art. 45(2)`, which are the cost ones, "may, on the basis of written mandate, be met by the provider of the online platform, on behalf of the producer"
Register you in the national register	No — unless it is your appointed representative or your PRO, and the state allows that route	`Art. 44(2)` and `44(3)`. See where registration can be delegated
Report your packaging quantities	No, on the same footing as registration	`Art. 44(7)` — you, your EPR representative, or your PRO
Be your authorised representative	Only if you appoint it as one, in writing, and it agrees	`Art. 45(3)` — a written mandate, per member state
Excuse you from any of it because you only sell there	No	Nothing in the Regulation makes selling through a platform a compliance position

Worth asking for, and almost nobody does. The fee-payment mandate in Art. 45(4) is a real, express permission sitting in the Regulation, and it is the piece of the burden a platform is best placed to absorb — it already knows what you sold. It does not remove your registration or your reporting. But if a platform tells you there is nothing it is allowed to do for you, that is not right, and this is the paragraph to put in front of it.

Three countries where the platform rule bites differently

Art. 45 is the floor. Three national layers change the picture enough to be worth knowing before you argue with a support agent.

Greece — the platform can become the producer: Greek law can shift EPR responsibility onto the marketplace unless you supply proof of your own EMPA registration. That inverts the incentive: the platform is not being officious, it is exposed. Register, and keep the evidence file where you can attach it in one click. See the Greece desk.
Croatia — the same, for an unregistered seller: The Croatian rule makes a marketplace the producer for a seller who is not registered. Combined with monthly reporting and monthly payment, Croatia is the country where a platform is most likely to act first and discuss it afterwards. See the Croatia desk.
Italy — ask your platform before you do anything: CONAI recognises simplified arrangements agreed between platforms and EPR systems, so the platform may already be handling the contribution — and CONAI equally states that where you do not use the platform service, it is yours. Establish which world you are in first; it changes the answer. See the Italy desk.
France — the marketplace needs one too: Unusual and worth flagging: the French mandataire duty reaches non-established online marketplaces facilitating distance sales, not only the sellers on them. If your platform is not French, it has its own problem. See the France desk.

When a valid number gets rejected

It happens, and Art. 45(6) is why: the platform is required to form a view on whether what you gave it is complete and reliable, and it forms that view with an automated check it did not write. The failure modes we have seen are dull and mostly fixable.

The name does not match the register

Automated reconciliation compares your platform account against the register entry. A trading name on one side and a legal name on the other is enough to fail it. The register entry is the one that has to change, and in most countries it is the one you control.

You gave your home country's number

The commonest of all. The number wanted is for the member state the customer is in. A German LUCID number does not satisfy an Austrian requirement, and the systems know it.

The registration is real but very new

Registers publish on their own schedule and the platform is checking a copy. A number issued yesterday can fail a check today. Wait a cycle before escalating.

The number is right and the field is wrong

Some platforms have one field per stream — packaging, EEE, batteries — and they are easy to cross. A packaging number in the EEE field fails, correctly.

What not to do: do not self-certify compliance you do not have in order to clear the form. The self-certification in Art. 45(4)(b) is a statement you are making, the platform is required to assess it, and in several countries the register is public. An unregistered seller with a clean self-certification is in a materially worse position than an unregistered seller who has not yet been asked.

Sources

The article numbers on this page were read directly in the Regulation rather than taken from a summary — which is how we found that our own previous citation was wrong. The national rows come from the country desks, where each sits next to its national source.

Regulation (EU) 2025/40 (PPWR) — EUR-Lex Source for Art. 45(4) (obtain the registration number and self-certification prior to allowing use of the service, and the second subparagraph on paying fees under written mandate), 45(5) (automated reconciliation), 45(6) (best-efforts assessment), 45(7)–(9) (fulfilment service providers, suspension, and the right to challenge it). Read directly for this page
ZSVR — marketplaces and fulfilment service providers Source for the German check under § 7a VerpackG, in force since 1 July 2022, and for the register access marketplaces are given
European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Read in full
The country desks Greece, Croatia, Italy and France above — each finding sits on its own desk next to the national source it came from

Help us finish this page

We would like to build a plain table of what each platform actually asks for, field by field — Etsy, Amazon, eBay, Shopify Markets, Bol, Allegro, Kaufland — and in what format, because the Regulation says "the registration number" and every platform has its own idea of what that looks like. If you have been through one of these onboarding flows, a screenshot and two sentences is a contribution nobody else can make.

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