As online shopping continues to accelerate globally, national authorities in the Nordic and Baltic countries have issued a firm reminder: businesses selling products online to consumers in these markets are legally obligated to comply with Extended Producer Responsibility (EPR) requirements. Many international sellers—often unknowingly—are violating these rules, prompting authorities to launch a new information website and an upcoming webinar aimed at helping companies meet their compliance obligations.
What Is Extended Producer Responsibility (EPR)?
- Extended Producer Responsibility is an EU-based legal framework that makes producers responsible for the entire life cycle of their products, including end-of-life waste management. Under EPR:
- Producers must ensure their products are properly collected, recycled, and managed as waste.
- Obligations apply to both physical and online sellers, regardless of where they are located.
- The system aims to reduce waste and drive sustainable production by encouraging durable, recyclable, and non-hazardous product design.
- Compliance is typically achieved by joining a Producer Responsibility Organisation (PRO) or appointing an Authorised Representative (AR) in the destination country.
Products Covered Under Mandatory EPR in the Nordic and Baltic Countries
For more information please visit https://eng.mst.dk/industry/waste/how-to-manage-extended-producer-responsibility
EPR applies broadly to businesses selling the following products to consumers:
In all Nordic–Baltic countries
- Packaging
- Electrical and electronic equipment (WEEE)
- Batteries
- Single-use plastics (SUP)
- Fishing gear containing plastics
- Vehicles
- Beverage containers
Additional obligations in specific countries include agricultural plastics, paper products, tyres, lubricating oils, textiles, lamps, and more.
Managing EPR Obligations
Businesses selling EPR-covered products must:
- Register in the producer register of each country where products are sold.
- Report product quantities placed on the market.
- Pay EPR fees to fund waste collection, sorting, and recycling.
EPR must be managed separately for each product group. For example, selling a laptop requires compliance for electronic equipment, batteries, and packaging individually.
Distance sellers—including those based outside Europe—face additional rules. Many must appoint an Authorised Representative, particularly for batteries, electronics, single-use plastics, and, from August 2026, packaging.
Importantly, selling via online marketplaces does not exempt companies from EPR obligations.
Implications for ASEAN Businesses and Policymakers
1. Growing Compliance Requirements for ASEAN Exporters
ASEAN-based companies increasingly selling to Nordic–Baltic markets must comply with the same EPR rules as European businesses. Non-compliance can lead to penalties, blocked listings on online platforms, reputational risks, and supply chain disruptions.
Products commonly exported from ASEAN—electronics, packaging-intensive goods, plastics, automotive parts, textiles—are all subject to EPR in these markets.
2. A Signal for ASEAN to Strengthen Own EPR Systems
Nordic–Baltic EPR enforcement highlights an emerging global trend. As ASEAN Member States advance strategies on circular economy and plastic circularity, this serves as a reference for:
- Improving national EPR frameworks
- Strengthening cross-border enforcement
- Supporting SMEs with compliance tools and capacity building
Countries such as Thailand, Vietnam, Indonesia, and the Philippines—already developing EPR regulations—can draw lessons from harmonised EU systems.
3. Opportunity for ASEAN to Build Regional EPR Guidance
The EU’s structured approach offers a model for ASEAN to develop:
- A shared regional EPR framework
- Regional guidance on online and distance selling
- Digital reporting systems and producer registers
- Support platforms for SMEs and e-commerce exporters
Such regional alignment supports ASEAN’s ambitions under the ASEAN Circular Economy Framework (2021–2025) and the ASEAN Declaration on Plastic Circularity (2024).
4. Strengthening ASEAN–EU Cooperation
Given the EU’s leadership in EPR, this presents an important opportunity for knowledge sharing, particularly through platforms such as:
- The ASEAN Circular Economy Stakeholder Platform (ACESP)
- EU SWITCH-Asia
- ASEAN–EU joint projects on circular economy and digitalisation
Conclusion
The Nordic–Baltic push to enforce Extended Producer Responsibility for online sellers demonstrates a rapidly evolving global regulatory landscape. For ASEAN exporters, this is both a compliance requirement and a strategic opportunity. Strengthening regional EPR systems, harmonising regulations, and supporting SMEs will position ASEAN competitively in sustainable global trade, while accelerating progress toward a circular, resource-efficient future