Do I Need a VAT Number to Register for EPR?

Do I Need a VAT Number to Register for EPR?

Overview

If you're preparing to register for Extended Producer Responsibility (EPR) in Germany, Spain, or France, one of the most common questions we hear is whether a VAT number is required. The short answer: no — though the exact requirement varies slightly by country.
Here's a breakdown of what you need for each market.

Germany

The core registration data required includes a VAT Identification Number (Umsatzsteuer-Identifikationsnummer) or a Taxpayer Reference Number.

This means there's a bit of flexibility — if you don't yet have a German VAT number, a taxpayer reference number can sometimes be used instead.

That said, if you're selling into Germany and storing stock there (for example, via a 3PL Warehouse, or Amazon FBA), you'll likely need VAT registration anyway. In practice, this often makes the question moot, as most sellers end up needing a VAT number regardless.

Spain

Yes, effectively required, but can obtain a digital certificate only if preferred 

Spain's system is built around the NIF (tax identification number), and there isn't really a way around this — it's how the Spanish authorities recognise your company for the packaging register.

So even though it isn't labelled a "VAT number," the NIF performs the same function and is essential for registration. We can help if wanting to proceed with ES EPR, without an active ES VAT number. For more information, please click here

France

France's EPR system also requires a way to identify your business for tax purposes, and a VAT number is the standard way to provide this.

There can be some flexibility depending on your company's legal setup, so it's worth checking your specific circumstances if you're unsure.

In Summary

You can't really register for EPR without proving who you are for tax purposes in that country — whilst a VAT number is the most common way to do this, there are options available country-by-country and we'll be able to discuss the best route forward depending on your needs.

Need more help?

Requirement can very depending on your company's setup and the registration route you take. If you're unsure, please get in touch, and we'll be happy to help confirm the right approach