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.
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'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.
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.