Do you sell vinyl yourself in the EU? Just one record can put you in charge of the packaging
The EU’s new packaging regulations could have implications for artists who ship vinyl and CDs to fans abroad themselves. Even a small number of vinyl sales could mean that you have to comply with packaging regulations in several different countries.
By Julie Westh Nielsen
Imagine this: A fan in Berlin orders your new vinyl from your online store.
You pack the vinyl in paper and packaging and send it off from Denmark.
It's the only record you sell to Germany all year round.
Nevertheless, the sale means that you are responsible as a manufacturer for the packaging in Germany.
What matters is not whether you run a large webshop or simply send out individual records to fans abroad. The rules also apply to the very small, direct sales.
The rules are becoming more uniform – but producer responsibility is not new
On August 12, 2026, it began The EU’s new packaging regulation, PPWR should apply. It should, among other things, make the packaging regulations more uniform across the EU.
These include requirements for materials, labeling, documentation, and recyclability. If you yourself manufacture vinyl, CDs, or packaging with your name or brand on it, you will therefore have a responsibility to ensure that the packaging complies with the regulations. Andreas Ring Andersen points out that this may be the case, regardless of whether the production takes place within or outside the EU.
The regulation also changes the rules regarding producer responsibility. Among other things, the rules on when a producer becomes responsible are now brought together into a common EU framework. Previously, the requirements for when and how to register were handled differently from country to country.
“As a rule, people have to register all the time, but that is becoming more formalized with the new regulation,” explains Andreas Ring Andersen.
However, the responsibility of producers is not uniformly standardized, and it remains a national matter for each country. Therefore, the handling of responsibility in other areas can vary greatly from country to country.
In practice, this means that whoever makes the packaging available in an EU country must register, report the quantities of packaging, and pay for the handling of the packaging once it becomes waste. This applies to every country where the packaging is made available.
For an artist with their own online shop, the question is therefore not only how much is sold, but also where the customers live.
Five countries can mean five systems
Imagine that your record is ordered by several fans
Ten are going to Germany. Three are being sent to Sweden.
A fan in France buys one, two end up in the Netherlands and six are shipped to Finland.
Sales are still modest. But because you sell directly to end users in several countries, you may have to deal with the manufacturer's responsibilities in each of them.
This can mean, among other things, more registrations and different producer schemes. And if you are not established in the country yourself, you must also have an authorized representative: That is, a local actor who assumes the producer responsibility on your behalf.
It is precisely here that the rules can become noticeable for the small self-publisher.
However, this does not necessarily mean that the artist himself has to handle the administration in all cases. How the release is sold on has significance for where the producer’s responsibility ends.
“If you sell through a distributor, the distributor may have to live up to the manufacturer’s responsibilities,” says Andreas Ring Andersen.
For some self-publishers, a distributor can therefore become an alternative to dealing with the requirements in several different countries.
Getting sales doesn't mean you're exempt
The new regulation contains a limit of 10 tons of packaging per year. However, it should not be understood as a minor limit, where smaller companies are exempt from responsibility for the packaging.
If you weigh under 10 tons, reporting becomes simpler, among other things. However, you still have to comply with the packaging regulations.
For the vast majority of self-published artists, 10 tons will of course be far above the amount of packaging they send out. But the point is that even a very small sale in itself does not exempt you.
There is therefore a good chance that you are subject to some of the new rules if you sell vinyls or CDs in the EU. However, all the new requirements will not come at once. Several of the more comprehensive requirements for, among other things, the recyclability of packaging will be introduced later.
Therefore, the most important thing right now is to figure out what role you play, how to market your publications, and which countries you sell directly to.
Do you sell vinyl or CDs yourself? Then it’s a good idea to have this under control:
Find your sales countries. Get an overview of which EU countries you send physical publications directly to end users in. The producer responsibility will be relevant from the first sale.
Investigate the registration in each country. If you sell directly to customers in several countries, you will need to register and comply with the producer liability scheme in each of them.
Check requirements for a local representative. If you are not established in the country in question yourself, you will need to have an authorized representative to take care of the producer responsibility.
Don't be fooled by the 10-ton limit. The limit means easier reporting, but does not automatically exempt small sellers.
Find out who is responsible for the production of the packaging. If you receive vinyl, CDs, or packaging made with your name or brand, you may also have obligations regarding the packaging itself.
Consider your sales model. If you sell through a distributor instead of directly to the end customer, the manufacturer’s responsibility may lie with the distributor.
Save the documentation. Make sure to obtain and keep relevant information from those who produce your records, covers and other packaging.
If you are in doubt, ask before sending. The specific situation depends, among other things, on where you sell and how your products and packaging are produced and distributed. Andreas Ring Andersen recommends first gaining an overview of whether you have responsibilities as a manufacturer or producer, and then assessing the consequences for your business.
Do you need help?
If you are unsure about how the packaging regulations affect your sales or your publication, you can contact the federation's legal department at jura@artisten.dk and Andreas Ring Mortensen on ara@artisten.dk.
The Danish Artist Union also advises self-publishers on, among other things, direct sales, distribution, and the agreements that come with a publication.