Lithuania EPR
What is Lithuania EPR Packaging
Extended Producer Responsibility (EPR) for packaging in Lithuania requires producers/importers to finance and ensure the proper management of packaging and packaging waste (collection, recycling, recovery targets), as well as maintain records and submit reports via the national system GPAIS. Even if obligations are fulfilled collectively through a Producer Responsibility Organization (PRO), registration and reporting in GPAIS remain mandatory.Does this apply to e-commerce & online sales
Yes. If you:- Place packaged goods on the Lithuanian market for the first time (including distance selling), or
- Import packaged goods or empty packaging into Lithuania,
- Shipping packaging (boxes, envelopes, filler, tape) used to deliver orders to Lithuanian customers.
- Product packaging (primary, secondary packaging) if you import or first place goods on the Lithuanian market.
Who is the “producer” under Lithuanian EPR
In Lithuania, the obligated party is typically the company that:- Manufactures and/or packages goods in Lithuania (even via subcontractors),
- Imports packaged goods into Lithuania (where Lithuanian VAT/import procedures apply),
- Manufactures or imports empty packaging.
Who must register for EPR packaging in Lithuania
Companies qualifying as producers/importers must:- Register in the Producers and Importers Register via GPAIS, and
- Maintain packaging records and submit reports through GPAIS.
Lithuania EPR Registration Threshold
Important nuance:- Registration and record-keeping obligations generally apply regardless of volume.
- Financial obligations (taxes or PRO fees) may depend on annual quantities.
- If less than 0.5 tonnes of packaging per year is placed on the market, environmental tax may not apply in certain cases.
- Companies placing ≤5 tonnes of filled disposable packaging may benefit from simplified accounting rules.
Detailed EPR Guidance for each Jurisdiction
We support 36 jurisdictions
Packaging Covered (and Excluded)
Covered packaging includes:- Sales packaging (primary packaging)
- Grouped/secondary packaging
- Transport packaging
- Single-use and reusable packaging
- All material types: plastic, paper/cardboard, glass, metal, composite packaging, etc.
- Deposit system packaging
- Packaging used for “own needs”
- Certain reusable packaging streams
Producer Responsibility Organization (PRO)
Obligations can be fulfilled:- Individually (self-compliance), or
- Collectively via a licensed organization (PRO).
EPR Registration in Lithuania (GPAIS Process)
Typical steps:- Create/login to a GPAIS account.
- Register in the Producers/Importers Register.
- Configure packaging accounting by:
- Material type
- Packaging type
- Single-use vs reusable
- Deposit vs non-deposit
- Choose compliance model (individual or collective) and sign a PRO agreement if applicable.
Authorized Representative
Foreign companies selling into Lithuania may need:- Registration as a foreign entity in GPAIS, and/or
- Appointment of a local representative (depending on structure).
What Data Must Be Reported
Typically required:- Packaging weight by material (plastic, paper, glass, metal, composite, etc.)
- Packaging type (primary, secondary, transport)
- Single-use vs reusable
- Deposit vs non-deposit
- Volume placed on the Lithuanian market
- Own-use packaging (if applicable)
First Reporting Period
Reporting starts from the date when the company first:- Places packaged goods on the Lithuanian market, or
- Imports packaging/packaged goods into Lithuania.
EPR Reporting Deadlines
Key deadline:- Annual packaging report via GPAIS must be submitted by February 19 (within 50 calendar days after year-end).
- Annual packaging report via Žaliasis taškas must be submitted by January 30 (within 30 calendar days after year-end).
- Environmental pollution tax declaration (form FR0524) may be required based on packaging volumes.
Labels & Marketing Claims
Important points:- Packaging marking is regulated under Lithuanian packaging legislation.
- The Green Dot (Žaliasis taškas) symbol indicates participation in a recovery system — it does NOT mean the packaging is recyclable.
EPR Eco Fees & Eco-Modulation
Financial mechanisms include:- PRO service fees (based on material type, recyclability, volume, etc.)
- Environmental pollution tax if obligations or recovery targets are not properly fulfilled.
Risks, Penalties & Common Mistakes
Common mistakes by e-commerce sellers:- Ignoring shipping packaging as “placed on the market”
- Incorrect material classification (especially composite packaging)
- Not separating reusable and deposit streams
- Late or inaccurate GPAIS reporting
- €900–€1700 for legal entities (depending on severity)
- Additional fines for responsible managers
What E-commerce Sellers Should Do Now
- Determine who is the obligated party in your supply chain.
- Create a packaging BOM (including shipping materials).
- Track packaging weight by material.
- Decide on individual compliance or PRO membership.
- Register and configure GPAIS properly.
- Set internal controls for the February 19 reporting deadline.
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FAQ
Do I need to register if volumes are small?- Usually yes, if you qualify as a producer/importer. Financial liability may depend on volumes, but registration is typically required.
- Not customs import, but EPR liability usually depends on who first places packaging on the Lithuanian market.
- No. Registration and reporting in GPAIS remain mandatory.
- No. It only indicates participation in a recovery scheme.