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How many countries does a compliance client need?

Most need one. Nearly four in ten need more. At an EU compliance business, the first business on EU27, 20 of the 52 client companies with country data (38%) hold work in two or more countries, and one holds work in ten. The mean is 2.06 countries; the median is 1. Data at 11 October 2026.

Published Last updated By EU27.ai

38%of client companies hold work in two or more countries: 20 of 52, at 11 October 2026.

How many countries does each client need?

One country for 32 of the 52 client companies with country data (62%). The other 20 (38%) hold an EPR registration or a Responsible Person appointment in two or more countries, and 12 (23%) in three or more.

Client companies by number of countries, 11 October 2026 (n = 52). Source: the first business on EU27, read-only query of paid work.
CountriesClientsShare of 52
13261.5%
2815.4%
335.8%
435.8%
523.8%
635.8%
1011.9%

The average hides the spread. The mean is 2.06 countries per client, pulled up by the few clients in six or ten countries, while the median client is in one. A practice that plans its desk around the average client will be wrong about most of its clients and badly wrong about its largest ones.

Each country is its own piece of work. A client registered for packaging in Germany and in France holds two registrations, with two national authorities and two sets of deadlines, inside one client relationship. In this dataset, the 20 multi-country clients account for 75 of the 107 country records, so most of the country work sits with a minority of clients. That is the case for keeping every client on one record, with each country beneath it, rather than one inbox thread per country. It is also why a country count belongs on the client's own screen: a client in six countries needs to see six statuses, not one.

Which countries come up most?

Germany: 19 of the 52 client companies (37%) hold work there. Ireland follows with 14, France and the Netherlands with 10 each, then Italy (8), Spain (7) and the United Kingdom (6). In all, the business holds work for clients in 24 countries.

Client companies per country, top ten, 11 October 2026 (n = 52; a client in several countries counts in each).
CountryClientsShare of 52
Germany1936.5%
Ireland1426.9%
France1019.2%
Netherlands1019.2%
Italy815.4%
Spain713.5%
United Kingdom611.5%
Poland47.7%
Belgium35.8%
Bulgaria35.8%

The data shows where clients hold work, not why they chose those countries. Seven countries each carry six or more clients, and the remaining 17 countries share the rest. For a practice, that means a handful of countries where the work is routine and many where only a few clients hold work, which is where knowing who holds each step matters most. Countries also bring languages: a client in Germany, France and Italy may want to write in German, and a partner there may write in its own. How often cross-border business crosses languages is the subject of our study of marketplace sellers and compliance clients by language.

Which services do clients buy, and do they buy more than one?

EPR registration is the most common service: 37 of the 61 paying client companies hold it. 18 hold a Responsible Person appointment and 14 had cosmetics safety work. Seven clients (11.5%) hold two or more services.

Paying client companies by service, 11 October 2026 (n = 61; a client with two services counts in both).
ServiceClientsShare of 61
EPR registration3760.7%
Responsible Person appointment1829.5%
Cosmetics safety work1423.0%
Two or more of the above711.5%

Of the seven clients with more than one service, four combine cosmetics safety work with a Responsible Person appointment, two combine EPR with a Responsible Person appointment, and one holds all three. The law links the two: a cosmetic product sold in the EU needs both a safety assessment and a designated Responsible Person under Regulation (EC) No 1223/2009. About one client in nine holds a second service. A client who already works with a practice has already shared its documents and contacts, so a second service starts from documents the practice already holds. EU27 shows each client the next service it could add, on its own screen, and lets it order without a call. The accounting page shows the same idea for a practice's own services.

When did clients arrive?

Mostly between July and September 2026: 51 of the 61 paying clients (84%) arrived in those three months, against 7 from April to June. August was the busiest month, with 20 new clients.

New paying client companies by month of first paid service, 2026 (n = 61). October is to 11 October only.
MonthNew clients
April2
May1
June4
July17
August20
September14
October (to the 11th)3

The rise coincides with the months around 12 August 2026, the date the EU's packaging regulation, Regulation (EU) 2025/40, began to apply. The data shows timing, not cause: other things changed over the same months, and this dataset cannot separate them. For a practice the lesson is about capacity rather than cause. Three months brought more than seven times the clients of the three before, so the systems a practice uses in a quiet quarter have to hold in a busy one.

How many documents does a client project carry?

A median of 6. Across 59 paid projects the business holds 899 documents, a mean of about 15 per project, and the largest single project carries 165.

The gap between the median and the mean says the same as the country figures: most projects are small, and a few are very large. Documents are the part of compliance work that moves between three parties. The client sends them, the business checks them, and for EPR a registration partner files them. Every hand-over is a chance for a file to sit in someone's inbox. One project like the largest here means 165 documents to track. Requesting each document with a due date, and filing it on the client's record when it arrives, is what lets a desk answer "what are we waiting for?" without searching mail. Responsible Person certificates are not counted as files here.

How this was measured

  • Source. The production database of an EU compliance business, the first business on EU27, read with read-only SQL on 11 October 2026. Paid work only; test records excluded.
  • Clients. A client is a distinct customer email with at least one paid service: 61. A company that used two emails would count twice.
  • Countries. The countries where a client holds an EPR registration or a Responsible Person appointment through the business, with names normalised to country codes. Clients with cosmetics work only carry no country list, so the country figures use the 52 clients that do.
  • Documents. Files attached to the 59 paid EPR and cosmetics projects. Responsible Person certificates are not files in this count.
  • Period. The first paid client in April 2026 to 11 October 2026. October is partial.
  • Limits. One business, 61 clients and six months. The figures reflect where this business sells and which services it offers; they are not a sample of the market, and they are a snapshot, not a forecast.

Questions

What share of compliance clients work in more than one country?

In this dataset, 38%: 20 of the 52 client companies with country data hold an EPR registration or a Responsible Person appointment in two or more countries, at 11 October 2026.

Which country do compliance clients need most often?

Germany. 19 of the 52 client companies with country data hold work there, followed by Ireland with 14 and France and the Netherlands with 10 each.

How many compliance clients buy a second service?

Seven of 61 paying client companies (11.5%) hold two or more services. Cosmetics safety work with a Responsible Person appointment is the most common pair, held by four.

How many documents does a compliance project hold?

A median of 6 per paid project, across 899 documents on 59 projects. The largest project holds 165.

See it in EU27

Sources

  • Client database of an EU compliance business, the first business on EU27: read-only query, 11 October 2026; 61 paying client companies, 52 with country data, 59 paid projects, 899 documents.
  • Regulation (EU) 2025/40 on packaging and packaging waste: EUR-Lex.
  • Regulation (EC) No 1223/2009 on cosmetic products: EUR-Lex.
  • European Commission, Packaging waste (in force since 11 February 2025; applies from 12 August 2026): environment.ec.europa.eu.

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