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PPWR — EU packaging regulation compliance across member states
Regulation (EU) 2025/40

PPWR: the EU packaging rules that apply to marketplace sellers since 12 August 2026

The PPWR — Regulation (EU) 2025/40 — has applied since 12 August 2026. It requires packaging EPR registration in every EU member state where you sell, explicitly including non-EU distance sellers. Marketplaces must verify that registration before allowing sales, and non-EU sellers also need an authorised representative in each country of sale. Eldris registers packaging EPR in 29 countries from £185 per country per year, annual reporting included and the authorised representative arranged where the law requires one.

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What is the PPWR?

The PPWR is the EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40. It entered into force on 11 February 2025 and has applied since 12 August 2026.

The PPWR, Regulation (EU) 2025/40, is the EU law that has made packaging extended producer responsibility (EPR) a registration duty in every member state since 12 August 2026. It entered into force on 11 February 2025, and because it is a regulation rather than a directive, its obligations apply directly across the EU, with no national transposition step to wait for. For marketplace sellers the operative parts are Article 44, which governs the national producer registers, and Article 45, which sets producer obligations and requires online platforms to verify a producer's registration information before allowing sales. The same 12 August 2026 date also brought the packaging Declaration of Conformity, a 40% maximum empty-space ratio for e-commerce packaging, and PFAS limits — with no grace period. The European Commission's packaging waste guidance tracks the implementing acts as they land.

Who must be registered now

Every business that first makes packaged products available in an EU member state is a producer under the PPWR — and the regulation explicitly includes non-EU distance sellers shipping to EU customers.

The PPWR's producer definition catches marketplace sellers directly: since 12 August 2026, anyone who first makes packaged products available in a member state — including non-EU distance sellers shipping cross-border — must be registered for packaging EPR in that member state. Where the sellers on the largest EU marketplaces are based: of the 54,325 sellers The Sellers Index found on Amazon Germany, France, Italy and Spain (last seen December 2025 to March 2026), 78.8% were based outside the country of the marketplace they were found on, 66.9% outside the EU and 61.6% in China or Hong Kong (Eldris seller data 2026). Where a seller is based says nothing about whether it complies. A seller that sells directly to consumers in a member state where it is not established appoints an authorised representative there (Article 45(3)).

EU companies: the Commission proposal to suspend the authorised-representative duty applies only to EU-based companies. If your company is established outside the EU, that relief does not cover you — the per-country authorised-representative requirement stands.

The per-country registration duty (Articles 44 and 45)

There is no single EU-wide packaging registration. Since 12 August 2026 you must hold a packaging EPR registration in every member state where you first make packaged products available.

Article 44 of the PPWR establishes national producer registers, and Article 45 has made registration in each member state of sale a condition of selling there since 12 August 2026. A seller shipping to customers in Germany, France and Spain therefore needs three separate packaging registrations — one per country — exactly as EPR registration already works today for WEEE and for batteries. Two practical complications matter for planning here. First, the implementing act that defines the registration format is running late, and national registers phase in through 2027; the obligation has applied since 12 August 2026 regardless. Second, registration through existing national systems — Germany's LUCID packaging register is the model — takes on average from 1 week (Germany packaging) to 9–17 weeks (Greece), or 4–5 months for Spain packaging without a Spanish tax number per country, so start with the countries where you already sell. Our guide to packaging EPR across EU markets covers the national schemes in detail.

One authorised representative per country

Non-EU sellers must appoint an authorised representative for EPR in each member state of sale where they have no establishment. One EU representative does not cover the whole bloc.

The PPWR requires a non-EU seller without an establishment in a member state to appoint an authorised representative for EPR in that member state before selling there. The duty multiplies by country: a US or UK seller shipping to ten EU markets has needed ten authorised representatives since 12 August 2026. The Commission has proposed suspending this duty — but only for EU-based companies, so non-EU sellers are not covered by that relief. The packaging authorised representative is also a different role from the EU Responsible Person that product-safety law requires under GPSR — many sellers need an EU Responsible Person under GPSR as well as per-country EPR representatives, and the two are never interchangeable. Every Eldris packaging registration includes the authorised representative where required, so the per-country appointments happen inside the registration fee rather than as a separate engagement. Eldris completes the appointment inside each national filing, and the representative's identity forms part of the registration information that marketplaces verify under Article 45.

Marketplaces must verify your registration

Article 45 of the PPWR requires online platforms to verify producers' registration information before allowing sales. Unregistered sellers face removal, not warnings.

Under Article 45, online platforms and marketplaces must verify a producer's packaging registration information before allowing that producer to sell — the same gatekeeper mechanism that EU Regulation 2019/1020 already gives marketplaces for WEEE enforcement. In practice this means Amazon, eBay, Temu, TikTok Shop and Zalando are the enforcement layer for the PPWR since 12 August 2026, checking per-country registration numbers at listing level. Sellers who have watched Amazon's EPR requirements tighten since 2022 will recognise the pattern: the platform collects registration numbers ahead of the deadline, then suppresses or deactivates offers that lack them once the date arrives. The enforcement calendar below shows how consistently that pattern has held across packaging, WEEE and battery deadlines. Holding the right national numbers is therefore the only reliable defence: verification is automated, listing-level and indifferent to good intentions.

Enforcement precedent: the dated record

Marketplaces have enforced every recent EU producer deadline on or near the day it arrived. The 18 August 2025 battery wave is the clearest precedent for how packaging verification works since 12 August 2026.

Date What happened
15 June – 1 July 2022 Amazon.de blocked listings of sellers without a LUCID packaging registration, in two waves.
31 December 2022 France required a Unique Identification Number (UIN) for EPR; Amazon auto-enrolled sellers without a UIN into Pay on Behalf.
January – July 2023 Amazon.de delisted electronics sellers without German WEEE registration; German fines reach €100,000.
1 January 2025 EU single-use plastics obligations enforced across member states.
18 August 2025 EU Battery Regulation producer deadline. Amazon deactivated non-compliant offers in Germany, the Netherlands, Poland and Sweden the same day; Temu and TikTok Shop enforced the same deadline.
31 December 2025 / 30–31 March 2026 Amazon.it ERN (Italian EPR registration) deadlines for packaging and WEEE.
12 August 2026 PPWR applies from this date: packaging EPR registration is required in every EU member state of sale, with marketplace verification under Article 45.

The dated record reads as a single escalating sequence. Amazon.de moved first, blocking LUCID-less packaging sellers in two waves between 15 June and 1 July 2022. France's UIN requirement landed on 31 December 2022, with sellers without a UIN auto-enrolled into Pay on Behalf. Through January to July 2023, Amazon.de delisted electronics sellers lacking German WEEE registration, against a fines ceiling of €100,000. Single-use plastics obligations took effect on 1 January 2025. On 18 August 2025, the Battery Regulation's producer duties arrived and non-compliant battery offers went dark across Germany, the Netherlands, Poland and Sweden within the day, while Temu and TikTok Shop applied the identical cut-off. Amazon.it's ERN deadlines followed on 31 December 2025 and 30–31 March 2026. Packaging's turn came on 12 August 2026, with Article 45 marketplace verification doing the enforcement work this time.

Germany's WEEE enforcement runs through Stiftung EAR; packaging through the LUCID register. See how sellers restore suspended Amazon listings once a registration gap is closed.

Packaging EPR pricing in all 29 countries

Eldris registers packaging EPR in 29 countries: the 27 EU member states, Norway and the UK, one payment a year per country — from £185 to £855 — with no monthly billing. Every registration includes filing with the authority and compliance scheme, the authorised representative where required (for Portugal packaging the representative's fee is passed through at cost), all annual declarations and reporting (including nil returns) and unlimited SKUs; scheme memberships, authority fees and eco-contributions above any included allowance are passed through at cost, never marked up.

Every line renews at the same price, so the renewal column simply repeats the first-year figure. EUR figures in brackets; EU and US sites display the same figure in EUR/USD at 1.5× GBP.

Country Packaging EPR / yr Renewal
🇩🇪Germany £185 (€280) Same as year one
🇫🇷France £295 (€445) Same as year one
🇮🇹Italy £505 (€760) Same as year one
🇪🇸Spain £395 (€595) Same as year one
🇳🇱Netherlands £190 (€285) Same as year one
🇵🇱Poland £450 (€675) Same as year one
🇦🇹Austria £405 (€610) Same as year one
🇧🇪Belgium £295 (€445) Same as year one
🇧🇬Bulgaria £470 (€705) Same as year one
🇭🇷Croatia £855 (€1,285) Same as year one
🇨🇾Cyprus £655 (€985) Same as year one
🇨🇿Czech Republic £355 (€535) Same as year one
🇩🇰Denmark £450 (€675) Same as year one
🇪🇪Estonia £305 (€460) Same as year one
🇫🇮Finland £405 (€610) Same as year one
🇬🇷Greece £570 (€855) Same as year one
🇭🇺Hungary £555 (€835) Same as year one
🇮🇪Ireland £325 (€490) Same as year one
🇱🇻Latvia £575 (€865) Same as year one
🇱🇹Lithuania £390 (€585) Same as year one
🇱🇺Luxembourg £190 (€285) Same as year one
🇲🇹Malta £565 (€850) Same as year one
🇳🇴Norway £355 (€535) Same as year one
🇵🇹Portugal £600 (€900) Same as year one
🇷🇴Romania £440 (€660) Same as year one
🇸🇰Slovakia £705 (€1,060) Same as year one
🇸🇮Slovenia £745 (€1,120) Same as year one
🇸🇪Sweden £465 (€700) Same as year one
🇬🇧United Kingdom £405 (€610) Same as year one

Prices generated from the Eldris pricing model, 26 September 2026. Spain packaging requires a Spanish NIF — a one-off £395 arrangement fee applies if you do not hold one. Norway sells packaging on its own; Norwegian WEEE and battery registrations exist only inside the all-in bundle, which also carries the packaging line. UK packaging is priced here for a small producer — large producers under pEPR are quoted individually by tonnage, and whether you are the obligated producer at all depends on how your goods reach UK customers. Full per-line detail on the pricing page.

Across the 27 EU members plus Norway and the UK, our price list is built from each country's own rates, so the spread is wide. The lowest packaging price is Germany at £185 a year, with Netherlands and Luxembourg a few pounds above at £190; Croatia tops the table at £855. There is no renewal discount and no renewal uplift anywhere: every line carries one figure, paid as a one-off annual payment — each registration runs for 12 months from the date that country is registered and renews at that same figure for as long as it runs — so year five costs what year one costs. Spain adds a one-off £395 NIF arrangement where no Spanish tax number exists. Norway can be taken as packaging alone at £355, or as a single all-in registration at £900 covering all three streams — there is no standalone Norwegian WEEE or battery line, so the bundle is applied automatically as soon as electronics or batteries are in scope. UK packaging is priced at £405, though whether you owe it at all depends on how your goods reach UK customers. EUR and USD displays are the same number at 1.5× the GBP figure, rounded up to the nearest five.

How Eldris registers you for the PPWR

One onboarding form covers every country. Eldris files each national packaging registration, appoints the authorised representative where required, and delivers the registration numbers marketplaces verify.

The process is built for multi-country scope from the first step. You complete one onboarding form covering every market you sell into; Eldris derives the packaging obligations per country, appoints the authorised representative wherever the national rules demand one, and files each registration with the national register or scheme in parallel rather than one by one. Scheme memberships, authority fees and eco-contributions above any included allowance are not part of the quoted figure: they are passed through at cost, never marked up, and invoiced when the scheme or authority bills them. There is no monthly billing at any point. Average registration time runs from 1 week (Germany packaging) to 9–17 weeks (Greece), or 4–5 months for Spain packaging without a Spanish tax number per country. When each registration completes, the numbers arrive ready for Seller Central and the other platforms' compliance portals — the same registration information marketplaces are required to verify under Article 45 of the PPWR.

Authorised representative arranged

Eldris arranges the authorised representative where the market requires one, with its cost in the registration price (for Portugal packaging the representative's fee is passed through at cost) — no separate per-country engagements to manage.

Scheme membership and fees handled

National register and compliance-scheme filing, and all annual declarations including nil returns, are part of the fee. Scheme memberships and authority fees are passed through at cost, never marked up — we invoice them when the scheme or authority bills them.

Published registration times

Average registration time runs from 1 week (Germany packaging) to 9–17 weeks (Greece), or 4–5 months for Spain packaging without a Spanish tax number, with countries filed in parallel. Each line on the pricing page shows its own average.

Marketplace-ready numbers

Registration numbers are delivered ready for upload to Amazon and other platforms — the exact data Article 45 verification checks.

Other Eldris services you may need

Packaging registration is one of several duties for sellers entering the EU and UK. These are the ones sellers most often need next.

EU & UK Responsible Person

The legal representative that sellers based outside the EU must name on their products before selling there, under the General Product Safety Regulation (GPSR). The UK has its own product rules; Eldris covers the UK as an additional market. Certificate and label address issued the same day.

Who it is for: Any brand outside the EU or UK selling physical products on Amazon, Shopify, eBay, Etsy or TikTok Shop in Europe.

£195 per market, one-off, then from £19.95 a month

Appoint your Responsible Person

Cosmetics compliance: CPSR, PIF and CPNP

The safety report (CPSR), the product information file (PIF) and the EU notification (CPNP) that every cosmetic product needs before it is sold in the EU, produced for you at a fixed price per product.

Who it is for: Skincare, haircare, fragrance and make-up brands selling into the EU or UK, including Amazon and TikTok Shop sellers.

£195 per formula, £39.95 per variation; CPNP filing £99 per CPSR

Get your CPSR and PIF

EU & UK compliance consultation

A fixed-price written report on what applies to your product in each market, what is missing and what to do next, with email follow-ups. Eldris then does the work if you want it to.

Who it is for: Any seller unsure what their product needs, before a launch or after a marketplace asks for documents.

£195 for 3 markets, £295 for 6, £495 for EU 27 + UK

Start a consultation

See all Eldris services

PPWR: frequently asked questions

When did the PPWR start to apply?

The PPWR — Regulation (EU) 2025/40 — entered into force on 11 February 2025 and has applied since 12 August 2026. There is no grace period: producers must hold packaging EPR registration in every member state where they sell.

Do I need a packaging EPR registration in every EU country I sell into?

Yes. Since 12 August 2026, Articles 44 and 45 of the PPWR have required producers — explicitly including non-EU distance sellers — to be registered in every member state where they first make packaged products available. There is no single EU-wide packaging registration.

Are non-EU sellers shipping into the EU covered by the PPWR?

Yes, explicitly. The PPWR names non-EU distance sellers as producers. A non-EU seller must also appoint an authorised representative for EPR in each member state of sale where it has no establishment.

Does the proposed authorised-representative relief cover non-EU sellers?

No. The Commission proposal to suspend the authorised-representative duty applies only to EU-based companies. Non-EU sellers are not covered by that relief and still need an authorised representative in each member state of sale.

How much does packaging EPR registration cost?

Eldris registers packaging EPR per country, one payment a year — no monthly fees. Germany is £185; across the 29 countries we cover, packaging registration runs from £185 to £855 a year. Every registration includes filing with the authority and compliance scheme, the authorised representative where required, and all annual declarations and reporting, including nil returns. Scheme memberships, authority fees and eco-contributions above any included allowance are not part of the price: they are passed through at cost, never marked up, and invoiced when the scheme or authority bills them.

Will Amazon block listings that have no packaging registration?

Article 45 of the PPWR requires online platforms to verify producers' registration information before allowing sales. Precedent says platforms enforce on the deadline: Amazon blocked LUCID-less sellers in 2022 and deactivated non-compliant battery offers in four markets on 18 August 2025, the day the Battery Regulation deadline arrived.

What else has applied since 12 August 2026?

Beyond registration, the PPWR has applied its Declaration of Conformity duty, a 40% maximum empty-space ratio for e-commerce packaging, and PFAS limits since 12 August 2026 — with no grace period. The registration-format implementing act is running late, and national registers phase in through 2027, but the obligations still apply.

How long does packaging EPR registration take?

Average registration time runs from 1 week (Germany packaging) to 9–17 weeks (Greece). The clock starts when we have your documents and signed power of attorney. Spain packaging takes 4–5 months without a Spanish tax number (NIF). Each line on the pricing page shows its own average. If you already sell in a country where you are not registered, register there before your next shipment. Eldris files in all 29 countries in parallel from a single onboarding form.

Register in every country where you sell

Pick your countries, see the exact annual one-off price, and Eldris files every packaging registration — authorised representatives arranged where required.