PPWR: the EU Packaging Regulation for marketplace sellers — what applies from 12 August 2026
The PPWR — Regulation (EU) 2025/40 — applies from 12 August 2026 and 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.
Last updated: 11 June 2026
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 applies from 12 August 2026.
The PPWR, Regulation (EU) 2025/40, is the EU law that makes packaging extended producer responsibility (EPR) a registration duty in every member state from 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 brings 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 act before 12 August 2026
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: from 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. The scale of exposure is measurable, and it concentrates where representation is hardest to arrange. Eldris proprietary tracking (The Seller Index dataset) shows 9,579 sell on the EU's four largest marketplaces (EU EPR Seller Compliance Index 2026), of which 1,364 non-EU/EEA-based sellers active on the EU-4 marketplaces carry the heaviest new duty (non-EU sellers' EU EPR gap), including 628 Greater-China sellers (China and Hong Kong analysis), the cohort with the least room to defer. Each of the 1,364 non-EU sellers in that dataset must appoint an authorised representative in every member state of sale from 12 August 2026.
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. From 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 makes registration in each member state of sale a condition of selling there from 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 still applies from 12 August 2026. Second, registration through existing national systems — Germany's LUCID packaging register is the model — typically takes 2–8 weeks per country, so waiting for enforcement to begin is the expensive option. 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 needs ten authorised representatives from 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 become the enforcement layer for the PPWR from 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 before the date 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 preview of what 12 August 2026 will look like for packaging.
| 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 non-compliant sellers 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: packaging EPR registration 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 non-compliant sellers 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 comes 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 EU, EEA and UK markets as an annual one-off fee per country — from £240 (€360) to £990 (€1,485) — with no monthly billing. Every registration includes the authorised representative where required, scheme membership, government fees (stated exceptions pass through at cost) and unlimited SKUs.
Where year-two renewal is cheaper than year one, the renewal column shows it. EUR figures in brackets; EU and US sites display the same figure in EUR/USD at 1.5× GBP.
| Country | Packaging EPR / yr | Renewal (yr 2+) |
|---|---|---|
| 🇩🇪Germany | £240 (€360) | £185 |
| 🇫🇷France | £385 (€580) | £335 |
| 🇮🇹Italy | £535 (€805) | Same as year one |
| 🇪🇸Spain | £520 (€780) | Same as year one |
| 🇳🇱Netherlands | £255 (€385) | Same as year one |
| 🇵🇱Poland | £605 (€910) | £520 |
| 🇦🇹Austria | £535 (€805) | Same as year one |
| 🇧🇪Belgium | £385 (€580) | Same as year one |
| 🇧🇬Bulgaria | £250 (€375) | Same as year one |
| 🇭🇷Croatia | £250 (€375) | Same as year one |
| 🇨🇾Cyprus | £250 (€375) | Same as year one |
| 🇨🇿Czech Republic | £250 (€375) | Same as year one |
| 🇩🇰Denmark | £600 (€900) | Same as year one |
| 🇪🇪Estonia | £250 (€375) | Same as year one |
| 🇫🇮Finland | £535 (€805) | Same as year one |
| 🇬🇷Greece | £520 (€780) | Same as year one |
| 🇭🇺Hungary | £740 (€1,110) | Same as year one |
| 🇮🇪Ireland | £390 (€585) | Same as year one |
| 🇱🇻Latvia | £250 (€375) | Same as year one |
| 🇱🇹Lithuania | £250 (€375) | Same as year one |
| 🇱🇺Luxembourg | £250 (€375) | Same as year one |
| 🇲🇹Malta | £250 (€375) | Same as year one |
| 🇳🇴Norway | All-in bundle (WEEE + Battery + Packaging) £1,190 (€1,785) | — |
| 🇵🇹Portugal | £790 (€1,185) | Same as year one |
| 🇷🇴Romania | £585 (€880) | Same as year one |
| 🇸🇰Slovakia | £495 (€745) | Same as year one |
| 🇸🇮Slovenia | £990 (€1,485) | Same as year one |
| 🇸🇪Sweden | £535 (€805) | Same as year one |
| 🇬🇧United Kingdom | Bespoke (pEPR — quoted by tonnage) | — |
Prices generated from the Eldris pricing model, 11 June 2026. Spain packaging requires a Spanish NIF — a one-off £200 arrangement fee applies if you do not hold one. Norway is sold only as an all-in bundle. UK packaging (pEPR) is individually quoted because fees scale with tonnage. Full per-line detail on the pricing page.
Across the 27 EU members plus Norway and the UK, the architecture of the price list is flat by design. Nine smaller markets — Czech Republic, Estonia, Latvia, Lithuania, Luxembourg, Malta, Bulgaria, Croatia and Cyprus — sit at £250 (€375) a year, while Slovenia tops the table at £990 (€1,485) and Portugal at £790 (€1,185). Only three markets discount the renewal year: Germany drops to £185 (€280), France to £335 (€505) and Poland to £520 (€780); every other country renews at its first-year figure. Spain adds a one-off £200 (€300) NIF arrangement where no Spanish tax number exists, Norway is bundle-only at £1,190 (€1,785) covering all three streams, and UK packaging is quoted individually because pEPR fees scale with tonnage. EUR and USD displays are the same number at 1.5× the GBP figure, rounded 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 will 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. Government fees and compliance-scheme membership are part of the quoted figure, with the stated exceptions passed through at cost and no monthly billing at any point. Filing windows run two to eight weeks per country, which is why a June start protects the 12 August 2026 date. 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 included
Every registration includes the authorised representative where the market requires one — no separate per-country engagements to manage.
Scheme membership and fees handled
National register filing and compliance-scheme membership are part of the fee; government fees are included, with stated exceptions passed through at cost.
2–8 week filing window
Registrations typically complete in 2–8 weeks per country, filed in parallel — start before summer 2026 to hold numbers on 12 August 2026.
Marketplace-ready numbers
Registration numbers are delivered ready for upload to Amazon and other platforms — the exact data Article 45 verification checks.
PPWR: frequently asked questions
When does the PPWR start to apply?
The PPWR — Regulation (EU) 2025/40 — entered into force on 11 February 2025 and applies from 12 August 2026. There is no grace period: producers must hold packaging EPR registration in every member state where they sell from that date.
Do I need a packaging EPR registration in every EU country I sell into?
Yes. From 12 August 2026, Articles 44 and 45 of the PPWR require 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 as an annual one-off per country — no monthly fees. Germany is £240 (€360) (£185 (€280) from year two), and smaller EU markets start from £240 (€360). Every registration includes the authorised representative where required, scheme membership and government fees, with stated exceptions passed through at cost.
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 changes on 12 August 2026?
Beyond registration, the PPWR applies its Declaration of Conformity duty, a 40% maximum empty-space ratio for e-commerce packaging, and PFAS limits from 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?
Registration typically takes 2–8 weeks depending on the country, so sellers starting in summer 2026 risk missing the 12 August 2026 application date. Eldris files in all 29 countries in parallel from a single onboarding form.
Hold your numbers before 12 August 2026
Pick your countries, see the exact annual one-off price, and Eldris files every packaging registration — authorised representatives included.