New EU PPWR: How Online Sellers Can Stay Compliant
Selling on Amazon EU, eBay EU, or shipping into the EU? The new Packaging and Packaging Waste Regulation (PPWR) puts you on the compliance frontline. Every box, mailer, and filler must now designed, reported, and recycled correctly — delaying action risks halted listings or lost marketplace privileges.
EU law covers all packaging on the market — commercial, household, or industrial — requiring strict standards for composition and recoverability.
PPWR entered into force on 11 February 2025, with major provisions from 12 August 2026, aiming for all EU packaging to be recyclable economically by 2030. Cross-border sellers must treat PPWR as a strategic priority to avoid fines and maintain a competitive foothold.
Understanding PPWR: Scope, Objectives, and Seller Obligations
The Packaging and Packaging Waste Regulation (PPWR) is the EU’s new legally binding packaging regulation that replaces the previous Packaging and Packaging Waste Directive (PPWD). It establishes harmonised rules across the 27 Member States on packaging design, recyclability, reporting and producer responsibility, aiming to make packaging economically recyclable by 2030 and to promote reuse and high-quality recycling.
Key points
- Comprehensive coverage: The PPWR applies to all packaging placed on the EU market—commercial, household and industrial.
- Circular economy focus: Waste prevention, reuse and high-quality recycling sit at the regulation’s core.
- Design-for-recycling & PCR: The Regulation sets design requirements and introduces material-dependent minimum post-consumer recycled (PCR) content targets; exact thresholds will be set by implementing acts and may vary by material and timeline.
- Waste reduction targets & single-use limits: Member States must meet packaging-waste reduction targets (e.g., reductions by 2030/2040), and certain single-use formats will be phased out under the Regulation.
Who is affected
- EU-based sellers: Update packaging, register for EPR and prepare for harmonised digital labelling.
- Non-EU sellers placing packaged goods on the EU market: Must appoint an EU authorised representative to manage EPR registration, reporting and fee obligations — unless an EU importer contractually assumes those duties.
- Manufacturers, fulfilment partners & marketplaces: Must track recycled content, comply with design criteria and, under Article 45, marketplaces are expected to verify seller packaging registration as part of market-access checks.
Note: The PPWR entered into force on 11 Feb 2025, and most core obligations are expected to apply after an 18-month transition (from 12 Aug 2026), though specific implementation timelines and thresholds will be refined in delegated/implementing acts.
PPWR Compliance: Practical Measures for Marketplace Sellers
With PPWR now in force, affected sellers must translate legal requirements into operational practices. Below are the practical measures and seller actions to prioritise.
Key compliance measures
- Material efficiency: E-commerce packaging will be subject to empty-space limits to reduce over-packaging; industry guidance frequently cites an approx. 40% empty-space benchmark, but some sources and provisions allow different thresholds or phased limits (some references note up to 50% in particular categories). Exact thresholds and exemptions will be set in implementing acts.
- Recycled content & recyclability: Minimum PCR requirements and recyclability grades will be introduced by material category; packaging must be recyclable by design by 2030.
- Labels & digital product data: Digital labelling requirements (machine-readable IDs/QR codes) are scheduled to roll out in coming years to link packaging to recyclability and reuse information.
- EPR & reporting: Producers must register for EPR, submit annual packaging reports by material and recyclability grade, and retain technical documentation (material declarations, PCR certificates, design/recyclability test reports) for audits.
Who must act
- EU sellers: Update EPR registrations, ensure packaging meets design and recyclability standards, and prepare digital labelling.
- Non-EU sellers (D2C or B2B placing goods in the EU): Appoint an authorised representative to manage registrations and reporting unless an EU importer takes responsibility.
- Marketplaces: Expect to collect seller registration numbers and self-certifications and to block or restrict listings where registration is missing or invalid.
Practical steps for sellers (priority checklist)
- Register for EPR in each Member State where you place packaging on the market, or prepare to use the central EU packaging registry when available.
- Submit annual reports detailing material composition, weight and recyclability grades per national EPR rules.
- Maintain technical documentation (supplier declarations, PCR certificates, design/recyclability evidence, test reports) ready for national audits or marketplace checks.
- Start packaging audits and design optimisations now to avoid last-minute redesigns and listing interruptions.
- Why act early: early compliance reduces regulatory risk, protects marketplace listings, and strengthens your brand’s reputation as a sustainable participant in the EU e-commerce market.
Key PPWR Deadlines and Compliance Timeline
Confirmed or Highly Reliable Milestones
| Date | Milestone | Notes |
| 11 Feb 2025 | PPWR officially enters into force (legal effect) | Confirmed by EU official sources (environment.ec.europa.eu) |
| 12 Aug 2026 | General application date — most core obligations start to apply | EU sources confirm applicability from this date |
| By 1 Jan 2030 | All packaging must be recyclable by design | Multiple sources indicate 2030 as key target for design-for-recycling |
| By 1 Jan 2035 | Packaging must be recyclable at scale | Sources indicate 2035 as milestone for large-scale recyclability |
| By 2040 | Stricter waste reduction and PCR content targets apply | Includes ~15% reduction in packaging waste vs 2018 and higher PCR content |
Developing or Pending Details Milestones
| Date | Milestone | Notes |
| 2027 | Digital labeling, empty-space limits, reuse count standards | Drafts and delegated acts expected; exact effective dates/ratios pending (packlab.gr) |
| 12 Feb 2027 | Delegated acts: define packaging minimization, empty-space, reuse frequency | Expected per EU timeline |
| 12 Aug 2028 | Unified marking / digital labeling may start to apply | Likely start date after delegated acts or 24 months post-implementation |
| Multi-year | Phased targets for PCR content, recyclability grades (A/B/C), empty-space, reuse rates | These are planned to be gradually introduced; specific numbers to be defined by EU Commission through implementing acts |
Phase-by-Phase Seller Actions
- Now–Aug 2026: Audit packaging, register for EPR, appoint authorised EU representative if non-EU.
- 2026–2029: Redesign packaging, implement digital labels, collect supplier PCR certificates.
- 2030–2035: Strengthen recycling partnerships, optimise EPR fees via better design.
- 2035–2040: Prepare for advanced circularity and reuse targets.
PPWR Compliance FAQ
For EU-Based Sellers
Q1: What are my main PPWR obligations?
You must register for EPR, ensure your packaging meets recyclability standards, and prepare for digital labelling by 2027. Annual packaging data (weight, material, recyclability grade) must be reported in each Member State where products are sold.
Q2: Do I need separate EPR registrations for each country?
Yes, until the central EU registry is launched (expected by 2029). Each Member State currently requires individual registration.
Q3: How can I reduce compliance costs?
Use recyclable or mono-material packaging and verify PCR content from suppliers — these factors lower your eco-modulated EPR fees.
Q4: What are the most common compliance risks?
- Missing the August 2026 registration window
- Incorrect packaging data or outdated design specs
- Missing documentation during audits
Compliance tools like VATAi can help maintain full compliance visibility across all markets.
For Non-EU Sellers Shipping to the EU
Q1: Can I still sell to EU customers after 2026?
Yes, but you must appoint an authorised representative in the EU to handle EPR registration and reporting. Without one, your listings may be blocked on marketplaces.
Q2: Does PPWR apply if I sell through Amazon or eBay fulfilment centres?
Yes. If your packaging reaches EU customers, you’re considered a producer under PPWR — even if sales go through a third-party logistics provider.
Q3: How do marketplaces enforce compliance?
Amazon, eBay, and others must verify your packaging registration before activating listings. Missing EPR numbers or non-compliant packaging can trigger listing suspension.
Q4: Can someone manage this process for me?
Yes. VATAi works with authorised representatives across the EU to register packaging, manage reporting, and submit required documentation on your behalf — ensuring uninterrupted sales.
Take Action Early
The PPWR introduces one of the most comprehensive sustainability frameworks in the world — and early movers will benefit most.
Need Help with EU PPWR Compliance?
Book a free call with VATAi today to get your personalised PPWR rodamap for your e-commerce business