Since 12 August 2026, the EU Packaging and Packaging Waste Regulation — PPWR, formally Regulation (EU) 2025/40 — applies across all 27 member states. For online retailers selling across borders, the most disruptive change is already in force: a seller shipping into an EU country where it has no establishment must appoint an authorised representative for packaging compliance in that country.
The timing matters because the relief many sellers were counting on has stalled. In December 2025 the European Commission proposed suspending the authorised-representative obligation for EU-based producers until 2035 as part of its Environmental Omnibus package. On 24 June 2026 the Council broke off its deliberations on that proposal amid opposition from a large majority of member states, and the European Parliament is negotiating a much narrower exemption. As of today, the rule stands as written.
From directive to regulation: why this bites harder
PPWR entered into force on 11 February 2025 and became applicable on 12 August 2026 after an 18-month transition, replacing the Packaging Waste Directive that had governed the field since 1994. The legal form is the point: a directive had to be transposed into 27 national laws, while a regulation applies directly and uniformly. The scope is broad — producers, importers, distributors and fulfilment service providers all count as economic operators, and packaging itself is regulated from design to waste.
Uniform rules do not mean one-stop compliance, though. Extended producer responsibility (EPR) — registration, data reporting and fee payments for the packaging you place on a market — remains organised country by country. There is no EU-wide registry: selling into ten member states means ten registrations.
What distance sellers must do now
Under the regulation, an online shop or marketplace trader selling packaged goods directly to end customers in another EU country is generally treated as the “producer” of that packaging there. Two obligations follow:
- EPR registration in every destination country. The seller must appear in the national packaging register and report volumes and pay fees under local rules.
- An authorised representative in every country where the seller has no establishment (Article 45). The representative takes over the EPR duties locally — and finding, contracting and paying one in each market is the cost that industry groups have been protesting since the rule was adopted.
Trade bodies warn that this per-country model hits small and mid-sized sellers hardest and risks fragmenting the single market it was meant to harmonise; the Cross-Border Commerce Association notes the obligation applies regardless of shipping volume, with no general country-specific exceptions.
The next deadlines are already scheduled
The regulation phases in further requirements that e-commerce teams should plan for now rather than discover later:
- August 2028: harmonised labelling of packaging, including material composition markings.
- 1 January 2030: an empty-space cap for e-commerce, transport and grouped packaging — no more than 50% of the parcel may be void space, and packaging must be minimised in weight and volume.
- 2030: recyclability performance grades begin to restrict what packaging may be placed on the market at all, with thresholds tightening over the following decade.
Penalties are set nationally; member states are required to make them “effective, proportionate and dissuasive”. In practice, enforcement will vary by country — one more reason the per-country representative model is under fire.
What it means for your business
If you sell physical goods into more than one EU country, treat this as a live compliance project, not a 2030 problem:
- Map your markets. List every member state where you shipped orders in the last 12 months. That list, not your company registration, defines your obligations.
- Check your EPR status in each of them. If you are registered nowhere but your home country, close the gaps first — registration is the precondition for lawful sales under PPWR.
- Contract authorised representatives where you lack an establishment. Several compliance providers offer multi-country packages; costs scale with the number of markets, so prioritise by revenue.
- Audit your parcels early. The 50% empty-space cap and recyclability grades arrive in 2030, but packaging procurement cycles are long — decisions you make this year determine whether your 2030 parcels comply.
- Watch the Omnibus file, but do not wait for it. Parliament’s first reading is expected in October 2026 at the earliest, the outcome is uncertain, and the current rule is enforceable today.
Compliance load of this kind also changes the economics of market selection: for some catalogues it now makes sense to concentrate on fewer, deeper markets rather than shipping everywhere. That is a strategy question as much as a legal one — the same modelling we do when building and localising e-commerce sites for clients entering new markets.
We expect enforcement to start unevenly and data demands to grow year by year. The sellers who fold packaging compliance into their market-entry checklist now will spend less than those who retrofit it under a deadline.
