You ship four parcels a week from your spare room, and one morning the marketplace asks you for a packaging registration number within a few days, or the shop gets suspended. Welcome to the PPWR, the European packaging regulation that turns any seller of physical goods into an official "producer", starting with the very first box.
The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It entered into force on 11 February 2025 and has applied since 12 August 2026 across all 27 member states. It replaces the 1994 directive and a patchwork of national regimes with one common framework: the same design rules, the same registration logic, the same checks everywhere.
This guide covers your three concrete obligations, a method for sorting the countries you sell into, what the platforms demand, and the timeline through 2030. No jargon is assumed.
Why this regulation exists
The European Commission puts numbers behind the urgency. Every person in the EU generated 186.5 kg of packaging waste in 2022. Packaging accounts for 40% of the plastic used in the Union, and for half of the litter found at sea.
The goal the Commission states in its packaging waste policy pages: make all packaging on the EU market recyclable in an economically viable way by 2030. The other effect of the text gets less airtime, and it is financial. It forces sellers based outside the EU to pay towards the waste they ship in by the million.
Are you a "producer" under the PPWR?
The trap word in the regulation is producer. It does not mean the company that makes the packaging. It means whoever first makes a packaged product available on the territory of a given country.
You pour candles in Manchester and sell one to a customer in Brussels? As far as the text is concerned, you are a producer in Belgium. Every country you ship to turns you into a local producer, with the paperwork that comes with it.
One nuance changes everything. If you sell to a professional reseller established in another country, a shop or a wholesaler, that reseller is the producer, not you. The reasoning above applies to direct sales to the end customer.
You are in scope as soon as you sell packaged products, whatever the channel: your own site, Etsy, Amazon, Vinted Pro, markets with shipping. You are out of scope if you only sell services. And the PPWR covers sales inside the EU only: Switzerland, the UK and the United States run their own regimes.
Obligation 1: prove your packaging is compliant
Since 12 August 2026, packaging cannot circulate on the European market without its file. That means technical documentation and a declaration of conformity covering composition, recyclability and restricted substances. Among those are PFAS, a family of very persistent fluorinated compounds, banned above certain thresholds in food contact packaging.
Good news: in the vast majority of cases, that file is not yours to build. As long as you buy your boxes, mailers and pouches from a supplier established in the EU, the supplier produces those documents and keeps them available for the authorities.
Your job comes down to four moves:
- Check where the company selling you the packaging is established, not where its warehouse sits.
- Archive every packaging invoice in one place. That is your proof that compliance rests on someone else.
- If you sell food, ask for a food contact compliance statement that mentions the absence of PFAS.
- If you import directly from outside the EU, obtain the full technical documentation from the manufacturer, or switch suppliers.
Ordering your packaging from an Asian marketplace makes you the importer of that packaging. The whole file lands on you: composition, restricted substances, recyclability, food contact. For a one-person business, moving to a European supplier almost always costs less than assembling that file.
Stock bought before 12 August 2026 can be used up normally, except in food. There, sales packaging counts as placed on the market at the moment you fill it. A batch bought before the date but filled after it has to respect the PFAS limits, so ask your supplier for the statement before you empty the box.
Reused shipping cartons follow the same logic: their original manufacturer took on compliance when the packaging was first placed on the market. Reporting is a different story. What triggers the eco-contribution is the packaged product you sell, not where the cardboard came from. A free box gets declared exactly like a new one.
Obligation 2: register as a producer, country by country
This is the heart of the text. You have to appear on the producer register of every country you sell into, with no minimum threshold. That file lets each state track the packaging circulating on its territory, and send the eco-contribution invoice to the right address.
In France, the IDU does the work
If you sell packaged products to consumers in France, you join a producer responsibility organisation, the approved body that collects contributions and funds sorting (Citeo or Léko). In return you receive a unique identifier, the IDU, which counts as registration in the French register held by ADEME.
For small volumes, Citeo offers an annual flat fee below 10,000 sales units, advertised at €110 excluding VAT at the time of writing. Signing up online takes about fifteen minutes. Check the current price on the organisation's site before you budget.
Elsewhere, three situations coexist
In theory, every member state keeps an equivalent register, open to foreign sellers, in a format harmonised at EU level. In practice, no. States get 18 months from the entry into force of the European implementing act to open those new-format registers. That act had not been published as of autumn 2026, so the countdown has not started.
Rather than learning 27 national rulebooks, sort the countries you sell into three groups.
| Group | Countries | What you do |
|---|---|---|
| 1. Compliant from the first parcel | Germany, Austria, Spain, Portugal, Greece, Finland, Italy, Belgium | Register and join a scheme now, starting with your biggest volume |
| 2. Protective thresholds | Netherlands (50 t/year), Ireland (roughly 10 t and €1M in local turnover), Czechia, Malta, Estonia | Track your volumes so you can prove you sit below the threshold |
| 3. Register not open yet | A good share of the 27 | Log shipments by country and by quarter, sign up when the portal opens |
Inside group 1, Germany comes first. Its LUCID packaging register is free, you can sign up yourself with no intermediary, it has been mandatory since 2019, and marketplaces genuinely check it. After registering, you join a collection scheme, billed at a few tens of euros a year for small volumes. Italy is the exception in this group: you join the national body CONAI directly, with no intermediary imposed. In Belgium, joining Fost Plus counts as registration since the 300 kg threshold disappeared.
The group 2 thresholds are out of reach for a solo business. At 50 tonnes of packaging a year, assuming 200 g of cardboard per order, that works out at roughly 250,000 parcels. The real work in those countries is keeping count, not registering.
Two rules worth memorising. Once a country opens its harmonised register, registration is due from the first packaged product, even if that country applied a threshold before. And below 10 tonnes of packaging a year, Article 44 of the regulation allows a simplified declaration: registration still applies, but the annual paperwork gets lighter.
Obligation 3: the authorised representative, and its bill
In every EU country where you sell without being established, the regulation requires an authorised representative for extended producer responsibility. Behind that title sits a local company that registers on your behalf, files your declarations and answers the authorities during an inspection.
Budget €300 to €400 per country per year, on top of eco-contributions. There is no single EU-wide portal.
Selling in five countries can therefore mean five representatives, so €1,500 to €2,000 a year in admin fees before a single packaging contribution is paid. This is the line that pushes many small sellers to give up on selling across EU borders.
Two things soften the picture. The obligation did not appear with the PPWR: around ten countries, including Spain, Austria, Portugal and Greece, already required a representative before August 2026. And many states have not built the appointment mechanism yet. Where there is no portal, there is nothing to do.
The European Commission proposed in December 2025 to suspend this obligation until 2035 for companies established in the EU. The European Parliament was still examining it in autumn 2026 and could narrow it to micro and small businesses. Until something is voted, treat the obligation as applicable, and check where the file stands before you sign with a provider.
Marketplaces are the real enforcement
No European inspector will knock on your door. Since 12 August 2026, the platforms are the ones required to verify that their sellers are registered in the countries they ship to. So the penalty rarely looks like a fine. It looks like a frozen shop until the number shows up.
What to keep within reach:
- Your French IDU, filled in on the seller account (Seller Central compliance section on Amazon, shop settings on Etsy).
- Your foreign numbers for the group 1 countries you sell into, German number first.
- A log of the countries you actually shipped to, not the ones you might sell to one day.
Never let a platform warning sit unanswered, because the deadlines they announce get enforced. Amazon also offers, in some countries, to settle eco-contributions on your behalf through a pay-on-behalf programme. The cost often exceeds joining a scheme directly, so compare before you switch it on.
Handing enforcement to the platforms is becoming Brussels' default method. The Digital Markets Act took the same route when it pushed Apple to rework its App Store commission rates in Europe.
The tracking sheet that saves you
If you sell from your own site, nobody will automatically block your Shopify or WooCommerce store. The discipline is entirely on you. One tab in your sales spreadsheet is enough, with four columns: destination country, number of orders or estimated packaging weight, country group, action needed.
The aim is to be able to say, at any moment: here is where I sold, here are my volumes, here is why I am registered or not. The day a register opens, you regularise with a history behind you instead of starting from scratch.
That log fills itself very nicely. An automation that listens for new orders, pulls the delivery country and adds an average packaging weight does the job without you. That is exactly the kind of chain you build with an automation tool like n8n.
The timeline through 2030
| Date | What applies | Who it affects |
|---|---|---|
| 11 February 2025 | Regulation enters into force | Nobody yet, transition period |
| 12 August 2026 | Packaging compliance, registration, authorised representative, marketplace checks, PFAS ban in food contact packaging | Every seller of packaged products |
| Date not set | Opening of the harmonised national registers, 18 months after the European implementing act enters into force | Member states, and you, to sign up |
| 12 February 2027 | National penalties notified to the Commission | Member states |
| 2028 | Harmonised labelling, identical sorting symbols across the EU | Packaging manufacturers |
| 12 February 2028 | Empty space in sales packaging reduced to the necessary minimum | You, if you fill boxes, pouches or gift sets yourself |
| 1 January 2030 | Harmonised recyclability criteria, recycled plastic content, ban on certain formats, maximum 50% empty space in shipping parcels | Manufacturers, and marginally shippers |
Most of the 2028-2030 deadlines land on the companies that make packaging, not on those who fill it. Two lines still point straight at you: the empty space reduction in February 2028, and the empty space cap in parcels in 2030.
The 50% cap does not mean "half empty is fine everywhere". It applies to shipping parcels, with an exemption when the sales packaging doubles as the shipping box. Sending a product in its own box, with no outer carton, keeps you out of scope.
Frequently asked questions
Does the PPWR apply if I ship fewer than 100 parcels a year?
Yes. Regulation (EU) 2025/40 sets no minimum threshold for the registration obligation: you are a producer from the first packaged product sold to an end customer in an EU country. Some states still apply national thresholds, such as the Netherlands with 50 tonnes of packaging a year, but those thresholds are due to disappear.
Do I have to build the compliance file for my boxes myself?
No, provided your packaging supplier is established in the European Union: the supplier produces the technical documentation and the declaration of conformity, and keeps them available for the authorities. Just keep your invoices. If you order your packaging from outside the EU, you become the importer and the full file lands on you.
How much does an authorised representative cost to sell in another EU country?
Budget €300 to €400 per country per year, on top of eco-contributions, with no single EU-wide portal. The European Commission proposed in December 2025 to suspend this obligation until 2035 for companies established in the EU, but the text was still under examination in the European Parliament as of autumn 2026.
Is my French IDU enough to sell in Germany?
No. The unique identifier issued through a French producer responsibility organisation counts as registration in the register held by ADEME, in France only. For Germany you have to sign up to the LUCID register, which is free and accessible without an intermediary, then join a German collection scheme. Marketplaces have been checking that number since 2019.
What do I do if the country I ship to has no register yet?
You keep selling. Where no portal exists for foreign sellers, you cannot register even if you want to. Log your shipped volumes by country and by quarter, then sign up when the register opens. That record lets you regularise cleanly and show you acted in good faith.