What is Extended Producer Responsibility (EPR)? The EU's per-country register/report/pay regime, in plain English

EPR makes the company placing a product on the market financially responsible for its post-consumer stage. It runs per-country and per-stream — packaging, WEEE, batteries, textiles — with marketplace delisting now the sharpest enforcement lever. Here's what it actually is.

EU Responsible Person (EU RP): who needs one, what they actually do, and how to designate one

An EU Responsible Person is the EU-established economic operator that authorities can reach when a non-EU brand sells into the Union. Since 13 December 2024, every covered consumer product placed on the EU market must have one named on the listing, the product, or the packaging. Here is what the role does, who needs it, and what to put in place this quarter.

GPSR for Shopify sellers: the Article 19 block, the EU Responsible Person, and what changes for every EU-shipping store

Shopify is not a marketplace under GPSR Article 22 — which makes the seller, not the platform, responsible for Article 19 compliance on every listing. Here is the exact listing block, the EU Responsible Person requirement, the theme-template change, and the per-region catalogue audit every Shopify store needs to run for the EU 27.

What is a Digital Product Passport (DPP)? The EU's per-SKU data record, in plain English

The Digital Product Passport is the structured digital record the EU is rolling out under ESPR — batteries first (Feb 2027), textiles next, then most physical product categories through 2030. Here's what it actually contains, who has to issue one, and what to do this quarter.

What is GPSR? A plain-English overview

The EU General Product Safety Regulation has been enforceable since 13 December 2024. Here is what it actually changes for online sellers — the obligations, the dates, and the practical baseline.

What is REACH SVHC? The 0.1% w/w per-article threshold and Article 33 communication duty, in plain English

REACH — Regulation (EC) 1907/2006 — requires anyone supplying an article in the EU that contains a Substance of Very High Concern above 0.1% w/w per article to (a) communicate sufficient information up the B2B chain under Article 33(1), (b) respond to consumer requests within 45 days under Article 33(2), and (c) notify the ECHA SCIP database. The Candidate List is updated by ECHA roughly each January and June — every update can pull new substances into your existing products.

What is CE marking? The EU self-declaration that lets you place a product on the market

CE marking is the manufacturer's declaration that a product meets every applicable EU product directive — Toy Safety, LVD, EMC, RED, PPE or Machinery, in most ecommerce cases. It is self-declared (Module A) for non-Annex-IV products, but you must hold a technical file and a signed EU Declaration of Conformity (EN ISO/IEC 17050-1) for ten years. Amazon EU has intensified DoC requests since August 2025 and delists ASINs that cannot produce one.

What is EmpCo? The EU's anti-greenwashing law, in plain English

EmpCo — Directive (EU) 2024/825 — is the live EU law banning vague eco-claims, offset-based 'carbon neutral' product claims and unverified sustainability labels. Enforcement starts 27 September 2026. Here's what it actually does.

What is the EU Right to Repair Directive? Plain-English overview of (EU) 2024/1799

The Right to Repair Directive — (EU) 2024/1799 — forces manufacturers of regulated product categories (washing machines, dishwashers, fridges, vacuum cleaners, smartphones, tablets and the categories ESPR expands to) to repair on request, offer spare parts and tools at a non-discriminatory price, and provide an indicative repair price up front using the standardised European Repair Information Form (Annex I). Repaired products get a 12-month warranty extension. Member states must apply the directive by 31 July 2026.

What is PPWR? The EU's directly-applicable packaging law, in plain English

PPWR — Regulation (EU) 2025/40 — is the EU's new packaging law. Same text in all 27 member states. General application starts 12 August 2026, with tightening milestones through 2038. Here's what it actually does.

GPSR on Amazon EU: the Manufacturer Contact attribute, the EU Responsible Person field, and how Seller Central enforces Article 22

Amazon is the EU's largest GPSR enforcer. The Manufacturer Contact and Responsible Person attributes in Seller Central are mandatory on covered listings since 13 December 2024, and Amazon delists non-compliant ASINs automatically. Here is what each field expects, the per-marketplace differences, and the audit every Amazon EU seller needs to run this quarter.

Non-EU seller obligations: the actual EU compliance stack for brands shipping into the Union from outside

If you sell physical consumer products into the EU from outside it, six regimes attach to every order: GPSR, EU Responsible Person, EPR, PPWR, EmpCo, and (from 2027 onwards) DPP. Here is the full obligation stack, the deadlines that are already live, and the operational checklist for 2026.

Banned green claims under EmpCo: the six practices to remove from your marketing

Under Directive (EU) 2024/825, six specific marketing practices are banned outright across the EU 27 from 27 September 2026 — no balancing test, no defence. Here are the six, with concrete before/after examples.

PPWR packaging requirements: the seven checks every EU seller must pass

PPWR (Regulation (EU) 2025/40) imposes seven concrete packaging requirements that phase in between 12 August 2026 and 2038. This guide walks each check with what is enforceable now versus what to capture for upcoming milestones.

EPR registration by country: the EU 27 register/report/pay map sellers actually need

EPR is implemented per member state — LUCID, ADEME, CONAI, Verpact and 24 others. Here's how the national registers work for packaging, WEEE, batteries and textiles, what PPWR Art. 44 changes from 12 August 2026, and where non-EU sellers need an Authorised Representative.

DPP for textiles: what sellers should track now

The Digital Product Passport lands on textiles before most other categories. Here is what fashion and apparel sellers should be capturing in 2026 to be ready.

Seller responsibilities under GPSR

GPSR assigns specific duties to manufacturers, importers, distributors and fulfilment providers. This guide maps the obligations to the role you actually play — and what 'documented' means when an authority asks.

Required product information under GPSR

GPSR Article 19 lists the information online sellers must surface before checkout — manufacturer details, Responsible Person, identifiers, warnings, safe-use instructions. Here is what each field really means in practice.

EPR for online sellers: how marketplaces enforce it, and what gets your listings delisted

For e-commerce sellers, the sharpest EPR risk in 2026 isn't national fines — it's marketplace delisting under the Digital Services Act. Here's how Amazon EU, Otto, Bol.com and others enforce EPR, what pay-on-behalf actually costs, and how to pre-empt suspension.

PPWR for e-commerce sellers: the parcel, the marketplace, and what changes 12 August 2026

PPWR explicitly covers e-commerce packaging and names online marketplaces as responsible actors. From 12 August 2026, the shipping box, mailer and polybag are in scope — and listing-level enforcement is the sharpest stick. Here's the practical guide.

GPSR for Etsy sellers: handmade is not exempt, the Responsible Person field, and what changes for makers shipping into the EU

Etsy is a marketplace under GPSR Article 22, and 'handmade' carries no exemption from the General Product Safety Regulation. Since 13 December 2024, every Etsy listing shipped into the EU 27 must carry manufacturer, Responsible Person, and warnings — and Etsy delists listings missing them. Here is what an Etsy shop actually needs to do.

EmpCo for fashion and textile brands: the highest-risk sector, mapped to the six bans

Fashion is the most-scrutinised sector under EmpCo. Generic 'sustainable' collections, offset-based 'climate neutral' garments, and self-made eco-badges are squarely in the banned set. Here's the sector-specific playbook for 2026.

DPP and product traceability: the supply-chain data work the passport actually demands

The Digital Product Passport is a traceability instrument before it is a consumer-facing artefact. Here's the data chain — identifier, components, suppliers, substances, country of origin, evidence — that any DPP under ESPR or the Batteries Regulation will demand, and how to start capturing it now.

GPSR for online marketplaces

GPSR Article 22 layers product-safety duties on top of the Digital Services Act. Here is what online marketplaces must now do, and what sellers should expect from the platforms they list on.

Common GPSR mistakes online sellers make

After a year of GPSR enforcement, the same gaps appear over and over in marketplace suppressions and national-authority findings. Here are the seven most common — and what a clean fix looks like.

Ecommerce compliance readiness: the per-SKU, per-regime readiness framework for EU-shipping catalogues in 2026

EU compliance is not a single 'are we compliant?' verdict — it is a per-SKU, per-regime readiness state across GPSR, EU RP, EPR, PPWR, EmpCo and DPP. Here is the five-layer framework, the per-SKU score that drives prioritisation, and the catalogue-audit pattern that turns a regulatory backlog into a shippable engineering ticket list.

Battery labelling requirements 2026–2027: what must be on your product

The Annex VI markings have applied since August 2026 and the QR code becomes mandatory on 18 February 2027. Exactly what has to appear on the battery, the packaging or the documentation — capacity, chemistry, hazardous substance symbols, collection symbol, size rules — and how it differs from GPSR traceability marks.

What is the Digital Battery Passport and how to prepare before February 2027

A full battery passport is required for LMT, industrial over 2 kWh and EV batteries — not for portable consumer cells, which get a QR code instead. What the passport contains under Article 77, why it is a supplier-data problem rather than a software problem, and a preparation plan by battery category.

Amazon flagged my listing for battery non-compliance — how to fix it

Amazon validates battery producer registration numbers at listing level for EU offers, and Germany's BattDG makes it a hard gate. What the platform checks, an eight-step route back to active, the five mistakes that cause suspensions, and how to stop it happening on your next launch.

Battery EPR registration: which EU countries require it and how to register

Battery producer registration is national, not EU-wide. Germany's BattDG register at the UBA, France's ADEME identifier, and the requirements in the Netherlands, Spain, Italy, Austria and Sweden — plus the authorised representative rule and why one product can need packaging, battery and WEEE registration in the same country.

The removable battery rule: what changes for product design from February 2027

From 18 February 2027, portable batteries in consumer products must be removable and replaceable by the end user under Article 11. What that means mechanically, which product categories are affected, why the wet-environment exemptions are narrower than sellers assume, and how the transition treats stock already on the market.

Non-EU seller? Your battery obligations in the European market

If you sell products containing batteries into the EU from the UK, US, China or anywhere outside the bloc, you are the legal producer of those batteries. The producer definition, the per-country authorised representative mandate, registration, verifying supplier labelling before you import, and a 30-day plan.

The complete GPSR compliance checklist for e-commerce sellers

A working checklist for GPSR: establishing your role, the technical file, a real risk assessment, traceability and batch numbering, listing information duties, language requirements, incident reporting through the Safety Business Gateway, and recall mechanics — plus the five failures that actually cost sellers money.

EPR registration: which countries require it and how to register

Extended Producer Responsibility is still national. Germany's LUCID, France's ADEME identifier and Citeo, Spain's producer register and plastic tax, Italy's CONAI and environmental labelling, and the Netherlands packaging fund — plus a six-step method for working out what you owe and where.

What is the EU Battery Regulation and who does it affect?

Regulation (EU) 2023/1542 covers batteries sold alone, inside products or with products — so most consumer electronics brands are battery producers. What already applies (registration, take-back, labelling, removability) and what the February 2027 digital battery passport will require.

EU Digital Product Passport: what brands need to know before 2027

Under the Ecodesign for Sustainable Products Regulation, product data moves from paper files to structured, machine-readable passports with tiered access. What a passport contains, which categories come first, why it is a data problem rather than a document problem, and what to organise during 2026.

PPWR is live: what EU packaging rules mean for your products right now

The EU Packaging and Packaging Waste Regulation applied from 12 August 2026, with no grace period for existing stock. Here is what is binding today — conformity documentation, PFAS and heavy metal limits, the 40% empty-space cap, recycled content declarations, Article 12 labelling and packaging EPR — and what arrives between 2028 and 2030.

EmpCo enforcement begins September 27: what your brand needs to do this week

From 27 September 2026, national rules implementing the EmpCo Directive apply to environmental claims. Banned outright: generic green adjectives, whole-product claims from one attribute, offset-based carbon neutrality and self-made sustainability labels. A five-day plan to clean up every claim you publish.

Selling to the EU from the UK? GPSR means you need a Responsible Person

Post-Brexit, a UK company is not established in the EU — so under GPSR Article 16 your products need an EU-based Responsible Person, named in every listing. What the role covers, who can hold it, how to appoint one, and why marketplaces suppress listings long before any authority calls.

EU product compliance for cosmetics and personal care brands

Cosmetics sit under more overlapping EU rules than almost any category: Regulation 1223/2009 plus GPSR for accessories and devices, PPWR and national EPR for packaging, EmpCo for environmental claims, and REACH and CLP for substances. A category map, plus the gaps we see most often in real catalogues.

EU compliance for textile and apparel sellers: the full 2026 regulatory stack

Textiles and apparel are among the most regulated product categories in the EU — and the regulatory burden is increasing. A textile seller entering the EU market in 2026 faces obligations under at least six overlapping regulations, with more arriving through the ESPR framework. This guide maps the complete regulatory stack for textile products, explains what each regulation requires, and identifies where the obligations overlap.

EU compliance for electronics sellers: CE, WEEE, RoHS, batteries, and DPP

Electronics and electrical products carry the heaviest regulatory burden of any consumer product category in the EU. A single electronic product can fall under six or more EU regulations simultaneously — each with its own documentation, labelling, registration, and reporting requirements.

EU compliance for cosmetics sellers: what is different from GPSR

Cosmetics are a special case in EU product compliance. The Cosmetics Regulation (EC 1223/2009) is a standalone, comprehensive framework that predates GPSR and operates alongside it. Cosmetics sellers face a distinct set of requirements — including their own "Responsible Person" role that is different from the GPSR EU Responsible Person — and getting the two confused is one of the most common compliance mistakes in this category.

EU compliance for toy sellers: safety, CE marking, and the updated Toy Safety Regulation

Toys are one of the most strictly regulated product categories in the EU. The existing Toy Safety Directive (2009/48/EC) sets comprehensive safety requirements, and the European Commission has adopted a new Toy Safety Regulation (published 2024) that will replace it with even stricter rules. If you sell toys in the EU — whether you manufacture them, import them, or resell them through marketplaces — you face a regulatory stack that combines product safety, chemical restrictions, CE marking, traceability, and marketplace enforcement.

EU compliance for furniture and home goods: REACH, GPSR, and product safety

Furniture and home goods occupy an unusual position in EU product compliance. Unlike electronics (which have CE marking directives) or cosmetics (which have a dedicated regulation), furniture has no single sector-specific EU regulation. Instead, compliance comes from the intersection of GPSR, REACH, flammability standards, PPWR, and — increasingly — ESPR sustainability requirements.

What is a Digital Product Passport and when does your product need one?

A Digital Product Passport (DPP) is a machine-readable digital record that consolidates essential information about a product's identity, composition, compliance, sustainability, and lifecycle. Mandated under the EU's Ecodesign for Sustainable Products Regulation (ESPR) — Regulation (EU) 2024/1781 — the DPP is intended to make supply chains more transparent, support circular economy objectives, and give consumers, regulators, and recyclers structured access to product information.

EU product compliance roadmap 2026–2030: every deadline in one place

EU product compliance is not a single event. It is a rolling series of deadlines — some already enforced, some weeks away, some years out. Missing one can mean listing suppression, customs refusal, fines, or product recalls. This roadmap consolidates every major EU product compliance deadline from 2026 through 2030 in one reference document.

The cost of EU product non-compliance: fines, delistings, and recalls in 2025–2026

Non-compliance with EU product regulations is no longer a theoretical risk. In 2025 and 2026, enforcement has accelerated across every channel — marketplace automated checks, customs interceptions, market-surveillance authority actions, and Safety Gate alerts have all increased significantly. The cost of non-compliance is no longer limited to a fine you might someday receive. It is listing suppression today, customs refusal tomorrow, and a recall notice next week.

EU compliance for US and UK brands: the complete market access guide

If you are a US or UK brand selling consumer products to EU buyers, 2024–2026 has fundamentally changed your compliance obligations. The General Product Safety Regulation (GPSR), the Packaging and Packaging Waste Regulation (PPWR), the Empowering Consumers Directive (EmpCo), and intensified marketplace enforcement mean that selling into the EU now requires structured compliance work that many non-EU brands have never done.

EU Battery Regulation: does your product need compliance?

If your product contains or comes with a battery — built-in, removable, rechargeable or disposable — Regulation (EU) 2023/1542 applies to you, even if you only import finished goods. Which products are in scope, the five battery categories, the producer and deemed-producer rules, and how battery duties sit alongside GPSR.

REVIEWED BY THE REGONANCE EDITORIAL TEAM

9 MIN READ · UPDATED 16 SEPTEMBER 2026

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Most sellers who are in scope of the EU Battery Regulation do not think of themselves as battery companies. They sell earbuds, kitchen scales, LED candles, ride-on toys, cordless drills, doorbell cameras, e-scooters. Somewhere inside the product, or in a blister pack beside it, there is a cell. That is enough.

Regulation (EU) 2023/1542 — the Battery Regulation — applies to batteries placed on the EU market, and it deliberately covers three situations: batteries sold on their own, batteries incorporated into products, and batteries supplied with products. There is no exemption for "I only sell the finished product". If a battery reaches an EU consumer because of something you sold, the regulation reaches you.

This article answers the scope question: is your product covered, which category does the battery fall into, and which obligations follow from that.

The simple test

Ask three questions about each product you place on the EU market.

Does it contain, or come with, a battery of any kind? Built-in or removable, rechargeable or single-use, coin cell or 60 Wh pack — all of it counts. A CR2032 in a bathroom scale is a battery under this regulation, and so is the AA pair taped to the back of a remote control.

Do you place it on the EU market? You place a product on the market the first time it is made available in the EU — importing it, or selling it directly to an EU customer from outside the EU.

Is it sold under your name, brand or trademark? If yes, you are treated as the manufacturer of that product for compliance purposes, whoever actually built it.

Two yeses put you in scope. Three yeses put you in scope as a producer carrying the full set of national registration and take-back duties.

Product categories that are almost always in scope

The regulation does not list products; it lists batteries. But in practice the categories where sellers are caught out repeat:

Consumer electronics — headphones, earbuds, speakers, cameras, e-readers, keyboards and mice, remote controls.
Wearables — smart watches, fitness bands, hearing aids, connected rings.
Portable power — power banks, jump starters, battery cases, portable solar chargers.
Toys — anything that lights up, moves, makes noise or connects, plus the loose cells in the box.
Power tools and garden equipment — drills, sanders, trimmers, robot mowers, and the spare battery packs sold as accessories.
Smart home and IoT — sensors, doorbells, thermostats, trackers, locks, cameras.
Kitchen and personal-care gadgets — scales, thermometers, milk frothers, electric toothbrushes, shavers, epilators.
Lighting — LED candles, torches, camping lanterns, decorative string lights, emergency lights.
Light means of transport — e-bikes, e-scooters, e-skateboards, mobility scooters.
Medical and measuring devices — blood pressure monitors, glucose meters, digital calipers.

If your catalogue includes anything in that list, treat battery compliance as a live obligation rather than a future project.

The five battery categories, and why the label matters

Your obligations follow the category of the battery, not the product it sits in. Article 3 defines five.

Portable batteries. Sealed, weighing 5 kg or less, not designed for industrial use and not an EV, LMT or SLI battery. This is the category almost all consumer product batteries fall into: coin cells, AA and AAA, the lithium pouch in a pair of earbuds, a power-bank cell. Portable batteries carry the registration, collection and take-back regime, the Annex VI labelling rules, and — from February 2027 — the removability requirement in Article 11 and a QR code carrying label information.

LMT batteries — light means of transport. Sealed batteries under 25 kg designed to provide traction for wheeled vehicles that can be powered by an electric motor alone or by a motor plus human power: e-bikes, e-scooters, e-mopeds in some configurations. LMT batteries carry a heavier set of duties than portable batteries, including a carbon footprint declaration and, from 18 February 2027, a full digital battery passport.

Industrial batteries. Batteries designed for industrial use, or any battery that is not portable, LMT, EV or SLI. Industrial batteries over 2 kWh carry the carbon footprint declaration, performance and durability requirements, and the battery passport.

Electric vehicle (EV) batteries. Batteries designed for traction in category L, M, N or O vehicles. Full passport, carbon footprint, recycled content targets, due diligence.

SLI batteries. Starting, lighting and ignition — the conventional 12 V lead-acid battery in a car, plus the equivalents in vans and machinery.

The single most common mistake is assuming that "battery passport" applies to everything. It does not. Portable consumer batteries do not get a full passport; they get a QR code that resolves to label information and the declaration of conformity. If you sell earbuds, your February 2027 problem is labelling, QR codes and removability — not a passport data model.

"I don't make batteries, I just import products with batteries inside"

This is the objection we hear most, and the answer is unambiguous: the regulation defines a producer by market placement, not by manufacture.

Under Article 3, a producer is any manufacturer, importer or distributor who, irrespective of the selling technique used — including distance contracts — supplies a battery, including one incorporated into appliances, light means of transport or other vehicles, for the first time within the territory of a Member State on a professional basis.

Read that clause slowly. "Including one incorporated into appliances" is there specifically to stop the argument that a company selling a finished product is not a battery producer. If you import a shipment of wireless mice from Shenzhen into Rotterdam, you placed the cells inside them on the EU market. You are the battery producer for the Netherlands, and for every other Member State you sell into you are the producer there too, with separate registration.

That producer status is what triggers the national obligations that cost money and take time:

Registration in each Member State where you make batteries available, in a national producer register (Article 55).
Extended producer responsibility — financing collection, treatment and recycling of the batteries you placed on that market (Article 56), usually by joining a compliance scheme.
Reporting volumes placed on the market, by chemistry and category.
Take-back obligations, and consumer information about collection.
An authorised representative in each Member State where you are not established (Article 57), if you are outside that country or outside the EU entirely.

None of this is delegated to your supplier by default. A factory in China is not registered in Germany on your behalf, and a contract clause saying "supplier warrants compliance" does not create a German registration number.

The deemed-producer rule for private label

If you place a product on the EU market under your own name or trademark, you carry the manufacturer's obligations for it, even though someone else built it. That is the same principle you already meet under the GPSR and under CE-marking legislation, and it applies here.

Practically it means you own the documents. The declaration of conformity for the battery has to name someone, and if the product is yours, that someone is you. The Annex VI markings have to carry a manufacturer identity, and it will be your identity. When a market surveillance authority or a marketplace compliance team asks for the battery type, chemistry, capacity and registration number, they ask you, not the factory.

Relabelling matters too. Buying a generic power bank and printing your logo on it converts you from distributor to manufacturer for that product. So does changing the cell, changing the charger specification, or repackaging in a way that changes the safety information.

Where this already bites: marketplaces and Germany

Enforcement is not theoretical. Germany's Batteriedurchführungsgesetz (BattDG) implements the regulation nationally and requires producers to be registered in the register operated by the Umweltbundesamt before making batteries available. Marketplaces are obliged to check, and they do: Amazon collects a battery registration number at listing level for German offers and suppresses listings without one. France, and progressively other markets, apply comparable checks.

The pattern is consistent with what happened for packaging EPR and for the GPSR: the regulation creates the duty, the marketplace turns it into a hard gate, and sellers discover both on the day a listing stops converting. Registering before you list costs a few hundred euros and some paperwork. Registering after suspension costs the same, plus the sales you lost while the ASIN was down.

How battery obligations intersect with your other EU duties

The same product usually sits under several regulations at once, and they do not substitute for one another.

GPSR (Regulation (EU) 2023/988). Governs general product safety, the technical file, traceability markings, the EU responsible person and the information shown in your listing. A battery-powered product needs both: GPSR traceability marks and Annex VI battery markings. They are different sets of information in different places, and one does not satisfy the other.

CE marking and sector legislation. A rechargeable device is usually also under the Low Voltage or Radio Equipment Directive, with its own conformity assessment. The Battery Regulation adds a separate CE-marking route for the battery itself.

WEEE. An electronic product with a battery generally needs both WEEE registration and battery registration in the same country. They are separate registers with separate numbers and separate fees.

PPWR and packaging EPR. The box the product ships in is a third registration. Sellers frequently hold a packaging EPR number, see "EPR registered" on their internal checklist, and assume batteries are covered. They are not.

Digital Product Passport. For batteries in scope of the passport, the February 2027 requirement arrives ahead of the wider ESPR passport waves and is the working template for them.

What to do this week

Pull your catalogue into a spreadsheet and add three columns: does it contain or come with a battery, what category is that battery, and which EU countries do you sell it in. That table is your scope assessment, and most sellers can complete it in an afternoon.

Then, for every row with a battery, confirm you hold four things: the battery chemistry and capacity, the Annex VI markings on the product or packaging, a national producer registration number for each market, and a written mandate with an authorised representative where you are not established. Those four are what enforcement asks for.

Educational information only, not legal advice. Category classification and national implementations vary — confirm your obligations with a qualified advisor.

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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.