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.

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.

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.

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.

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.

REVIEWED BY THE REGONANCE EDITORIAL TEAM

9 MIN READ · UPDATED 16 SEPTEMBER 2026

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From 18 February 2027, a portable battery inside a product sold in the EU has to come out. Article 11 of Regulation (EU) 2023/1542 requires portable batteries incorporated into appliances to be readily removable and replaceable by the end user, and products that fail that test cannot be placed on the EU market.

This is not a filing requirement. It is a design and sourcing constraint, and the products being specified now for 2027 inventory are the ones affected.

What Article 11 actually says

Two obligations, aimed at different battery types.

Portable batteries in appliances must be readily removable and replaceable by the end user. "Readily removable" means the battery can be removed with commercially available tools, without needing specialised tools — unless those are provided free with the product — and without needing proprietary tools, thermal energy or solvents to disassemble the unit. Manufacturers must supply instructions and safety information about removal and replacement, and make them available for the expected lifetime of the product, including online in a permanently accessible form.

LMT batteries, and batteries in light means of transport, plus industrial and EV batteries follow a different standard: removable and replaceable by an independent professional, not by the consumer. For an e-bike pack, the requirement is that a qualified independent technician can remove and replace it — including individual cells in some cases — not that the rider can.

There are two further points people miss. Software must not obstruct replacement: a product that refuses to work with a replacement battery of the correct specification does not meet the requirement. And spare batteries have to be available to end users for a period after the last unit of the model is placed on the market, at a non-discriminatory price.

Which products are affected

The categories where sealed batteries are the norm are exactly the categories where this bites.

True wireless earbuds, where cells are glued into each bud and into the case.
Smart watches and fitness bands with adhesive-bonded batteries behind pressed backplates.
IoT sensors and trackers — ultrasonically welded housings with soldered coin cells.
LED candles, decorative lighting and novelty electronics built as sealed units.
Low-cost consumer electronics where a soldered pouch cell saves a connector and a screw.
Electric toothbrushes, shavers, epilators — sealed for water ingress, historically with no service route.
Bluetooth speakers and portable audio with bonded packs.
Toys with soldered rechargeable packs.
Vapes and single-use electronics, which are separately in the crosshairs of national bans.

If you sell any of these, the practical question is not whether the rule applies. It is whether the units your supplier plans to ship in Q1 2027 can be opened by a customer with a household screwdriver.

What "removable by the end user" means in practice

Regulators have not published a torque figure, but the intent is clear enough to design against.

Commercially available tools. A Phillips or Torx screwdriver, a plastic pry tool. Not a heat gun, not a proprietary jig, not a solvent.

No destructive disassembly. If getting the cell out breaks the housing, or a clip, or a seal that cannot be re-made, the battery is not replaceable.

No soldering. A cell soldered to the board is the clearest failure case. A connector, a spring contact, or a battery holder is the fix.

No adhesive-only retention. Cells held solely by structural adhesive fail. Adhesive with pull tabs designed for removal, plus instructions, is the common industry answer.

Instructions that a consumer can follow. Written, available with the product and online, kept available for the expected lifetime, with the safety warnings a lithium cell warrants.

A replacement that is actually obtainable. A removable battery with no spare on sale is compliance on paper only.

The pragmatic design pattern converging across the industry is: one or two accessible fasteners, a serviceable seal or gasket, a connector rather than solder tabs, pull-tab adhesive where retention is needed, a labelled cell with matching spare part number, and a QR code on the product resolving to removal instructions — which also serves the February 2027 QR requirement.

The exemptions, and why not to rely on them

Article 11 provides narrow derogations. Broadly, a portable battery may remain non-removable where:

continuity of power supply is necessary and a direct connection between the appliance and the battery is required for safety, performance, medical or data-integrity reasons; or
the appliance is designed to operate in a wet environment, being specifically designed to be regularly washed, or to work in conditions that require ingress protection, or is a professional medical imaging or radiotherapy device.

Where a derogation applies, the battery must still be removable and replaceable by qualified independent professionals, and the product carries information about that.

Three cautions. First, the exemptions are read narrowly: "splash-resistant" is not "designed to be regularly washed", and an IP rating alone has not been treated as sufficient. Second, the exemption removes the consumer-removability duty, not the professional-removability duty — a fully potted assembly with no service route fails either way. Third, the burden of demonstrating the derogation sits with you, in your technical documentation, and a market surveillance authority will ask for the reasoning.

Assume you are in scope unless a lawyer has told you otherwise in writing.

What this means commercially

Three consequences worth planning for.

Sourcing lead time. A design change to add a fastener, a connector and a serviceable seal is a tooling change. Tooling changes run months, and your factory will not start until you ask. A product being quoted in autumn 2026 for spring 2027 delivery has to be specified for removability now.

Spare parts as a product line. You will need to sell replacement cells, which brings its own duties: the spare cell is itself a battery placed on the market, with Annex VI markings, a producer registration, and dangerous-goods handling for shipping. Many brands underestimate this second obligation entirely.

Warranty and support. A user-replaceable battery changes your returns picture — usually for the better, since a dead cell stops being a dead product — but it needs a support script, a part number, and instructions written for a non-technical customer.

What to put in a supplier brief

Suppliers respond to specifications, not to regulation names. A brief that works reads roughly like this.

The battery must be removable and replaceable by an end user using commonly available tools. No soldered or welded cell connections — use a connector, spring contacts or a holder. Retention must be mechanical or by pull-tab adhesive; structural adhesive alone is not acceptable. Fasteners must be standard drive types accessible without destroying the housing or any non-replaceable seal. Any gasket in the removal path must be re-usable or supplied as a spare. Provide the cell part number, the electrical and mechanical specification, and confirm the spare cell can be supplied for at least five years. Supply removal and replacement instructions in editable form, with safety warnings, plus a photographed teardown of the production unit. Firmware must accept any replacement cell meeting the specification.

Ask for a sample from tooling, not a prototype, and open it yourself. The gap between what a factory confirms in writing and what arrives in the first container is the risk you are managing.

How this interacts with your other obligations

Removability is not a standalone rule; it sits inside a set of duties that touch the same product.

QR code and label information. From the same February 2027 date, portable batteries carry a QR code giving access to label information, the declaration of conformity, removal instructions and collection information. The removal instructions Article 11 requires are the same instructions the QR code serves — write them once.

WEEE treatment. A separable battery is what allows the appliance and the cell to go into their correct end-of-life streams, which is the policy behind the rule.

GPSR. Replacement introduces a foreseeable-use scenario your risk assessment has to cover: a consumer handling a lithium cell. That means warnings, instructions and, in some categories, a keyed or shrouded connector so the cell cannot be fitted the wrong way round.

Spare parts as products. A replacement cell you sell is a battery placed on the EU market in its own right, with Annex VI markings, producer registration and transport classification of its own.

The transition: what happens to stock already out there

The requirement applies to batteries and products placed on the EU market from 18 February 2027. Placing on the market is the first making available in the EU, per unit.

That means: units already placed on the market before the date are not retrospectively non-compliant, and a retailer can continue to sell through existing stock that was lawfully placed on the market. But every unit you first make available in the EU on or after the date must comply — so a container arriving in March 2027 with glued-in cells is a problem, regardless of when you ordered it.

Two practical implications. Get your EU-inbound schedule and your compliant-design schedule on the same chart, and know exactly which shipment is the first that must comply. And keep the evidence: records showing when units were placed on the market are what defend legacy stock if anyone asks.

What to do now

Audit the range. For each battery-powered SKU: is the cell removable with common tools, is it connectored or soldered, is retention adhesive or mechanical, does a documented removal procedure exist, and is a spare available. Photograph a teardown of your top ten sellers — an afternoon of work that produces an unambiguous answer.

Write removability into supplier specifications. Not "must comply with EU regulations", which suppliers will sign and ignore, but the specific mechanical requirements: connector not solder, mechanical or pull-tab retention, fastener count and type, seal serviceable, spare part number available, removal instructions supplied.

Decide the fate of the failures. For each non-compliant SKU: redesign, replace with a compliant alternative, or sell out before the date. That is a commercial decision with a deadline, and it is better made in a planning meeting than in a customs hall.

Bundle it with the other February 2027 work. The QR code requirement lands on the same date and can carry the removal instructions Article 11 requires. Doing artwork, documentation and design in one pass is materially cheaper than three passes.

For the wider scope question, see our guide to whether your product needs battery compliance; for the labelling and QR code detail, see our battery labelling guide.

Educational information only, not legal advice. Derogations and their interpretation are narrow and fact-specific — confirm your position with a qualified advisor.

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