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.

9 MIN READ · UPDATED 7 JUNE 2026

Ask any EU-shipping ecommerce operator "are you compliant?" and the honest answer is "with what?". EU product-compliance obligations land per regime and per SKU. A 10,000-SKU catalogue selling into 27 Member States is simultaneously in six regulatory regimes — GPSR, EU Responsible Person, EPR, PPWR, EmpCo, and (from 2027) DPP — each with different scope, different enforcement, and different timelines.

"Compliance" as a single binary verdict is not a meaningful unit of analysis. Readiness as a per-SKU, per-regime score is.

This guide describes the readiness framework Regonance uses across hundreds of catalogues: the five-layer model, the per-SKU scoring, the prioritisation pattern, and how to turn a regulatory backlog into a shippable engineering ticket list.

Why readiness, not compliance

Three structural facts make "are we compliant" the wrong question:

1. Per-SKU, not per-company. GPSR Article 9 / 19 attaches to every product sold. Two SKUs in the same shop can have different compliance states. The unit is the SKU, not the company.

2. Per-regime, not per-binary. A catalogue can be GPSR-clean and EPR-broken (or vice versa) at the same moment. Each regime needs its own score.

3. Per-deadline, not point-in-time. PPWR data capture is needed by 12 August 2026; PPWR recyclability thresholds bind in 2030. Both are "PPWR readiness" but the work is different and the prioritisation is different.

A readiness framework that ignores any of these three produces either a false-sense-of-security score (catalogue-level "we are compliant") or a false-alarm score (everything is red because the 2030 obligations are not yet met).

The five-layer readiness model

Readiness across an ecommerce catalogue lives in five layers, top-down:

Layer 1 — Listing layer. What the consumer sees before purchase. GPSR Article 19 (manufacturer, EU RP, warnings, model). EmpCo claims (green-claim language audit). Marketplace-specific attribute fields (Amazon Manufacturer Contact, Etsy Responsible Person). Highest signal-to-noise: verifiable from outside the supply chain by opening the listing.

Layer 2 — Product layer. What is physically on the product or its packaging. GPSR Article 9 (manufacturer + EU RP marking). CE marking and category-specific pictograms. Batch/serial identifier. PPWR packaging mark. Requires fulfilment-side change, not just listing-side change.

Layer 3 — Documentation layer. The technical file behind the SKU. Bill of materials, supplier-per-component, substance declarations, test reports, EC declaration of conformity, risk assessment under GPSR Article 9(7). This is what an authority asks for when they write in.

Layer 4 — Operational layer. The processes around the SKU. Incident-response plan (GPSR Article 9(8) — duty to notify Safety Gate). Recall and corrective-action procedures. Customer-complaint intake (GPSR Article 9(9)). EPR per-country reporting calendar. EU RP escalation path.

Layer 5 — Catalogue layer. Coverage across the SKU base and across the marketplaces. Per-country EPR registration status. Per-marketplace seller-account health. Onboarding workflow for new SKUs (do they enter the catalogue with the readiness already in place, or as a backlog item to fix later?).

Each layer is where a different failure mode bites: Layer 1 failures get you delisted by marketplaces; Layer 3 failures get you fined by authorities; Layer 5 failures compound silently into the next product launch.

Per-SKU scoring

For each SKU, score each applicable regime 0–100:

0 — no evidence captured, regime obligation unmet.
25 — partial data captured, gaps in critical fields.
50 — primary fields captured, secondary fields and substantiation missing.
75 — complete dataset captured, dated provenance present, output not yet generated.
100 — complete, dated, evidenced, output rendered (technical file, Article 19 block, EPR report, EmpCo claim ledger, DPP passport).

Weight by regime severity at the current date:

GPSR / EU RP — enforcement active since 13 Dec 2024. Highest weight.
EPR — per-country, enforcement varies (Germany / France high, others moderate). High weight.
EmpCo — enforcement from 27 Sep 2026. Rising weight through 2026.
PPWR — main application 12 Aug 2026 (data capture and minimisation); 2030+ thresholds (recyclability). Rising weight.
DPP — batteries 18 Feb 2027; textiles 2027–2029. Forward-looking weight.

Aggregate per-SKU, then per-collection and per-marketplace. The headline is the aggregate; the drill-down is the per-SKU per-regime grid that operations actually fixes against.

The prioritisation pattern

Three rules in order:

Rule 1 — Fix the listing layer first. Article 19 is enforced by marketplaces, visible from outside, and uses data needed for every other regime. Closing it across the catalogue is the highest-leverage move.

Rule 2 — Fix the per-country EPR registrations before scaling the geography. EPR is the most fragmented regime — 27 different national registers and reporting calendars. Adding a new destination country without the EPR registration in place is creating compliance debt.

Rule 3 — Capture the data ahead of the deadlines, render the output at the deadlines. PPWR data is capturable in 2026 even if the recyclability thresholds bind in 2030. EmpCo substantiation is capturable now even if enforcement starts 27 Sep 2026. DPP per-SKU datasets are capturable now even though the textiles delegated act is 2027–2029.

The pattern: one captured dataset, multiple rendered outputs, against escalating deadlines.

Turning a regulatory backlog into a ticket list

A readiness audit that produces a 300-page PDF is a worse outcome than no audit. The deliverable that actually ships is a per-SKU ticket list:

SKU. GTIN or internal identifier.
Regime. GPSR | EU RP | EPR-DE | EPR-FR | PPWR | EmpCo | DPP.
Gap. Specific missing field or output (e.g. "EU RP address not populated in Shopify metafield", "FR EPR identifier missing for textile stream").
Owner. Engineering | operations | legal | supplier-facing.
Effort. S / M / L (single-SKU fix vs cross-cutting catalogue change vs supplier engagement).
Deadline. Specific date (regulatory deadline or marketplace-enforcement deadline).
Evidence. Where the substantiation will be stored once captured.

This is a ticket list, not a report. Operations imports it into Linear, Jira, Notion, or whatever the team runs. Compliance becomes a velocity metric, not a memo.

Reading the score

A few patterns from running this audit across hundreds of catalogues:

A score under 30 across the listing layer means the catalogue is at active delisting risk. Marketplace sweeps will catch it before authority enforcement does.
A score under 30 across the documentation layer with a high listing-layer score means the brand has the front-end right but the technical file is empty — the moment an authority writes in, the response cannot be produced.
A high catalogue score with low new-SKU readiness means compliance debt is being created with every product launch. The fix is at the SKU onboarding flow, not at the back end.
Per-marketplace divergence — high score on Shopify, low on Amazon — typically means the catalogue is managed in one system and the marketplace listings are out of sync. The fix is a single source of truth that pushes to every channel.

How Regonance helps

Regonance is the readiness operations platform: per-SKU, per-regime scoring across the five layers; the gap-to-ticket conversion automated; outputs rendered (Article 19 block, GPSR technical file, EU RP register, per-country EPR pack, EmpCo claims ledger, PPWR packaging inventory, DPP passport) from a single dataset; reassessment on every catalogue change so the score reflects today, not the audit date. The Growth plan sizes for under-500 SKU catalogues; Pro for 500–5,000; Agency for multi-brand operators.

Glossary

SKU. Stock-keeping unit — the per-product identifier on which obligations attach.

Readiness score. A 0–100 measure of how complete the evidence base is for a specific regime on a specific SKU.

Article 19 block. The listing-side disclosure required by GPSR Article 19: manufacturer, EU RP, warnings, sufficient product identification.

Five-layer model. Listing → product → documentation → operational → catalogue.

Compliance debt. Obligations created by adding SKUs or geographies without the corresponding readiness work, compounding into future remediation cost.

Educational information, not legal advice. The readiness framework is an operational pattern, not a substitute for qualified compliance counsel on contested questions.

Frequently asked questions

Why isn't 'compliance' a single yes/no answer?+

Because EU product-compliance obligations attach per regime and per SKU, not at the company level. A catalogue with 10,000 SKUs sold across 27 Member States faces six live regimes (GPSR, EU RP, EPR, PPWR, EmpCo, DPP) — each with different scope, different enforcement, and different timelines. Asking 'are we compliant?' produces no actionable answer. Asking 'for each SKU, which regimes apply and which evidence is missing?' produces a prioritised backlog an operations team can ship against.

What is the highest-leverage place to start?+

Article 19 of GPSR — the listing block (manufacturer, EU Responsible Person, warnings, sufficient product identification). It is verifiable from outside your supply chain in seconds, it is what marketplaces (Amazon, Etsy, eBay) are already enforcing, and the data needed to populate it is needed for every other regime. Fix Article 19 across the catalogue first, then move outward.

How do you score a catalogue's readiness?+

Score per-SKU on each applicable regime (0–100), weight by regime severity (active enforcement now scores higher than 2030 obligations), aggregate to a per-SKU readiness score, and roll up to a per-collection and per-marketplace score. The aggregate is the headline; the drill-down is what teams actually fix against.

Which regimes are 'live now' versus 'coming'?+

Live now (Q2 2026): GPSR Article 19 (since 13 Dec 2024), EU Responsible Person designation (same date), EPR per-country registrations (varies, mostly live). Landing in 2026: PPWR main application (12 Aug 2026), EmpCo enforcement (27 Sep 2026). On the 2027+ horizon: DPP battery passport (18 Feb 2027), DPP textiles (2027 delegated act, applicability 2028–2029).

How long does a readiness audit take?+

For a single-country catalogue with under 100 SKUs, a first-pass readiness audit is a 1–2 week effort. For a multi-country catalogue with 1,000+ SKUs, it is a 4–8 week structured project. The fixed cost is the data model and the per-regime ruleset; once those exist, scoring is automatable and repeatable.

Is this the same as an ISO 14001 or an SA8000 audit?+

No. ISO 14001 (environmental management) and SA8000 (social accountability) are voluntary management-system certifications. Ecommerce compliance readiness is an assessment against binding EU regulations — GPSR, EmpCo, PPWR, EPR, DPP — with the explicit goal of producing the evidence those regulations require, not a certificate.

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AI-assisted informational guidance. Not legal advice. Consult qualified counsel for your specific situation.