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.

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.

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.

8 MIN READ · UPDATED 7 JUNE 2026

EmpCo — Directive (EU) 2024/825 — works by adding specific marketing practices to the Unfair Commercial Practices Directive blacklist (UCPD Annex I). Items on the blacklist are banned with no case-by-case balancing test: the practice itself is the violation. From 27 September 2026, six new banned practices apply to every consumer-facing claim reaching the EU 27.

This guide walks each of the six with concrete before/after examples drawn from current EU marketing copy. Use it as a remediation checklist.

1. Generic environmental claims without substantiation

Banned: Generic terms — "eco", "green", "eco-friendly", "environmentally friendly", "climate friendly", "biodegradable", "eco-conscious", "natural", "nature-positive", "earth-friendly" — used without demonstrated, recognised and verifiable excellent environmental performance.

The bar is high on purpose. "Excellent environmental performance" means measurably better than the category baseline, with the underlying methodology and data available to a regulator.

Before: "Our eco-friendly packaging is better for the planet." After (substantiate): "Our packaging is 100% PCR cardboard certified under FSC Recycled (FSC-C123456), reducing virgin fibre use by 60% versus the category average." After (qualify): "Made from recycled cardboard." (factual, specific, no superlative)

The rule does not ban every nice word. It bans unsubstantiated superlatives. Specific, narrow, evidenced claims — "made from 100% recycled aluminium", "produced with renewable electricity at our Lisbon facility" — are fine.

2. Offset-based product-level carbon claims

Banned: "Carbon neutral", "climate neutral", "net zero", "CO2-positive", "climate-positive", "zero impact" applied to a product, where the basis is carbon offsetting rather than actual emissions reductions in the product's value chain.

This is the cleanest, sharpest rule in EmpCo. There is no scheme-quality exception: even Verra-certified, high-additionality, vintage-2024 nature-based offsets cannot rescue a product-level "carbon neutral" claim. Only in-value-chain reductions (renewable energy at your factory, lower-carbon materials, redesigned logistics, supplier emissions cuts) count.

Before: "This T-shirt is climate neutral — every emission offset through verified reforestation projects." After (substantiate, actual reductions): "This T-shirt's cradle-to-gate emissions are 38% below the 2022 baseline through GOTS-certified organic cotton and 100% renewable-electricity wet processing." After (remove): "This T-shirt: 4.2 kg CO2e cradle-to-gate." (transparent, no neutrality claim)

What is still allowed: Company-level "we offset our operational emissions" is not banned by this specific rule, but if misleading remains exposed to the general unfair-practices regime. Disclose the methodology and the boundary.

3. Sustainability labels not backed by a recognised scheme

Banned: Use of any sustainability label, badge or seal that is not based on a certification scheme or not established by public authorities.

This catches self-created eco-badges, unverified seals, in-house "Conscious", "Eco Choice" or "Green" labels, and any badge designed to look like a third-party certification but lacking the scheme behind it.

Recognised examples (non-exhaustive, EU/global):

EU Ecolabel (Commission Regulation (EC) 66/2010)
EU Organic
FSC and PEFC (forest)
GOTS, OEKO-TEX, GRS, RCS, Cradle to Cradle (textiles and materials)
Energy Label (EU 2017/1369)
B Corp (independent scheme; covers governance, not a product mark)

Before: A green leaf badge on the product page with the words "Eco Choice" and no further context. After (remove): Delete the badge. After (replace): Replace with the GOTS logo + certificate number + "Certified organic cotton, GOTS-2024-A1234".

4. Future environmental performance claims without a credible plan

Banned: Future commitments — "climate neutral by 2030", "100% recycled by 2027", "carbon negative by 2035", "fossil-free by 2040" — without clear, objective, publicly available, independently verified commitments set out in a detailed, realistic implementation plan with measurable, time-bound targets.

The verification bar is high. An internal sustainability roadmap is not a plan in EmpCo's sense. The plan must be publicly available (link on the corporate site, not a board deck), independently verified (third party, ideally SBTi-validated for science-based targets), with measurable interim milestones.

Before: "We will be climate neutral by 2030." After (substantiate): "Our SBTi-validated net-zero target commits to a 90% absolute reduction in Scope 1, 2 and 3 emissions by 2040 against a 2022 baseline, with interim 42% reduction by 2030. Validated by SBTi in March 2025; annual progress disclosed in our CDP Climate report." After (remove the claim): Drop the future commitment from consumer-facing copy until the verified plan exists.

5. Advertising legally-required attributes as distinctive features

Banned: Marketing as a unique selling point any feature that is already legally mandatory for all products in the category.

This is the rule everyone underestimates. It catches:

"PFOA-free" on cookware (PFOA already EU-banned).
"BPA-free" on baby bottles (BPA already banned in EU baby bottles since 2011).
"CFC-free" on aerosols (banned since the 1990s).
"Microbead-free" in rinse-off cosmetics (banned in many EU member states).
"Animal-testing-free" on cosmetics (already mandatory under EU Regulation 1223/2009).

Before: "BPA-free baby bottle — safer for your child." After (remove): Delete the BPA-free claim from the product page; replace with substantiated category-relevant differentiators. After (acceptable when factual): A product specification list that includes "BPA-free" alongside other technical attributes, without framing it as a distinctive selling feature.

6. Missing durability and reparability information

This is the positive disclosure that pairs with the bans. Where relevant to the consumer's purchase decision, traders must clearly inform consumers about:

Expected lifetime of the product (where measurable — e.g. cycles for appliances, hours for electronics).
Reparability — including a reparability score where one applies (France's reparability index is the working example).
Spare parts — availability, duration of availability, and how to obtain them.
Repair services — what is offered, by whom, at what indicative cost.
Software-update support — for digital and connected products, the duration of free security and functionality updates, and any negative impact those updates have on the product's performance.

The omission of this information where it would influence the purchase is itself a banned practice. The most exposed categories are electronics, appliances, furniture, footwear, and any connected/smart product.

What to do this week

Pull a claims inventory across product pages, packaging copy, paid ads, social posts (last 12 months), influencer briefs, sustainability pages, and PDP modules.
Classify each claim against the six categories above. Severity = banned outright (1–5) or disclosure gap (6).
Pick the remediation per claim: substantiate (with evidence file), qualify (narrow and specify), replace (recognised scheme reference), or remove.
Brief marketing, ecommerce, social and the agency network so new copy passes the same filter.
Add the durability and reparability block to product pages where it applies.

How Regonance helps

Regonance runs an AI claims scan over your product URLs, packaging text, ad copy and sustainability pages, classifies each claim against the six banned-practice categories with severity and remediation, and captures the evidence file behind your retained claims. The free EmpCo checker gives a single-page risk read with no signup; the full per-claim audit with evidence capture is on Pro and Agency plans.

Educational information, not legal advice. Validate scope and obligations with a qualified advisor before acting; consult the consolidated text of Directive (EU) 2024/825 on EUR-Lex for the authoritative legal source.

Frequently asked questions

Can I still say 'carbon neutral' if I buy verified offsets?+

Not at the product level. Offset-based 'carbon neutral', 'climate neutral', 'net zero' and 'CO2-positive' product claims are banned outright from 27 September 2026, even if the offsets are high quality and third-party verified. Only claims based on actual value-chain emission reductions are permitted. Company-level statements are not directly banned by this rule, but remain exposed to the general misleading-practices regime if unsubstantiated.

Is 'sustainable' a banned word?+

Not automatically — but used generically without substantiation it falls under banned practice (1): generic environmental claims without demonstrated, recognised and verifiable excellent environmental performance. 'Sustainable cotton' with a GOTS or BCI scheme reference behind it can pass. 'Our sustainable collection' with no scheme, no metric and no evidence file: banned.

What about my own brand's 'Eco' or 'Green' badge on product pages?+

If the badge is self-created and not backed by a recognised certification scheme or established by a public authority, it falls under banned practice (3) and must be removed. Remove or replace with a reference to a recognised third-party scheme (EU Ecolabel, EU Organic, FSC, GOTS, OEKO-TEX, Cradle to Cradle, etc.).

How are influencer and affiliate claims treated?+

The brand carries primary liability for claims made on its behalf, including by influencers, affiliates and resellers. EmpCo does not exempt 'they said it, not us'. Brief your influencer network with the same banned-practice rules and approve copy before posting.

What about claims I made before 27 September 2026 that are still live?+

Enforcement applies to claims live on or after 27 September 2026, including legacy product pages, archived campaigns still indexed by search, packaging in market, and historical sustainability reports still on your site. Take down or remediate before the date — content from 2023 still findable in 2026 is still a violation.

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