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.

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.

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.

8 MIN READ · UPDATED 7 JUNE 2026

Fashion is the sector EmpCo was effectively designed for. The European Commission's 2020 sweep of 344 websites across consumer-product sectors found that 42% of green claims in fashion were exaggerated, false or deceptive — the highest rate of any sector tested. NGO actions since (BEUC's 2024 complaint against 17 fashion brands; the Dutch ACM rulings against Decathlon and H&M; the DGCCRF settlement with SHEIN in France) have continued to target the same patterns. Directive (EU) 2024/825 (EmpCo) now formalises those rules across the EU 27 with enforcement from 27 September 2026.

This guide maps each of EmpCo's six banned practices to the fashion-specific patterns regulators and NGOs are already flagging, and gives a sector-specific remediation playbook.

The fashion-specific risk map

Banned practice	Fashion pattern that triggers it
1. Generic eco claims	"Sustainable collection", "conscious choice", "eco line", "responsibly made" with no scheme, metric or evidence
2. Offset-based "carbon neutral"	"Climate neutral T-shirt", "carbon neutral hoodie" via offsets — banned at the product level
3. Self-made eco-badges	Brand-created "Conscious", "Eco", "Green" leaf badges with no third-party scheme behind them
4. Future commitments without a plan	"100% organic by 2030", "circular by 2027" without a publicly verified roadmap
5. Legally-required as distinctive	"Free of [restricted azo dye]", "PFOA-free" framed as unique selling points
6. Missing durability info	No information on garment lifetime, repair services, spare buttons/zips availability

Banned practice 1 — generic "sustainable" collections

The most common pattern. A fast-fashion brand labels a portion of its catalog as "Conscious", "Sustainable Collection" or "Eco Edit" without naming the material, the percentage, the scheme or the methodology.

Real-world precedent. The Dutch ACM in 2022 required H&M to remove generic sustainability claims from its "Conscious" line and refund consumers; the Norwegian Consumer Authority issued similar findings on Norrøna; the UK CMA's Green Claims Code (parallel UK regime) struck Asda, Asos and Boohoo for the same pattern.

Remediation.

Replace "Sustainable Collection" landing pages with specific, evidenced filter labels: "GOTS organic cotton", "GRS recycled polyester ≥50%", "OEKO-TEX Standard 100 certified".
Move every claim from page-level to SKU-level with the certificate number and the percentage by weight.
If the underlying evidence does not exist for an SKU, the SKU does not get the label.

Banned practice 2 — offset-based "climate neutral" garments

The textile sector's offset-based product claims are the test case. Allbirds (US filings); ON Running; multiple cycling and outdoor brands have used "carbon neutral" product claims based on offsets. From 27 September 2026 those product-level claims are banned in the EU regardless of offset quality.

Remediation.

Remove "carbon neutral", "climate neutral", "net zero" and "CO2-positive" from product pages, packaging and labels.
Replace with a transparent footprint disclosure: cradle-to-gate kg CO2e per item, methodology (ISO 14067 or PEFCR for apparel), and the year. Specific numbers without a neutrality claim are permitted.
Company-level "we offset our operational emissions" is not banned by this specific rule, but disclose methodology and boundary.
For genuine reductions, claim only what is in your value chain: renewable electricity at wet-processing facilities, lower-impact fibre choices, redesigned logistics.

Banned practice 3 — self-made "eco" badges

The leaf icon. The green tag. The "Eco Choice" badge designed to look like a third-party label but maintained entirely in-house. These are the cleanest banned-practice hits in fashion.

Remediation.

Remove every self-created eco-badge from product pages, plp filters and packaging.
Replace with recognised scheme logos and verifiable certificate numbers. The default fashion-sector set: GOTS, OEKO-TEX (Standard 100, Made in Green, STeP), GRS, RCS, FSC (for cellulosic fibres), Bluesign, Cradle to Cradle, EU Ecolabel (textile criteria from 2024).

Banned practice 4 — "100% recycled by 2027" without a plan

A staple of fashion sustainability reports: a future commitment to "100% recycled or organic by 2030" or "circular by 2027". Banned unless backed by a clear, objective, publicly available, independently verified implementation plan with measurable, time-bound targets.

Remediation.

Audit every future commitment on the corporate site, sustainability report, investor deck (where consumer-facing), and product pages.
For each: is there an SBTi-validated roadmap, a public interim milestone, a third-party verifier?
If yes: link to it next to the claim.
If no: remove the claim from consumer-facing copy until the verified plan exists.

Banned practice 5 — legally-required as distinctive

Fashion-specific cases:

"PFOA-free" or "PFC-free" performance wear — many PFCs are already EU-restricted under REACH; the per-substance picture is moving fast, so a sweeping claim risks the rule.
"Free of azo dyes" — specific azo dyes that release carcinogenic amines have been EU-banned in textiles since 2003.
"Lead-free", "cadmium-free", "phthalate-free" framed as distinctive features when those substances are already restricted in textiles or accessories.
"Cruelty-free" on textile-adjacent personal-care or accessory items where animal testing is already prohibited under Regulation 1223/2009.

Remediation. Move these from selling-point copy into the factual specification list. Do not frame as distinctive.

Banned practice 6 — missing durability and reparability information

EmpCo is positive-disclosure here. Where relevant to the purchase, fashion brands must inform consumers about expected lifetime, repair services, spare buttons or zips availability, and (for connected garments — yes, these exist) software-update support.

Remediation.

Add a "Care, repair and longevity" block to every product page above the fold or in the spec area.
Cover: expected lifetime with normal use; care instructions tied to that lifetime; repair service offered (in-house, partner network, or links to the repairability scheme); spare-parts availability for items with buttons, zips, soles, hardware.
For connected wearables, add the software-update support period and any negative impacts of updates.

The French AGEC reparability score and durability index (live for textiles in 2025–2026) is a useful template — even where it is not mandatory, structuring your disclosure in that format makes you defensible across the EU 27.

The marketplace dimension

Major fashion marketplaces have already moved. Zalando removed its in-house sustainability flag in 2024 after an Authority for Consumers and Markets settlement and now only displays third-party certifications. About You, Zalando Lounge, Galeries Lafayette and Otto have added EmpCo-aligned questions to seller onboarding. Amazon EU's Climate Pledge Friendly programme tightened its rules in late 2024 to require recognised third-party schemes.

If you sell through marketplaces, the practical near-term risk before September 2026 is not state enforcement — it is listing-level deprioritisation or removal by the marketplace itself.

The 90-day playbook for fashion brands

Days 1–30 — Inventory. Pull every consumer-facing environmental, ethical or sustainability claim across product pages, plp landing pages, packaging copy (hangtags, garment bags, shipping boxes), care labels, paid ads (last 12 months), influencer briefs, sustainability page, About page, corporate site, investor materials reaching consumers. SKU-level wherever possible.

Days 31–60 — Classify and decide. Every claim → banned-practice category → severity → action (substantiate / qualify / replace / remove). Assemble the evidence file for everything you retain. Pull legacy content from archive crawl.

Days 61–90 — Remediate and brief. Push the changes live across all surfaces. Update the agency network (paid social, PR, influencer) with the new guardrails. Add the durability/reparability block to product pages where it applies. Re-onboard marketplace listings against the new rules.

How Regonance helps fashion brands

Regonance runs the EmpCo claims scan across your product URLs, plp pages, packaging copy and sustainability pages, classifies each claim against the six banned-practice categories with severity and a plain-language remediation, and captures the GOTS, OEKO-TEX, GRS or equivalent certificate evidence behind your retained claims. The textile-DPP module feeds the same supplier and material data into the broader compliance picture so you capture it once. Run the free EmpCo checker on a single product page to see the risk profile, or start a full scan to map the catalog.

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

Why is fashion the most exposed sector under EmpCo?+

The Commission's 2020 sweep of textile and fashion websites found that 42% of green claims were exaggerated, false or deceptive — the highest rate of any sector tested. Subsequent NGO actions (BEUC complaints against 17 fashion brands in 2024, Authority for Consumers and Markets sanctions in the Netherlands, DGCCRF actions in France) have continued to focus there. EmpCo formalises the rules those actions were already enforcing.

Can I keep using GOTS, OEKO-TEX or GRS labels on my product pages?+

Yes. These are recognised third-party certification schemes and are explicitly the kind of label EmpCo wants you to use — provided the certification is current, scoped correctly to the product, and the certificate number is verifiable. Self-made 'Conscious' or 'Eco' badges are out; properly-cited third-party labels are in.

Does EmpCo affect 'made of recycled materials' claims?+

Specific, evidenced claims like 'shell made of 70% recycled polyester (GRS-certified)' are fine. Generic claims like 'made from sustainable materials' without naming the material, the percentage or the scheme fall under banned practice (1). The pattern: be specific, name the scheme, cite the certificate.

How does EmpCo interact with the upcoming textile DPP?+

EmpCo controls the marketing language about a garment; the textile Digital Product Passport (expected 2027–2028 under ESPR) controls the structured data that travels with the garment. They are complementary: the DPP captures fibre composition, country of manufacture and substances — the exact evidence base you need to substantiate any environmental claim under EmpCo. Capture the data once, use it for both.

What about secondhand, vintage and rental fashion claims?+

EmpCo applies to consumer-facing claims regardless of business model. Resale platforms making generic 'sustainable shopping' claims face the same substantiation bar. The narrative defence — 'circular by definition' — is not enough; specific, evidenced claims (avoided emissions per item, materials kept in circulation) are.

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

The fashion-specific risk map

Banned practice 1 — generic "sustainable" collections

Banned practice 2 — offset-based "climate neutral" garments

Banned practice 3 — self-made "eco" badges

Banned practice 4 — "100% recycled by 2027" without a plan

Banned practice 5 — legally-required as distinctive

Banned practice 6 — missing durability and reparability information

The marketplace dimension

The 90-day playbook for fashion brands

How Regonance helps fashion brands

Frequently asked questions

Run a free compliance readiness scan

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