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.

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.

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.

7 MIN READ · UPDATED 7 JUNE 2026

A year of enforcement under Regulation (EU) 2023/988 has produced a clear pattern. The 2025 enforcement summaries from BAuA (Germany), DGCCRF (France), AGCM (Italy) and the Dutch NVWA, combined with marketplace listing-suppression data, all point at the same recurring gaps. None of them are exotic — most are structural problems with how online sellers organised their data before GPSR landed.

This guide walks through the seven most common GPSR mistakes online sellers make, with the underlying cause and the clean fix for each.

1. Responsible Person on the website but not on the listing

The most common Article 19 finding by a wide margin. Non-EU sellers add the EU Responsible Person details to the website's "Legal" or "Imprint" page — which is correct — and then assume that satisfies the obligation. It does not. Article 19(1)(c) requires the Responsible Person's identity and contact to be visible to the consumer before the conclusion of the contract, which means on the product page, on every channel.

Fix. Render the Responsible Person block from a single data source on every product page, in every channel, in every destination language. Most Shopify themes need a custom metafield and a section binding; most marketplaces have a dedicated field that just needs to be populated.

2. Warnings translated for one EU market only

The product page shows the EN 71-1 small-parts warning in English. The seller ships to Germany, France, Poland and Spain. Article 9(7) and Article 19 require the warning to be in a language "easily understood by consumers in the country of sale" — for every destination, not just one.

Fix. Maintain a warnings dictionary keyed by SKU and destination market language. Push translations through your localisation pipeline alongside the rest of the listing copy. For marketplaces with per-locale listings (Amazon DE vs Amazon FR), the dictionary populates the right locale automatically.

3. Manufacturer identified as a marketing name

The listing says "Made by Aurora Co." A market-surveillance officer searches the EU and national company registries — and finds no Aurora Co. Aurora is a trading name; the underlying legal entity is "LumenCorp SAS". Article 9(5) and Article 19(1)(a) require the legal manufacturer name (or registered trade mark, but only if it is registered).

Fix. Use the format "BrandX, a trading name of LegalEntityCo SAS" or list the legal entity explicitly. If your trade mark is registered, you can list the trade mark with the registration number.

4. Generic technical file shared across SKUs

A common mistake for sellers with many variants: a single "general risk assessment" copy-pasted across every SKU. Authorities reject this. Article 9(2) is explicit that the risk assessment must reflect the actual product as placed on the market — including the foreseeable misuse risks specific to its category and target audience.

Fix. A short (2–4 page) per-SKU risk assessment is sufficient for most categories. Reuse boilerplate sections (e.g. category-level hazards) but require a per-SKU exposure-and-mitigation table that names the variant, the target user, and the residual risk after mitigations.

5. Incident-response SOP that points at an unmonitored inbox

The SOP exists. It says "report incidents to compliance@brand.com." That inbox is a shared mailbox that nobody monitors at weekends. The product safety officer who tries to reach you with a Safety Gate alert on a Friday afternoon gets no response by Tuesday. The authority concludes — correctly — that there is no functioning corrective-action capability.

Fix. Name a specific human owner (with a deputy), commit to a published decision window (24h to acknowledge, 48h to notify the Safety Business Gateway if confirmed unsafe), and put the SOP in the same place as the rest of your operational playbooks. Test it quarterly with a tabletop exercise.

6. Responsible Person on file but not registered in the EU economic-operator database

eBay validates Responsible Person appointments against the European Commission's economic-operator database. A few EU RP service providers are not in the database — usually because they are new entrants or have an irregular legal structure. The listing passes initial validation, then gets suppressed weeks later when the eBay system completes the registry check.

Fix. Before appointing a Responsible Person, confirm they are registered as an economic operator in the EU. Ask the provider for their EORI number and their registration in at least one Member State's product-safety registry.

7. Recall communications that do not follow the Implementing Regulation template

Implementing Regulation (EU) 2024/1435 prescribes the exact format of recall and safety-warning notices to consumers under GPSR. National authorities no longer accept free-form recall press releases. The notice must include specific elements (product identification, hazard description, action required, remedy choice between repair/replacement/refund, contact for queries) and use the visual template the implementing regulation specifies.

Fix. Pre-stage the recall notice template before you need it. Most authorities provide a downloadable template per Member State; Regonance bundles them into the incident response kit.

How Regonance helps

Regonance scans your existing product files and listings, identifies which of these seven gaps apply per SKU per channel, and outputs a prioritised remediation list — high-impact fixes first. Most sellers close the top three gaps inside a working week using the structured output. Run a free scan on a single SKU to see your current exposure.

What to do this week

Audit the Article 19 fields on your top 20 EU-selling listings against the seven gaps above.
Confirm your Responsible Person is in the European Commission's economic-operator database.
Localise warnings for every destination market.
Run one tabletop exercise on your incident SOP — find the failure modes before an authority does.

Glossary

Safety Gate Portal. The EU's rapid alert system for non-food dangerous products, accessible to authorities and the public.

Safety Business Gateway. The EU portal where economic operators notify authorities of unsafe products and corrective actions.

Implementing Regulation (EU) 2024/1435. The rule that prescribes the template and procedure for recall and safety-warning notices under GPSR.

EORI number. Economic Operators Registration and Identification number — the EU identifier used for customs but also relied on for product-safety registry checks.

Educational information, not legal advice. Consult the consolidated text of Regulation (EU) 2023/988 and the relevant implementing acts on EUR-Lex for the authoritative legal sources.

Frequently asked questions

What is the single most common GPSR mistake?+

Listing the Responsible Person on the brand's legal page but not on the product listing itself. Article 19 is product-specific and channel-specific — the information must render on every product page, in every destination market language. The 2025 BAuA and DGCCRF enforcement summaries both rank this first.

How aggressive is GPSR enforcement so far?+

Less aggressive on first-time gaps than on repeated failures. Most national authorities issue a written request first; non-response within the deadline (typically 10 working days) triggers escalation. Marketplace suppression happens faster — Amazon EU and Zalando suppress automatically when key fields are missing.

Will fixing the listing also fix marketplace suppression?+

Usually yes, but with a lag. Most marketplaces re-evaluate suppressed listings within 24–72 hours of the seller updating the compliance dataset. Some require manual reactivation via seller support.

Can I fix GPSR gaps retroactively for products already sold?+

Yes for the listing-side fixes (Article 19 information). No for the technical file — if you placed a product on the market without a risk assessment, that placement is non-conformant and an authority finding will reach back to it. Going forward you can clean up.

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