PPWR and Amazon: what changes for FBA sellers in 2026
If you sell on Amazon EU marketplaces — Germany, France, Italy, Spain, the Netherlands, Poland, Sweden, or Belgium — the EU Packaging and Packaging Waste Regulation (PPWR) now applies to you. The regulation became directly binding on 12 August 2026, and Amazon is named in the regulation as a responsible actor when it handles packaging or logistics on behalf of third-party sellers.
If you sell on Amazon EU marketplaces — Germany, France, Italy, Spain, the Netherlands, Poland, Sweden, or Belgium — the EU Packaging and Packaging Waste Regulation (PPWR) now applies to you. The regulation became directly binding on 12 August 2026, and Amazon is named in the regulation as a responsible actor when it handles packaging or logistics on behalf of third-party sellers.
This guide explains what PPWR means specifically for Amazon FBA sellers, what Amazon is likely to enforce, and what to do now.
Why PPWR matters for Amazon FBA sellers specifically
Amazon FBA sellers face a particular complexity: when you use Fulfilment by Amazon, Amazon handles the shipping packaging. But the regulation's scope covers all packaging that reaches the consumer — retail packaging (your product's box or bag), grouped packaging (multi-packs), and transport packaging (the shipping carton).
Under PPWR, the "producer" is typically the entity that first places packaging on the EU market. For FBA sellers importing goods from outside the EU, that is usually you — not Amazon. Even though Amazon physically packs and ships the order, the compliance obligation for the product's packaging (and in some cases the shipping packaging) sits with the seller.
The PPWR also explicitly names online marketplaces as responsible actors when they handle packaging or logistics on behalf of third-party sellers. This means Amazon has a regulatory incentive to verify seller compliance, just as it has done aggressively with GPSR.
What Amazon is likely to require
Amazon has not yet published a detailed PPWR enforcement playbook equivalent to its GPSR enforcement. However, based on the regulation's requirements and Amazon's enforcement pattern on GPSR and EPR, sellers should expect:
EPR registration verification. Amazon already requires EPR registration numbers for packaging in Germany (Verpackungsgesetz / LUCID register) and France (Citeo). The PPWR harmonises EPR rules across the EU, which will likely extend this requirement to every EU marketplace. If you cannot provide a valid EPR number, listings may be suppressed.
Packaging material data. The PPWR requires producers to document packaging materials and composition. Amazon may begin requiring this data in Seller Central, similar to how it now requires GPSR fields.
Declaration of Conformity. The PPWR requires a Declaration of Conformity for packaging placed on the EU market from 12 August 2026. Amazon could request this documentation during compliance audits.
Authorised Representative verification. For non-EU sellers, the PPWR requires an authorised representative in the EU for EPR purposes. Amazon may begin requiring this information alongside the existing GPSR Responsible Person requirement.
The packaging that applies to you
As an FBA seller, you need to think about three categories of packaging:
1. Primary (retail) packaging — the box, bag, bottle, or container your product comes in. This is always your responsibility.
2. Grouped packaging — multi-packs, shrink-wrap bundles, display packaging. Also your responsibility.
3. Transport packaging — the shipping carton, void-fill, and protective materials. When Amazon ships via FBA, Amazon controls the transport packaging. However, the packaging you use to ship products to Amazon's fulfilment centres (the inbound shipping packaging) may also be in scope depending on how national schemes classify it.
For each category, you need to know: the material, the weight, whether it contacts food, and whether it is registered under the relevant national EPR scheme.
What to do now — the FBA seller checklist
Step 1: Confirm EPR registration in every EU marketplace country
If you sell on Amazon.de, you need German EPR registration (LUCID). If you sell on Amazon.fr, you need French EPR registration (Citeo or Léko). This applies for each EU country where you make packaged products available. If you use Pan-European FBA, your products may be stored and shipped from multiple EU countries — each of which triggers an EPR obligation.
Check your current registrations against your actual sales countries. Missing registrations are the most common compliance gap and the most likely trigger for enforcement.
Step 2: Document your packaging materials
For each product or SKU, record:
- packaging material type (plastic, cardboard, glass, metal, composite);
- weight per unit;
- whether any component contacts food;
- whether the packaging contains recycled content;
- supplier declarations for substances of concern (including PFAS for food-contact packaging).
You will need this data for EPR reporting and potentially for Amazon compliance fields.
Step 3: Prepare a Declaration of Conformity for your packaging
The Declaration of Conformity is a document stating that your packaging meets the PPWR essential requirements. At minimum, it should identify the packaging format, reference the applicable regulation, state that the essential requirements are met, and be signed by the producer or their authorised representative.
If you source packaging from a supplier, request their documentation. If you create your own packaging, you are the manufacturer and the declaration is your responsibility.
Step 4: Appoint an Authorised Representative if needed
If you are a non-EU seller placing packaging on the EU market, the PPWR may require you to appoint an authorised representative for EPR purposes. This is separate from your GPSR EU Responsible Person — they serve different legal functions under different regulations, though the same entity can sometimes fulfil both roles.
Step 5: Review empty-space compliance
The PPWR limits empty space in ecommerce parcels to 40%. While Amazon controls FBA shipping packaging, your own product packaging should not contain excessive empty space. If you ship oversized boxes with minimal product inside, this provision applies.
How PPWR interacts with GPSR and EPR
If you sell on Amazon EU, you are now managing compliance across multiple overlapping regulations:
| Regulation | What it covers | Key requirement |
|---|---|---|
| GPSR | Product safety | EU Responsible Person, manufacturer details on listing, safety warnings |
| PPWR | Packaging | Declaration of Conformity, EPR registration, PFAS limits, material data |
| EPR | Waste responsibility | National registration, reporting, and fee payment per country per stream |
| EmpCo | Green claims | No unsubstantiated environmental claims from 27 September 2026 |
| ESPR/DPP | Product sustainability | Digital Product Passport (phased by category, 2027+) |
Each regulation has its own requirements, its own enforcement timeline, and its own documentation. Managing them separately across spreadsheets and email is where compliance breaks down.
How Regonance helps
Regonance maps your product portfolio across EU regulations — GPSR, PPWR, EPR, EmpCo, DPP, and more — in one workspace. The platform scans your product listings, identifies missing compliance fields, and surfaces gaps before a marketplace flags them.
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Educational information only. Not legal advice. Amazon's PPWR enforcement approach may evolve — monitor Seller Central announcements for marketplace-specific requirements.
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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.