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.

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.

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.

9 MIN READ · UPDATED 7 JUNE 2026

PPWR — Regulation (EU) 2025/40 — translates into seven concrete checks that every economic operator placing packaging on the EU market must pass. Some are live on 12 August 2026, others phase in through 2030, 2035 and 2038. This guide walks each one with what is enforceable now, what data must be captured for upcoming milestones, and what defensible documentation looks like.

Use it as a packaging-team checklist.

Check 1 — Role identification and packaging inventory

Live: 12 August 2026. The first thing PPWR asks is who you are and what packaging you are placing on the market.

Identify your role per item: producer (you place the packaged product on the market under your own name), importer (you bring packaged goods into the EU from outside), distributor (you make available packaging or packaged products without changing the packaging), fulfilment service provider (you store, label, pack or dispatch goods you do not own). The role determines which articles bind you.
Inventory every packaging component per SKU:
- Primary packaging — the retail pack the consumer sees and unboxes
- Secondary packaging — the grouping pack (e.g. shelf-ready tray, multi-pack)
- Tertiary packaging — the transport pack (pallet wrap, shipper, crate, dunnage)
- Capture material, weight, dimensions, supplier, recycled-content, layer structure, adhesives, inks, closures

Without this inventory, none of the other checks can be answered.

Check 2 — Packaging minimisation (Art. 10)

Live: 12 August 2026. Packaging weight and volume must be minimised to what is genuinely necessary. The regulation lists permitted justifications: protection, handling, marketing, hygiene, sorting, consumer information, presentation, regulatory information.

Concretely:

No unnecessary empty space in the packaging design (the rule of thumb regulators use: substantial visible void with no functional explanation).
No superfluous packaging layers beyond what protection genuinely requires.
E-commerce parcels are in scope. The shipping box, mailer, void-fill and polybag must each be justifiable on the same grounds.

Default targets enforcement is likely to pursue first: visibly over-packaged e-commerce parcels, retail packaging with structural air pockets used purely for shelf presence, and gift packaging where the over-design is unjustified by protection.

Check 3 — Recyclability (Art. 6 + delegated acts)

Data capture live now. Grade A–C enforceable 1 January 2030. A–B only from 1 January 2038.

PPWR introduces a packaging recyclability grading scale:

A: ≥95% of the packaging is recyclable at scale (high design-for-recycling, fully separable, compatible with EU sorting infrastructure)
B: ≥80%
C: ≥70%
D, E: below 70% — not marketable from 1 January 2030

From 2038, only A–B may be placed on the EU market. The exact grading methodology — what counts as separable, sortable, compatible — is being defined in Commission delegated acts; until that lands, capture the underlying design data so the grade can be calculated automatically.

What to capture per packaging component: material composition (polymer ID, fibre type), layer structure (mono-material vs multi-layer), adhesives, inks, coatings, labels (separable?), closures (material match?), and any feature known to disrupt sorting (carbon-black plastics, full-sleeve shrink labels of incompatible polymer, metallised films).

Check 4 — Recycled content in plastic packaging (Art. 7)

Live: 1 January 2030. Data capture starts now. Minimum recycled-content thresholds for plastic packaging apply from 2030, varying by category. Annex II of the regulation sets the percentages, including step-up targets for 2040.

The categories run roughly: contact-sensitive plastic packaging made from PET; contact-sensitive packaging from other plastics; non-contact-sensitive plastic packaging; single-use plastic beverage bottles. Recycled content must be post-consumer unless otherwise specified, with supplier evidence (e.g. ISCC PLUS or equivalent third-party chain-of-custody attestation).

The 2026 task is unglamorous but decisive: get per-component recycled-content data from each packaging supplier and store the evidence. Brands that turn up in 2029 without supplier data will be unable to comply.

Check 5 — Substance restrictions (Art. 5)

Live now. Several restrictions are already enforceable and predate the 2030 milestones:

PFAS in food-contact packaging — restrictions apply with phase-in periods set by Commission delegated acts.
Heavy metals (Pb, Cd, Hg, Cr VI) — sum of concentrations in packaging cannot exceed 100 mg/kg.
Other restricted substances — captured by Art. 5 with the regulation referring out to REACH Annex XVII and other EU chemical legislation.

For every packaging component, confirm with the supplier: PFAS presence, heavy-metal concentrations, presence of substances of very high concern (SVHCs) above relevant thresholds. Capture the declaration and store it with the SKU's compliance file.

Check 6 — Harmonised labelling (Art. 12 + implementing acts)

Phases in 2028–2029 via Commission implementing acts.

PPWR requires harmonised labelling of:

Material composition of each packaging component (pictogram + standardised codes)
Consumer sorting instructions — which bin, in which member state, in a consistent visual format
Recycled-content claims where made — backed by a standardised method

The exact pictograms and language are being defined in implementing acts; until those land, absence is not yet a violation. Once they go live (expected 2028–2029), the unmarked pack becomes the issue. Plan your packaging artwork refresh cycle around the implementing-act publication.

Check 7 — Format bans (Art. 25 / Annex V)

Live: 1 January 2030. Specific single-use formats are prohibited from market placement from 2030. Annex V is the binding list, but the main hits are:

Single-use plastic packaging for unprocessed fresh fruit and vegetables under 1.5 kg (with limited derogations for technical reasons).
Single-use plastic packaging for foods and beverages served and consumed within HORECA premises (dine-in cups, plates, cutlery, condiment sachets).
Single-use plastic mini-bottles for cosmetics and toiletries in the accommodation sector (the hotel toiletries pump-bottles replace miniatures).
Grouped packaging used purely for marketing (shrink-wrap multi-packs that serve no transport or protection function).
Very lightweight plastic carrier bags (under 15 microns) except where required for hygiene or as primary packaging for loose food.

If any in-scope SKU is in your assortment, the redesign clock is running.

What "compliant" looks like in 2026

PPWR is not a single binary verdict in 2026. A defensible posture is a packaging readiness profile per SKU with:

All seven checks answered (or flagged as data-missing)
Live-now obligations passing today (role identified, minimisation reviewed, substances confirmed, EPR registered per country)
A forward-looking forecast against 2028–2029 (labelling) and 2030 (recyclability A–C, recycled content, format bans), with the data already in hand to act when each milestone bites
Supplier evidence captured per packaging component and retained in a dated documents hub

How Regonance helps

Regonance captures your packaging components per SKU, runs all seven PPWR checks, and returns a readiness profile with live-now flags and a forward-looking forecast against the 2028 / 2030 / 2035 / 2038 milestones. Plain-language remediation per check lets packaging engineering act now rather than firefight in 2030. Pairs with the EPR module so the same packaging data feeds straight into per-country EPR reporting. Available on Pro and Agency plans.

What to do this week

Build a per-SKU packaging inventory. Material, weight, dimensions, supplier, recycled content where known, for primary / secondary / tertiary components.
Run a minimisation pass on the top 20 e-commerce SKUs — likely the easiest enforcement target.
Send a substance declaration request to every packaging supplier — PFAS, heavy metals, SVHCs.
Open a recycled-content data request to every plastic packaging supplier with a 2030 deadline horizon.
Identify any Annex V format risk in the current assortment and start the redesign brief.

Educational information, not legal advice. Validate scope and obligations with a qualified advisor before acting; consult the consolidated text of Regulation (EU) 2025/40 (especially Articles 5, 6, 7, 10, 12, 25 and Annexes II and V) on EUR-Lex for the authoritative legal source.

Frequently asked questions

What is enforceable on 12 August 2026 versus later?+

12 August 2026 (live now): operator role duties, packaging minimisation, substance restrictions (Art. 5), Authorised Representative requirement (Art. 40 — verify per-country scope), and harmonised EPR registration (Art. 44). 2028–2029: harmonised labelling via implementing acts. 1 January 2030: recyclability A–C grading enforceable; minimum recycled-content thresholds for plastic packaging; certain single-use format bans; 70% packaging-waste recycling target. 2035 / 2038: tightening — A–B only from 2038, higher reuse and waste-reduction targets.

How does the recyclability grading work?+

PPWR introduces a five-grade scale (A–E) assessed against design-for-recycling criteria (sortability, separability, contamination risk, material compatibility with EU sorting infrastructure). From 1 January 2030 only grades A–C may be placed on the EU market; from 1 January 2038, only A–B. The exact grading methodology is being defined in Commission delegated acts. Capture material composition, layer structure, adhesives, inks and closures now so the grade can be calculated as soon as the methodology is published.

What are the recycled-content thresholds for plastic packaging?+

PPWR Art. 7 sets minimum recycled content per plastic packaging component, varying by category, applicable from 1 January 2030. Categories include contact-sensitive plastic packaging made from PET, contact-sensitive packaging from other plastics, non-contact-sensitive plastic packaging, and single-use plastic beverage bottles. Exact percentages and a 2040 step-up are in Annex II of the regulation. The 2026 task is to capture per-component recycled content data with supplier evidence.

What format bans take effect in 2030?+

Annex V of PPWR lists specific single-use packaging formats that are prohibited from 1 January 2030. The main hits: single-use plastic packaging for unprocessed fresh fruit and vegetables (under 1.5 kg); single-use plastic packaging for foods and beverages served and consumed within HORECA (dine-in); single-use plastic mini-bottles for cosmetics and toiletries in the accommodation sector; grouped packaging used purely for marketing (e.g. shrink-wrap multi-packs with no transport function); and very lightweight plastic carrier bags except where required for hygiene. Some derogations exist; check Annex V before redesigning.

Does the minimisation rule apply to my branded shipping box?+

Yes. The minimisation requirement (PPWR Art. 10) applies to all packaging placed on the EU market, including e-commerce parcels. Packaging weight and volume must be minimised to what is genuinely necessary for protection, handling, hygiene, sorting and marketing functions. An e-commerce parcel that is 40%+ empty space is a textbook target, as is an oversized retail pack designed to look more substantial on shelf. Marketplaces are named responsible actors and can act on flagged listings.

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