In partnership with
01 - The Brief
The EU's Packaging and Packaging Waste Regulation became applicable on 12 August 2026
The PPWR (Regulation (EU) 2025/40) replaced the EU's old packaging directive and, unlike a directive, applies directly and uniformly across all 27 member states. It entered into force in early 2025, and its core obligations became applicable on 12 August 2026, six days ago. It governs how packaging is designed, registered and paid for under Extended Producer Responsibility (EPR) rules, and it reaches almost anyone placing packaged goods on the EU market.
Non-EU sellers may need an authorised representative in every country they ship to
The provision with the biggest operational impact: a producer must appoint an EPR authorised representative in each member state where they sell but are not established. For sellers based outside the EU, this requirement applies from 12 August 2026, potentially meaning a separate local representative in each EU country you ship B2C parcels into. For a business shipping across several EU markets, that's a significant new administrative burden.
The enforcement lever is marketplace access, not just fines
As with the seller-verification rules we covered recently, the real teeth here are on the platforms. Marketplaces are required to verify sellers' EPR registration status before activating or continuing their accounts. In practice, that means a seller without valid packaging EPR registration risks having listings suspended, which for many businesses is a more immediate threat than any regulatory penalty.
02 — The Deep Dive
What the PPWR's producer-responsibility rules require, who has to act now, and the one big question still unresolved
Extended Producer Responsibility for packaging isn't new in Europe, sellers have registered with national schemes like Germany's LUCID and France's CITEO for years. What's changed with the PPWR is that these obligations are now set at EU-regulation level, applying directly across all member states, and they come with a specific, demanding requirement around local representation and marketplace enforcement that catches a lot of cross-border sellers off guard.
What EPR actually means here
Under Extended Producer Responsibility, the business that puts packaging on the market is financially responsible for its end-of-life: the collection, sorting and recycling of that packaging. In practice you meet this by registering with each country's national packaging scheme and paying fees based on the type and volume of packaging you use. This applies to the packaging your products ship in, not just retail packaging, so ecommerce parcels are squarely included.
The PPWR requires a producer to appoint an authorised representative for EPR in each member state where it makes packaging available but is not established. An authorised representative is a person or entity based in that destination country, formally mandated in writing, who takes on the administrative EPR obligations locally and can carry legal and financial responsibility for them.
For a non-EU seller shipping to consumers in, say, Germany, France, Italy and Spain, the literal reading is that you may need a separate authorised representative in each of those countries. That's a real operational and cost burden, and it's the single biggest reason this regulation matters for cross-border sellers rather than being a box-ticking exercise. It's worth noting some member states (Austria, Spain, Greece and Denmark among them) already required foreign sellers to appoint one even before the PPWR harmonised the rule.
The rule that bites isn't "register your packaging", most cross-border sellers already do. It's "appoint a locally liable representative in every country you ship to but aren't based in." That's the new operational weight.
The big open question: a possible reprieve, but only for some
Here's where it's essential to be precise, because the situation is genuinely unsettled. In December 2025, the European Commission proposed suspending the authorised-representative obligation for EU-established producers until 2035, with later amendments suggesting the relief might be narrowed to micro and small enterprises. But three things are critical to understand about that proposal. First, it has not been adopted, and it has actually stalled: in June 2026 the Council declined to advance the suspension after a large majority of member states raised objections, and a Parliament committee vote isn't expected until around October 2026, after the deadline had already passed. Second, it is aimed only at EU-based producers. Every authoritative source is explicit that the proposed relief does not cover non-EU sellers, who remain fully in scope.
There is one piece of interim relief worth knowing about. Around the 12 August application date, the Commission publicly indicated it had asked Parliament and member states to abolish the AR requirement, and suggested national authorities issue warnings rather than sanctions while the legislation is unresolved. That's meaningful, but it's a soft enforcement posture, not a removal of the obligation, the requirement itself is still law as of 12 August, and relying on a "warnings for now" stance is not the same as being exempt.
So the honest current picture is a split one. If you're a non-EU seller, you should treat the authorised-representative requirement as live now, the proposed suspension isn't aimed at you and the Council didn't advance it anyway. If you're an EU-based seller, there's a stalled proposal that might eventually ease this, but until it's actually adopted, the safe assumption is that the requirement applies as originally planned. Acting as though an unadopted, stalled proposal has already changed the law is exactly the kind of bet that goes wrong.
Marketplaces are the enforcement point
What makes this immediately practical rather than theoretical is how it's enforced. Under the PPWR, online marketplaces have to verify that sellers hold valid EPR registration before letting them operate, an obligation on the platform, mirroring the trader-verification duty under the Digital Services Act we covered recently. The consequence for sellers is direct: no valid packaging EPR registration can mean suspended listings. And notably, a marketplace collecting eco-fees "on your behalf" (as some do) is generally not a substitute for holding your own EPR registration, a distinction that trips up sellers who assume the platform has handled it for them.
What you also have to produce
Beyond registration and representation, the PPWR requires a Declaration of Conformity for each packaging format placed on the EU market from August 2026, backed by technical documentation demonstrating the packaging meets the regulation's requirements. This is separate from the recyclability and design rules that phase in later (from 2030), so it's the registration, representation and documentation layer that's the immediate concern this month, not yet the packaging-redesign requirements.
Action plan, if you ship packaged goods into the EU
Confirm your EPR registration in every country you ship to. If you sell into Germany, France, and others, you need valid packaging EPR registration in each. Gaps here are what put marketplace listings at risk.
Non-EU sellers: treat the authorised-representative requirement as live now. The proposed suspension is aimed at EU-based companies and hasn't been adopted anyway. Assume you need representation where required, and get advice on which countries apply it to you.
Don't assume your marketplace's eco-fee service covers you. A platform collecting fees on your behalf is generally not the same as you holding your own EPR registration. Confirm what you're actually registered for.
Prepare your Declaration of Conformity. For each packaging format you place on the EU market, you need a Declaration of Conformity and supporting documentation. Start assembling this now if you haven't.
EU-based sellers: track the suspension proposal, but don't rely on it. It has stalled, the Council declined to advance it in June, and any Parliament vote comes after the deadline. Until relief is actually adopted, plan as though the requirement applies.
This article is for informational purposes only and does not constitute legal or compliance advice. The PPWR is complex, some elements remain subject to pending legislative change, and obligations vary by country and business circumstances. Consult a qualified compliance or legal adviser to determine exactly what applies to you.
03 — The Stack
National EPR registers (LUCID, CITEO and equivalents)
Given this week's topic, the most relevant "tools" are the official national packaging registers you actually have to register with.
Official registers ✓Country-specific ✓Germany: LUCID ✓France: CITEO ✓Netherlands and others ✓
Each EU country runs its own packaging EPR system, Germany's LUCID register and France's CITEO are the two largest, with equivalents in the Netherlands and every other member state. These are the official points of registration marketplaces check against, so registering directly (or through a reputable compliance provider that does it for you) is the concrete action the PPWR actually demands. Registering in the countries you ship to is what keeps your marketplace listings active.
The one limitation worth noting: registering is country-by-country and genuinely fiddly, each register has its own process, language, and rules, and some (like Germany's LUCID) require the initial registration to be done by the producer personally rather than delegated. There's no single EU-wide portal that covers all 27 at once, which is precisely the administrative burden the authorised-representative requirement adds to.
Not a sponsored placement. No affiliate relationship.
04 — The Number
27
The number of EU member states the PPWR applies across directly and uniformly, and, in the worst case for a non-EU seller shipping everywhere, the number of separate national EPR registrations and authorised representatives that could be required.
Source: Regulation (EU) 2025/40 (PPWR), applicable from 12 August 2026; European Commission
The reason this regulation lands harder than it first appears is that "the EU market" is, for compliance purposes, still 27 separate registration regimes. The PPWR harmonises the rules, but the registrations and representatives remain national. For a seller shipping across the bloc, the practical question isn't "am I compliant in the EU" but "am I compliant in each of the specific countries I ship to", which is a very different, and more demanding, question.
Get more meetings by removing the LinkedIn limits.
When you need more leads, you want to do more, right?
Adding mailboxes to cold emails.
Placing more cold calls
Running more ads.
But what do you do if your leads are on LinkedIn? LinkedIn outreach still depends on the limited number of profiles already on your team.
Aimfox Avatars lets you rent dedicated, customizable LinkedIn profiles that start conversations and hand interested replies to your existing sellers.
Add outreach capacity without hiring another SDR or turning every employee account into a prospecting channel..