PPWR: what the EU Packaging Regulation means for online sellers

What is the PPWR?

The PPWR is the EU regulation on packaging and packaging waste. It entered into force in February 2025 and has applied since 12 August 2026. It replaces Directive 94/62/EC, which every member state had transposed in its own way. You know the result: different terms, thresholds and rules in every country. The PPWR levels the base.

That does not mean the national organisations disappear. Verpact, LUCID, Citeo and Fost Plus remain, as do their fees and portals. What changes is that the rules they work within are now European.

Who is a producer under the PPWR?

The PPWR defines the producer at EU level. For online sellers the key point: whoever delivers packaged products at a distance to end users in another member state is the producer in that member state. That was already the case in most countries, but it is now settled the same way everywhere.

What is new is that the PPWR separates whoever designs or commissions the packaging (responsible for the requirements on the packaging itself) from whoever places it on the market (responsible for EPR). Countries have aligned their terms: Germany with the new VerpackDG, Belgium by replacing its packaging responsible party with the EU producer.

Registration in every member state

Every member state keeps a producer register. You must be registered in every member state where you first place packaged products on the market, and a producer that is not registered may not place packaging on the market there. There is no EU-wide collective registration, as Kaufland also points out explicitly to its sellers.

The authorised representative

Article 45 of the PPWR requires a producer placing packaged products on the market of a member state where it is not established to appoint an authorised representative for EPR there. That representative handles your registration, declarations and payments in that country. A webshop delivering to ten member states would need ten representatives.

That obligation is contested:

• December 2025: the European Commission proposed, in an environmental omnibus, suspending the representative obligation for EU-established producers until 2035. Non-EU producers were not included.
• June 2026: a majority of member states opposed the suspension, after which talks in the Council were put on hold.
• European Parliament: a narrower version is being discussed there, with an exemption for small companies. A first reading is scheduled for October 2026 at the earliest.

Where things stand: the obligation is part of the PPWR as it has applied since 12 August 2026. Germany has written it into the VerpackDG; Verpact notes it may still be dropped. Keep an eye on this page; we update it once there is a decision.

What is still coming

The PPWR covers more than EPR. Requirements on the packaging itself phase in over the coming years. For webshops these matter most:

The empty space requirement hits webshops most directly: one standard shipping box for every product size becomes a risk.

What to do now

1. 1Map which member states you deliver packaged products to, across all your channels together.
2. 2Check per country whether you are registered, and register where you are not.
3. 3Work out where you need an authorised representative, and follow the EU decision on it.
4. 4Update your registrations where countries have changed their terms, such as LUCID in Germany.
5. 5Record your packaging per product, per component and per material: you need it for every declaration, and soon for the recyclability and empty space rules too. See calculating packaging weight.

Frequently asked questions

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