The EU’s Packaging and Packaging Waste Regulation (PPWR) is changing how businesses think about packaging, recyclability and producer responsibility. For ecommerce sellers, the biggest question is simple: what do I need to do now to stay compliant?
PPWR stands for the Packaging and Packaging Waste Regulation. It’s an EU regulation designed to reduce packaging waste and create more consistent packaging rules across the EU. It covers packaging throughout its life cycle, including design, materials, composition, recyclability, reuse and waste prevention.
The regulation applies broadly to packaging placed on the EU market, regardless of whether that packaging is produced in the EU or imported from outside the EU. Its wider aim is to encourage more recyclable, reusable and less wasteful packaging.
PPWR is a specific piece of legislation that sets the wider rules for packaging and packaging waste. EPR (Extended Producer Responsibility), is the compliance framework that places responsibility for packaging waste onto the producer. In other words, PPWR is a kind of EPR legislation.
In practice, PPWR requires two things from ecommerce sellers:
Potentially, yes. Amazon may continue to manage certain parts of EPR compliance in some countries, such as eco-contributions or reporting. However, this does not always replace the seller’s own producer registration obligations. The rules can differ between EU Member States.
If you currently sell on Amazon, keep an eye out for communication from them. Check whether you need your own EPR numbers, an authorised representative or any other country-specific documents. Bear in mind that marketplace and legal requirements don’t always move at the same pace, so having clear records is important.
EU Member States can choose how they implement certain parts of PPWR, including the consequences of non-compliance. Therefore, what might happen if you don’t meet the deadline will vary by country. Similarly, each marketplace will be different – Amazon and eBay will likely have different approaches to non-compliant sellers.
National authorities are likely to issue warning and impose fines. Marketplaces might remove product listings until you can prove you’re compliant or fully suspend your account.
Thresholds are another instance where Member States have control over how they implement EU-wide legislation. In some countries you’ll need an EPR registration before you start selling. In others, you’ll have to hit a volume or turnover threshold – or both.
For example, the Netherlands requires registration for packaging after 50 tonnes a year. In Ireland, both a packaging volume threshold and a turnover threshold may need to be met. You should always check the current rules in each country before you start making sales.
The EU is aiming to harmonise the EPR systems. It’s not unlikely that in the future we’ll see the removal of thresholds all together.
The packaging threshold in Ireland has been removed. Previously, you needed to have:
before you would be required to register. However, with the introduction of PPWR, that has changed, and you'll need to be registered before your first sale.
Yes. If you sell regulated goods or put packaging to market in Ireland, you'll need to register. EPR regulations apply to domestic and international businesses. For example, a business in France would have to register for EPR in Germany, even though both countries are in the EU. Depending on what they sell, businesses in Northern Ireland will have EPR obligations in the UK. As a result, the special conditions for trade across the Northern Ireland/Republic of Ireland border don't impact your EPR obligations.
The first step is understanding your packaging footprint. You’ll need to collect and review data on:
A key part of meeting these obligations is monitoring the volume of packaging and its composite materials. It’s a good idea to get in touch with your suppliers, as they’ll be able to help you understand the material quantities. Plus, if you identify anything that needs changing, they can help you find alternatives.
PPWR encourages packaging to be designed with minimum necessary weight and volume while still protecting the product. In practical terms, that means looking for ways to reduce unnecessary empty space, oversized boxes and avoidable filler materials.
Product safety still matters. Packaging must protect the item in transit and ensure it reaches the customer in usable condition. The aim here isn’t to remove protective packaging, but to avoid excessive or unjustified packaging.
SimplyVAT can now help you register and file for certain EPR categories in 14 countries:
There’s a lot of potential for you to reduce your costs by following PPWR’s guidelines. First, right sizing your packaging will impact your outgoing costs in three areas:
These are all areas where size and weight add a premium.
Then, there are the eco-contributions. This is the amount you pay to the Producer Responsibility Organisation (PRO). They can vary depending on the materials you use, the type of packaging or the country you’re selling to. Packaging that is easier to recycle or made with recycled content may help reduce the amount you have to pay.
Packaging is only one of the regulated categories in Europe. Other common EPR regulations include electrical and electronic equipment and batteries. If a product contains electronics, sensors, chips or built-in batteries, it may trigger additional EPR obligations beyond its packaging.
For example, a remote control sold without batteries may fall under electrical and electronic equipment rules. If batteries are included, the seller may also need to consider battery EPR obligations.
In particular, France has a large number of EPR categories. A broad range of products are covered; from DIY & garden supplies to Textiles.
Generally speaking, how eco-contributions are calculated varies by country and PRO. The common factors are:
At the moment, there are no exemptions for micro or small businesses. That might change in the future (similar to the SME Scheme and ViDA), but don’t rely on it happening. It’s best practice to operate from the assumption that PPWR will apply to you.
PPWR entered into effect in 2025. The 12th of August 2026 is the date in which large parts of the legislation become enforceable. PPWR has multiple components with varying implementation dates.
An authorised representative is a local representative that acts on your behalf regarding your EPR compliance. PPWR makes it mandatory for you to have one in EU countries where you’re not established. That rule applies to everyone, regardless of whether you are based in the EU or not.
The representative acts as the point of contact for the authorities when they have questions or concerns about registrations, reports or payments.
