A significant regulatory shift is coming for e-commerce businesses selling into the EU. The Packaging and Packaging Waste Regulation (PPWR), published in January 2025, introduces updated rules on how businesses manage, report, and take responsibility for the packaging they place on the EU market, with requirements applying from 12 August 2026.
Whether you sell through Amazon, eBay, or your own online store, understanding your obligations under the PPWR regulation now could be the difference between seamless trading and costly disruption.
What Is the EU PPWR and Why Does It Matter?
The EU Packaging and Packaging Waste Regulation 2025/40 is part of the European Union’s broader circular economy strategy. It aims to reduce packaging waste, improve recyclability, and increase the reuse of packaging materials across all EU member states.
It replaces the previous Packaging and Packaging Waste Directive (94/62/EC), which required implementation through national laws in each EU member state, leading to differences across countries such as Germany, France, Italy, and Spain.
For e-commerce sellers, this matters because the regulation applies to anyone placing packaging or packaged goods on the EU market for the first time, regardless of where your business is based.
Who Does the PPWR Apply To?
Under the regulation, you are considered a producer if you are the first entity placing packaged goods onto the market in a given EU country. This applies to:
- Manufacturers supplying packaged goods under their own brand
- Importers bringing packaged products into the EU
- Online sellers shipping directly to EU customers
- Amazon FBA and Fulfilled by Merchant (FBM) sellers whose product packaging enters EU countries
- Businesses based outside the EU that sell into EU member states through distance selling
It is worth noting that if you are an FBA seller, Amazon may assume responsibility for certain fulfilment or transport packaging it adds during the fulfilment process, depending on the applicable national EPR rules.
However, the packaging your product arrives in before it reaches Amazon’s fulfilment centre remains your responsibility entirely.
What Are Your Obligations?
PPWR compliance involves four core obligations for producers:
Registration: You must register with the producer registry in each EU country where you place packaged goods on the market. This means obtaining an EPR Registration Number (ERN) per country, which must also be submitted to marketplaces such as Amazon via your Seller Central account.
Reporting: You are required to report the volume of packaging placed on the market, the types and weight of materials used, and whether packaging is designed for single use or reuse.
Eco-contribution fees: Fees must be paid to Producer Responsibility Organisations or environmental authorities in each relevant EU country to cover the cost of packaging waste management.
Authorised representatives: If your business is not established in the EU country where you sell, you may be required to appoint an authorised representative who is legally established in that country and can fulfil your producer obligations on your behalf.
The Amazon Angle: What Marketplace Sellers Need to Do
For sellers on Amazon, PPWR compliance integrates directly with existing EPR requirements on the platform. Even sellers currently enrolled in Amazon’s EPR Pay on Behalf service must now obtain an ERN in each country where they sell and submit it via their Account Health dashboard in Seller Central.
Failing to submit a valid ERN can result in offers being deactivated in non-compliant countries. As country-specific implementation guidance continues to emerge throughout 2026, sellers who have not yet registered risk being caught unprepared when enforcement begins.
What Packaging Is in Scope?
The regulation covers all packaging placed on the EU market, across both business-to-consumer and business-to-business transactions. This includes:
- Primary (sales) packaging: the packaging that forms part of the product unit for the end user
- Secondary (grouped) packaging: outer packaging containing multiple sales units
- Transport (tertiary) packaging: used for handling and shipping multiple units
- Service packaging: bags, trays, and containers filled at point of sale
- Composite packaging: made from multiple materials that cannot be separated by hand
The regulation applies regardless of the packaging material used.
Why You Should Not Wait Until August 2026
The August 2026 deadline is firm, and with enforcement just months away, the time to act is now. Here is why early action matters:
- Registration processes vary by country and can take weeks to complete
- Individual EU countries are still finalising their own implementation requirements
- Eco-fee calculations require accurate product and packaging data, which takes time to collate
- Businesses selling across multiple EU markets face multiple registration obligations simultaneously
- Non-compliance risks include offer deactivation on Amazon and eBay, regulatory fines, import disruption, and reputational damage
Starting the process now gives your business the time to register correctly, gather the data required, and submit your ERNs before enforcement begins.
How J&P Accountants Can Help
Navigating extended producer responsibility across multiple EU jurisdictions is complex. Each country has its own registry, its own deadlines, and its own reporting requirements, and managing all of this alongside running a growing e-commerce business is a significant undertaking.
J&P Accountants is a one-stop European compliance service provider with a dedicated SaaS system built to support e-commerce businesses from their first registration through to full global cross-border expansion.
As a trusted Amazon compliance service provider, we help clients meet the latest platform requirements across Amazon, eBay, and other marketplaces without disruption to their operations.
Our PPWR and EPR compliance services include:
- EPR registration and ERN procurement across multiple EU countries
- Authorised representative appointment for non-EU established businesses
- Eco-fee calculations and payment management
- Multi-country reporting and deadline management
- Ongoing compliance reviews as your product range and markets grow
- Amazon and marketplace audit support
Frequently Asked Questions
Do I need to register for PPWR if I am based outside the EU?
Yes. If you place packaged goods on the EU market, the regulation applies to you regardless of where your business is established. Depending on the country, you may also be required to appoint an authorised representative who is legally established in that member state. J&P Accountants can act as your authorised representative, managing the full registration and ongoing compliance process on your behalf.
Do I need a separate ERN for each EU country I sell into?
Yes. You must register with the producer registry in each EU country where you introduce packaged goods for the first time. This means obtaining and submitting an individual EPR Registration Number per country to relevant authorities and, where applicable, to marketplaces such as Amazon.
I already have an ERN from before the PPWR came into force. Do I need to reregister?
In most cases, existing packaging EPR registrations remain valid and do not need to be redone under PPWR. However, requirements may vary depending on the country and your specific setup. As implementation details continue to evolve, we recommend reviewing your current registrations regularly and contacting us if you are unsure about your compliance status.
Conclusion
The EU Packaging and Packaging Waste Regulation represents a meaningful shift in how e-commerce businesses must manage their packaging obligations across European markets. With the August 2026 deadline now firmly on the horizon and country-specific guidance continuing to emerge, sellers who act without delay will be far better positioned than those who wait.
Understanding whether you are classified as a producer, which countries you need to register in, and what data you need to report are the first steps. Getting those steps right requires expert guidance.
At J&P Accountants, we are here to make that process straightforward. Our team of compliance specialists works with e-commerce businesses of all sizes to ensure their cross-border obligations are met accurately, on time, and without unnecessary disruption.
Ready to get ahead of the PPWR deadline?
Contact J&P Accountants today for a free, no-obligation consultation and find out exactly what your business needs to do to remain fully compliant across EU markets.
