PPWR 2026: What Small Online Sellers Need to Do Now

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The EU Packaging and Packaging Waste Regulation (PPWR) started applying on 12 August 2026.
If you are a small Etsy, Shopify or other non-EU seller shipping physical products to EU customers, you may now be wondering whether you need to register for packaging EPR, replace your packaging or even stop selling to certain EU countries.

The short answer is: do not panic and do not automatically stop your EU sales.
For most small overseas sellers, the practical first step is to understand which EU countries you actually sell to, identify the packaging you use, keep basic packaging records and check the applicable national EPR procedure for those markets.

What Is the PPWR and How Is Packaging EPR Connected?

PPWR is the EU regulation covering packaging throughout its life cycle. It sets rules on matters such as packaging materials, recyclability, labelling and waste management. European Commission overview.

Packaging EPR (Extended Producer Responsibility) deals with businesses’ responsibility for packaging after it becomes waste. Businesses covered by the system contribute to the costs of collecting, sorting and recycling that packaging, and may also have organizational responsibilities. EPR is an established approach under EU waste law. European Commission explanation of EPR. 

Packaging EPR existed before the PPWR. The PPWR incorporates and updates packaging EPR rules within its broader framework, while registration, reporting and fee arrangements remain administered through national systems. These obligations can apply to sellers placing packaged products on a market, including overseas online sellers, as well as packaging manufacturers. PPWR, Articles 3 and 44–46.

So… What should I do?

Legal rules and practical procedures are not always the same.

The PPWR sets common EU rules, but packaging EPR registration, reporting and local authorized representative procedures are still operated separately by each country. Some countries already have an official procedure that overseas sellers can use. In other countries, the new registration or authorized representative procedure is still unclear or unavailable.

You cannot complete a procedure that does not yet exist. You should therefore deal only with the countries where you currently sell and take the action that matches your actual situation.

Your current situation
What to do
You are already registered for packaging EPR in a country
Maintain your existing registration, reports, PRO membership and fee payments. If your provider or the official register later asks you to add an authorised representative or update your details, complete that additional step.
You are not registered and have not received any request from a platform or authority
Begin keeping basic packaging records and check the current national EPR requirements only in the countries where you actually send orders. If a clear official requirement applies to you, take the relevant steps for that country.
A marketplace, authority or EPR organisation asks for a registration number, representative or other action
Check the requirement for that country and complete the applicable official procedure. A request concerning one country does not normally apply to your other EU markets.
No clear and usable procedure is available for overseas sellers
Keep evidence of the official sources or enquiries you checked and monitor the relevant authority or register. The absence of a usable procedure is not an exemption. Act when one becomes available, but do not pay for a representative solely because a service provider says one is required.

Selling only a few items does not automatically provide an EU-wide exemption from packaging EPR. However, it also does not mean that you should immediately pay for registrations and representatives in every country.

For a small seller, the practical starting point is to record the packaging you use, check only the countries where you actually sell and complete any clear and applicable official procedure that is available. Do not close all EU markets without first understanding the actual requirements.

What to start doing now

Start now
Simple action
List your packaging
Write down the boxes, envelopes, product packaging, protective materials and tape used for EU orders.
Record the material
Note whether each item is paper, cardboard, plastic, glass, metal, wood or another material.
Record the weight
Weigh one example of each packaging item. If you cannot weigh it, use supplier information or a reasonable estimate and mark it as estimated.
Record the quantity by country
Record how many of each packaging item you use for orders sent to each EU country.
Keep existing documents
Keep packaging invoices, receipts, supplier details and any material information you already have. You do not need to create information that is not currently available.
Check food-contact packaging if relevant
Food-contact packaging must comply with the PFAS concentration limits applying from 12 August 2026. This particular requirement does not apply to ordinary packaging that is not intended to contact food.

Example of a simple packaging record

Germany

Packaging type
Mailing box
Material
Paper/cardboard
Weight per item
65 g
Quantity used
2
Total weight
130 g
Source
Measured

France

Packaging type
Mailing envelope
Material
Paper
Weight per item
About 25 g
Quantity used
30
Total weight
About 750 g
Source
Estimated

Ireland

Packaging type
Protective paper
Material
Paper
Weight per item
About 8 g
Quantity used
8
Total weight
About 64 g
Source
Estimated

Ireland

Packaging type
Paper tape
Material
Paper/adhesive
Weight per item
About 4 g
Quantity used
5
Total weight
About 20 g
Source
Estimated

You do not need a perfect spreadsheet or specialist software. A simple note showing the destination country, packaging material, approximate weight and quantity is enough to begin.

What to prepare later

Prepare gradually
What this means
Supplier information
When buying or reordering packaging, keep any material specifications, declarations or technical information supplied with it.
Simpler packaging
When you need new packaging, consider choosing simple materials that are commonly recycled. You do not need to discard your current packaging solely for this reason.
EU packaging labels
Wait until the final format and applicable date are confirmed. The harmonised label requirement will apply from 12 August 2028 or 24 months after the relevant implementing rules enter into force, whichever is later.
Main 2030 requirements
Prepare gradually for recyclability, recycled plastic content, packaging minimisation and empty-space requirements. Detailed assessment methods and implementation rules are still being developed.

What you do not need to do now

Do not do this merely because of the PPWR
Reason
Replace all your existing packaging
The PPWR does not require every seller to discard all packaging immediately. Requirements already applying to particular packaging, such as PFAS limits for food-contact packaging, must be considered separately.
Buy or request a general “PPWR certificate”
There is no single official certificate covering every business, packaging type and EU country. Keep genuine material or technical information when available, but do not buy or ask suppliers to create a certificate with no clear legal meaning.
Register in all 27 EU countries
You only need to consider the countries where you actually sell and the official procedures that apply there.
Stop all EU sales
Do not stop selling solely because the PPWR has become applicable. Check the actual situation in the countries where you sell.
Add your own PPWR mark
Do not create or add an unofficial PPWR mark before the official label format and application date are confirmed.
Use your GPSR Responsible Person as your packaging EPR representative
These are different legal roles. The same details must not be used without a separate valid appointment.

The European Commission has explained that early enforcement should not disrupt trade, supply chains or consumer access to goods. Where non-compliance is identified, the business should generally first be informed and given an opportunity and reasonable time to correct it. This is not a general exemption, but it supports a practical approach: check the situation, correct what is necessary and avoid closing all EU sales without first understanding the actual requirement.

Unsure What the PPWR Means for Your Business?

Optimalcert provides EU Responsible Person services under the GPSR and does not directly provide packaging EPR or PPWR registration services. However, I will continue monitoring the official registration and authorized representative procedures introduced by individual Member States and provide another update when additional action becomes practically necessary for small overseas sellers.

If you are unsure which requirements apply in a country where you currently sell, or if you feel that the new rules may significantly disrupt your business plans, please contact me before purchasing a packaging compliance service or stopping your sales. I will help you review the situation and decide what action is actually necessary.

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