If you are an online ecommerce store owner or someone who’s into frequent exports and imports and selling your products into the EU countries, you’ve got to be careful from now onwards, as PPWR 2026 applies from August 12, 2026.
It doesn’t matter whether you’re running your business in Manchester (the United Kingdom), Beijing (China), Sydney (Australia), or Ohio (the US). If you are selling your products to EU customers, you have to follow PPWR. It is applicable across all 27 EU member countries. Your packaging and every box, bag, and bit of tape you ship into the bloc must be as per the standards mentioned in PPWR 2026.
Recently, we spoke to Jon Greenwood, Director at Limmys, part of SL2 Group, and a WorldFirst ambassador, who have spent the past few months getting their business ready for the deadline. He said: “The issue appears to be that people either don’t really understand what it is, they don’t know it’s coming, they’re misunderstanding the rules, they’re being badly advised, or not getting consistent messages from different places — it’s a bit of a mess.”
In this guide, we’ll explain what PPWR actually is, walk through the EPR registration process, bust a myth about Amazon that’s catching sellers out, and set out exactly what to do before the deadline lands.
Key Takeaways
- The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) applies from August 12, 2026.
- Compliance requires both paying Extended Producer Responsibility (EPR) fees where applicable and ensuring that the packaging meets the applicable composition and sustainability requirements.
- PPWR sets a combined concentration limit of 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium in packaging and packaging components. It also introduces restrictions on PFAS in food-contact packaging from August 12, 2026.
- EPR registration is required on a country-by-country basis, meaning low-volume markets can carry full compliance and registration costs.
- Amazon’s “Pay on Behalf” scheme does not automatically replace individual country EPR registrations or other legal obligations.
- Packaging composition rules apply to packaging and packaging components, and businesses may need Declarations of Conformity and supplier evidence to demonstrate compliance with the applicable requirements.
- Non-compliance risks may include marketplace account suspensions, financial fines, and legal scrutiny. Stock placed on the EU market before the application date may be covered by transitional provisions for certain requirements.
- Achieving early compliance can help avoid sudden sales disruptions across EU marketplaces.
What Is PPWR?
PPWR stands for the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It entered into force on February 11, 2025, and applies from August 12, 2026. This regulation now applies directly across the EU and covers packaging and packaging waste.
This regulation replaces Packaging Directive 94/62/EC that had governed EU packaging rules.
Unlike its predecessor, PPWR isn’t a directive that each country interprets in its own way. It is an EU regulation and applies directly in all 27 member states without national transposition. Thus, even businesses who are sourcing their products from non-EU markets like the US, Malaysia, India, and China can’t ignore this rule as something not relevant to them. Because any packaged products that enter the EU market have to comply with the applicable PPWR requirements.
Two Key Components of PPWR
Extended Producer Responsibility, EPR: In simple terms, you’ll pay to cover the cost of recycling the packaging you put on the market, where EPR obligations apply.
Packaging composition rules: You must be able to prove that your packaging meets the applicable restrictions on certain substances. PPWR sets a combined concentration limit of 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium in packaging and packaging components. It also includes restrictions on PFAS in food-contact packaging from August 12, 2026.
In its simple sense, EPR means if a seller is selling his packaged products in any EU country, he’ll be also liable for paying to collect and recycle that package, depending on the applicable national EPR rules.
The EPR Registration Problem
The European Union wants one single system where you register once and follow one set of rules for all of Europe. But at present, every EU country runs its own separate EPR system.
Suppose, you’re an exporter who sells goods in Austria, Poland, and Italy. In this case, you’ll have to register separately in all three EU countries if you fall within the relevant producer registration requirements. Also, you’ll have to submit separate packaging reports to each country where you are required to register and pay necessary fees according to each country’s system.
The new PPWR regulations are now also targeting online sellers and businesses outside the EU like UK, US, or Asian sellers. If you ship packaged products directly to customers in EU countries, you need to check your EPR registration and other PPWR obligations in every EU country where you are required to register and comply with the applicable deadlines.
Every country you sell into may require its own EPR number and its own filing, depending on the national rules.
Physically holding stock in a country may also create a registration requirement, depending on how the products are placed on that market.
Jon shared a real example from their own compliance work: getting an EPR registration number in some countries can cost between €500 and €1,500.
For an SMB that has a modest annual turnover, it can be challenging, as the registration cost can outweigh the profit the market generates.
As Jon put it: “Why spend a thousand euros on this if you’re not going to make €1,000 in profit?”
Firms like Limmys, where Jon is an employee, have made a deliberate call. Taking a decisive step forward, they’ve now decided not to sell into certain lower-volume EU countries where EPR registration is not financially viable for them.
It’s not an emotional decision, but a prudent one. For smaller markets or when selling products in certain EU countries, walking away can be a wise decision rather than complying with the regulations, which could be financially draining for SMBs earning moderate profits.
If you consider some markets are worth keeping, budgeting matters. Quoted registration fees are often in euros, and if your revenue is in sterling or dollars, currency movement can quietly inflate what you thought you’d budgeted.
Businesses paying compliance consultants, Producer Responsibility Organisations, or EU-based agents in euros often use a multi-currency account to hold and pay from local currency balances rather than converting on every invoice.
The Amazon “Pay on Behalf” Confusion
Amazon runs an EPR Pay on Behalf service in several markets. If a seller hasn’t uploaded a valid EPR number, Amazon can offer to handle certain EPR obligations on their behalf and charge the applicable service fees and eco-contributions. Many sellers assume that because Amazon is quietly remitting these sums, they’re fully compliant. They aren’t necessarily.
Adding further, Jon said: “There’s an expectation that Amazon’s Pay on Behalf scheme on its own is sufficient now, but… everybody needs to have these EPR numbers as well. That’s the bit that seems to be getting missed.”
Pay on Behalf means Amazon can file certain EPR declarations and make payments on behalf of the seller, but the seller remains responsible for meeting the legal requirements that apply to them. If you continue to rely on it alone, it can put you in trouble.
Take, for instance, Amazon can block a seller from selling into a given country if the seller does not meet the applicable EPR requirements. In markets like Germany, selling without a valid packaging registration can trigger listing deactivation and other enforcement measures. It’s worthwhile to mention here that Germany has enforced packaging registration through its LUCID system since July 2022, and Amazon has required sellers to provide valid registration information for affected packaging obligations.
Packaging Composition: What You Should Know
Every seller also has to prove that their packaging doesn’t contain harmful substances. Especially, these chemicals and substances are checked, like lead, cadmium, mercury, and chromium. PFAS include a family of over 10,000 chemicals and compounds that can be found in a wide range of products, packaging, and in the environment. Considering their omnipresent nature, they are also called forever chemicals. But Europe has already started taking various initiatives to reduce exposure to these chemicals, as they could directly impact the environment and human lives as well.
What Does PPWR Check in Your Packaging Components?
- Outer box and bag
- Printing ink
- Labels and barcode ink
- The product itself
- The adhesive tape used to seal the parcel
For each of the components mentioned, you have to furnish supporting evidence like a Declaration of Conformity. So, if you are sourcing any product into the EU market, you should ask your wholesalers or factory owners to provide you with a copy of the test data, clearly mentioning which chemicals were used in the packaging components and to what limit. If the names of these chemicals don’t contain any restricted substances, you need not worry.
Discussing the same, Jon said, “You need to demonstrate that every part of your packaging is compliant… you have to talk to your factories, all your suppliers, and get them to provide evidence of the testing.”
Don’t Ignore Your Shipping Cartons
If your outer shipping or master carton carries your company name, logo, or trademark, it automatically counts as packaging and falls under EPR obligations.
“Even if you ship everything in recyclable paper, you still have to pay EPR on it,” Jon added.
Case Study: How Is Limmys Complying with PPWR-2026
Limmys have been proactive on PPWR-2026 for their business. They had applied for EPR numbers before the set deadline of August 12, 2026, when the PPWR will come into effect. In order to avoid the last-minute rush.
Also, they made the deliberate call to stop selling into lower-volume EU nations where registration costs quietly eat into the margins that sellers are earning.
In other words, the cost of EPR registration is just too high compared to the expected level of margins to be earned, especially in the online selling segment and dropshipping, where the margin is already too thin.
For the compliance part, Limmys have consulted with an external compliance consultancy to manage the ongoing registration and reporting process.
For a business selling across multiple EU markets, paying an EU-based compliance consultancy or a PRO isn’t a one-off cost. It’s a recurring, euro-denominated outgoing.
Sellers who’ve expanded internationally often find it easier to manage this alongside supplier payments and marketplace payouts through the same cross-border payment setup they already use for sourcing stock, rather than running separate bank transfers for every EU country’s registration fee.
What’s Next After August 12, 2026?
- Minimum recycled content requirements for packaging
- Packaging minimisation rules, including limits on empty space in parcels. An unavoidable technical need exemption aside, empty space in e-commerce parcels must not exceed 40% from August 12, 2026.
- Further recyclability and design requirements phased in through 2030, 2035, and 2040
Jon explained, “This is a new law, and as a business you’ve got a responsibility to do things the right way. Whether you agree with it or not, you have to do what you’re asked to do.”
What Actually Happens on 12 August if You’re Not Compliant?
It could mean Amazon blocking sales into a given country or direct fines from national authorities. If non-compliance turns out to be widespread across the EU market and in many EU member countries, sellers can expect some form of grace period. But things will get clear only after a few days have passed after the deadline.
As a matter of relief, PPWR will not be applicable retrospectively. It means if the packaging was already placed on the EU market before the deadline, it won’t be needed to comply with PPWR. But the obligation applies to all newly produced or imported packaging after August 12.
Is EPR Registration Actually Worth It For?
According to Jon, “there’s no universal answer when it comes to specifically pointing out which countries should require no EPR registration. He said it comes down to running the numbers for your own sales volume, market by market. There’s going to be a lot of competitors who don’t get this right or comply with PPWR. Meanwhile, if you can do it well and others can’t, that’s a competitive advantage.”
His closing advice was the simplest line of the whole conversation: “If people haven’t started, start. You can’t escape it. This is happening now.”
How Can WorldFirst Help You in Your Cross-Border Trade in EU Countries?
If you’re weighing up whether a lower-volume EU country is worth the EPR registration cost, that calculation depends on your actual margins in that market. You have to factor in how much currency conversion charges and payment fees are eating into what you collect from that EU nation. A business collecting revenue through a multi-currency account, such as WorldFirst’s marketplace collections, which supports payouts from 130+ marketplaces, has clearer visibility into true per-country profitability than one losing an unknown percentage to conversion fees along the way.
Another point is that paying for EPR registration itself, along with any compliance consultancy fees, often means sending payments to service providers or authorities in a different currency from your home base. Businesses managing multiple supplier and compliance payments across currencies can use WorldFirst’s forward contracts to lock in a rate ahead of a known upcoming cost. This ensures that a EUR-denominated registration fee doesn’t increase in value due to FX fluctuations.
A multi-currency World Account also makes it simpler to pay suppliers or compliance partners in 100+ currencies without opening a separate local bank account in every country involved.
A Practical Checklist Before 12 August 2026
Map every EU country you sell meaningful volume into, or hold stock in, and check that country’s EPR registration requirements.
Don’t assume Amazon’s Pay on Behalf service makes you compliant. Instead, you should get your own EPR number in each relevant country.
Contact your factories and suppliers now for Declaration of Conformity documentation and substance test data, covering every item that was used in the packaging process, like boxes, ink, labels, and tape.
Check out whether some of the lower-volume EU markets are actually worth the registration cost.
Decide if your branded shipping cartons need to be brought into your EPR reporting. An external consultant who has an idea about it can help you determine it accordingly, as per the latest PPWR rules and regulations.
Budget for registration and consultancy fees in euros, and think about how you’ll pay suppliers, PROs, and compliance consultants across borders without losing margin to FX swings.
FAQs
1. What is PPWR in one sentence?
PPWR (Regulation (EU) 2025/40) is the EU’s new packaging law. It requires anyone placing packaging on the EU market to register for and pay Extended Producer Responsibility fees and prove their packaging is free from certain restricted substances with effect from 12 August 2026.
2. Does PPWR apply to UK sellers?
Yes. PPWR applies to anyone selling packaged goods into the EU market.
3. Is Amazon’s Pay on Behalf scheme enough to make me EPR compliant?
No. Pay on Behalf covers the remittance of eco-contributions Amazon calculates on your behalf, but sellers are still required to hold their own valid EPR registration numbers in each relevant country.
4. Do I need a separate EPR number for every EU country?
Yes. Because there’s no centralised EU-wide EPR system yet. Each member state runs its own registration and reporting requirements.
5. What happens if I’m not PPWR compliant by 12 August 2026?
Possible consequences include marketplaces blocking your listings in a given country, fines from national regulators, or might invite legal troubles.
6. Do unbranded shipping cartons count as packaging under PPWR?
If your outer shipping carton carries your company name, logo, or trademark, it counts as packaging and falls under EPR.
7. Watch Jon Greenwood’s full case study interview with WorldFirst on YouTube.
If you’re managing cross-border payments, supplier costs, or compliance fees across multiple EU markets, see how WorldFirst can help you manage international payments as you get PPWR-ready.
Sources
- https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- https://www.gleisslutz.com/en/know-how/new-eu-packaging-regulation-key-requirements-august-2026 https://www.coolset.com/academy/packaging-and-packaging-waste-regulation-ppwr-essentials
- https://www.complir.io/resources/guides/ppwr-explained
Interview source: Phone call with Jon Greenwood, WorldFirst ambassador and Director of Limmys (SL2 Group),
- https://www.worldfirst.com/uk/ WorldFirst
- https://www.worldfirst.com/uk/product/collect/get-paid-by-marketplaces/ https://www.worldfirst.com/uk/product/pay/pay-business-partners/
- https://www.worldfirst.com/uk/product/
- https://www.dw.com/en/eu-waste-forever-chemicals-pfas-cancer-packaging-plastic-pollution-recycling-graphics/a-78326555
- https://www.dhl.com/discover/en-hk/logistics-advice/import-export-advice/eu-packaging-regulations
- https://www.ppwr-guidebook.eu/about-the-ppwr/
- https://envirotecmagazine.com/2026/08/12/new-eu-packaging-rules-target-waste-and-resource-use/
