Quick answer
The PPWR does not create one EU packaging number. A seller must identify where it is the packaging producer, register in each relevant Member State, arrange local representation where required, and keep evidence ready for marketplaces and fulfilment providers.
What PPWR 2026 changes on 12 August
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force in February 2025 and generally applies from 12 August 2026. Unlike a directive, the regulation applies directly across the EU. It replaces the previous packaging directive while retaining a national structure for producer registration and waste management.
For cross-border ecommerce, the central question is who first makes the packaged product available in each destination market. That business can become the packaging producer for that country. It must then meet the local registration, financing and reporting requirements before placing the packaging or packaged product on that market.
The full legal text is available in the official PPWR on EUR-Lex. The European Commission also confirms 12 August 2026 as the general application date in its packaging waste overview.
The key point
A registration in France, Germany or another Member State does not cover the rest of the EU. Packaging EPR remains a country-by-country obligation.
PPWR registration is national, not EU-wide
Article 44 requires Member States to maintain producer registers. A producer may not make packaging or packaged products available for the first time in a Member State unless it, or its authorised representative where applicable, is registered there.
In practice, sellers should start with their sales and logistics flows rather than a list of websites. The relevant markets are the countries where packaged goods reach end users, and the responsible producer can change when the importer, warehouse model, delivery terms or legal seller changes.
Our EPR obligations by country guide provides an initial view of national registers and representative rules. It should be followed by a product and supply-chain assessment for each destination.
- Map every destination country where you sell packaged goods.
- Identify the producer for each sales flow and legal entity.
- Confirm the national register, producer responsibility organisation and reporting cycle.
- Keep registration numbers matched to the correct entity, country and packaging scope.
When an authorised representative is required
Article 45(3) introduces a clear rule for EU cross-border distance sales. A producer established in one Member State that sells packaging or packaged products directly to end users in another Member State must appoint an authorised representative for EPR in that destination country. The appointment must be made by written mandate.
For a producer established outside the EU, the PPWR allows each Member State to decide whether local representation is mandatory. Non-EU sellers should therefore avoid any claim that one representative setup works everywhere. The answer must be checked country by country.
A proposal to suspend the EU representative provisions was discussed, but the Council discontinued negotiations on those proposals in June 2026. Businesses should work to the regulation currently in force and the 12 August application date. The Council announcement records that decision.
France also has a separate national mandataire requirement that has applied since 10 July 2026 and reaches beyond packaging. Read our French EPR mandataire update before treating the PPWR as the only rule.
What marketplaces and fulfilment providers will check
Online marketplaces covered by the PPWR must obtain the producer's destination-country registration information and a self-certification of EPR compliance before allowing offers to consumers. They must make best efforts to assess whether that information is complete and reliable.
Fulfilment providers receive a related duty. They must obtain and assess the registration information supplied at the start of the service relationship. If information appears inaccurate, incomplete or out of date, they must ask the producer to correct it. If the producer does not do so, the provider must suspend the relevant service.
The seller remains responsible for accurate information. Marketplaces and fulfilment providers are compliance gatekeepers, not replacements for the producer. Enforcement may differ between platforms and countries, so a complete evidence pack is safer than waiting for an account warning.
- National producer registration number for each market.
- Self-certification covering the relevant packaging EPR obligations.
- Evidence of producer responsibility organisation membership where required.
- Written authorised-representative mandate where the rule applies.
A practical PPWR action plan for sellers
Start with an applicability map, then close the registration and representation gaps in order of commercial importance. Existing registrations should be checked for the correct legal entity and scope rather than assumed to be complete.
VAT EPR EXPERT FRANCE can review the countries, entities, product flows and packaging obligations in one assessment. We can then coordinate the registrations, representative mandates, producer responsibility organisation memberships and ongoing declarations that are actually required.
Use our EPR eligibility checker for an initial screen, or contact our EPR team for a country-by-country review.
Official sources
Last reviewed 26 July 2026. Rules and operational procedures can change, so confirm the current position for your exact products and sales flows.