The EU’s Packaging and Packaging Waste Regulation (PPWR) sets a new, directly applicable framework for packaging and packaging waste across all materials and sectors.

This page focuses on the part that tends to create the most day-to-day work for companies selling into multiple EU countries: packaging Extended Producer Responsibility (EPR).

The PPWR applies from 12 August 2026 (and it formally entered into force 20 days after publication in the Official Journal).

What “packaging EPR” means under PPWR

EPR is the mechanism that finances and organises packaging waste management: collection, sorting, treatment, and the system costs around it. PPWR builds on the general EPR rules in the Waste Framework Directive (Directive 2008/98/EC) and adds packaging-specific provisions where needed.

In practical terms, PPWR is nudging EPR toward:

• clearer roles (who is the producer),
• more consistent registration/reporting expectations,
• stronger cross-border controls (especially for distance selling and marketplaces).

Who counts as the “producer”

A common pain point in packaging EPR is that “producer” doesn’t automatically mean “brand owner”.

Under PPWR, the producer is generally the party that makes packaging or packaged products available in a Member State for the first time (and in some cases, the party that unpacks packaged products without being an end user).

That means responsibility can shift depending on your setup:

• local EU entity vs. non-EU seller shipping directly to consumers,
• importer-of-record models,
• private label / trademark-driven distribution,
• marketplace fulfilment structures.

A quick producer-role check up front saves a lot of confusion later– especially when you expand into new EU countries.

Registration becomes the “proof of compliance” centrepiece

PPWR introduces a more structured approach to producer registration:

• Member States must set up national producer registers (with links to other national registers to make cross-border registration easier).
• Producers must register in each Member State where they first make packaging/packaged products available (or unpack packaged products without being end users).
• Importantly, PPWR also states that producers should not place packaging/packaged products on a Member State market for the first time if they (or their authorised representative, where applicable) are not registered there.

If you’ve dealt with Germany’s packaging rules before, this will feel familiar: Germany already expects businesses distributing packaged goods to be registered in the LUCID register. VerpackungsregisterPPWR’s direction is to make this “registration-as-gatekeeper” approach more consistent across the EU over time.

Authorised representatives: especially relevant for cross-border e-commerce

For companies that aren’t established in a Member State, PPWR implementation guidance highlights that an authorised representative for EPR shall be appointed in each Member State where the producer is not established (and Member States may decide to extend this to producers in third countries).

In other words: if you sell D2C across several EU markets from outside those countries, authorised representative coverage becomes a practical part of staying continuously compliant.

Marketplaces and fulfilment providers will ask for evidence

PPWR connects packaging EPR to the enforcement logic of the Digital Services Act (DSA) for certain online platforms.

The Regulation explains that where online platforms enable distance contracts with producers, they should obtain information about those producers’ EPR compliance before letting them use the service – and the producer register is treated as a public register for these checks. PPWR also flags similar “free-riding” concerns for fulfilment service providers.

Separately, the Commission’s PPWR stakeholder presentation summarises the expectation in very operational terms: online marketplaces check EPR compliance in the register; fulfilment service providers also check compliance.

What this looks like in real life: onboarding questionnaires, “upload your registration proof” requests, and periodic re-checks – especially when you expand into a new Member State.

Reporting: more structure, more comparability

Most EPR reporting challenges aren’t caused by the forms – they’re caused by the underlying packaging dataset.

PPWR implementation guidance points toward:

• greater granularity in reported data (with a lighter approach indicated for producers placing less than 10 tonnes on the market), and
• a Commission implementing act intended to set a harmonised format for registration and reporting (including packaging types/material).

The direction is clear: better comparability across Member States, and fewer “country-specific interpretations” in how the same packaging is classified and reported.

Fees and “who pays what”

Packaging EPR fees are still administered nationally, but PPWR reinforces the polluter-pays logic and the expectation that producers finance the system.

The Regulation also explicitly notes that financial contributions should be without prejudice to voluntary agreements where online marketplaces, with a written mandate, accept all or part of those costs on behalf of producers.

So while EPR fee responsibility sits with producers, commercial arrangements can vary – especially in marketplace ecosystems.

How Viron helps

Viron Compliance Ltd supports companies selling packaged products into the EU by keeping packaging EPR straightforward and audit-ready:

• producer-role assessment per Member State (including distance selling and marketplace models),
• registration strategy and coordination (including authorised representative coverage where needed),
• packaging data structuring that supports consistent multi-country reporting,
• evidence packs that work for partner checks (marketplaces, fulfilment providers, distributors).