Picture a customer who buys something small from your store — say, a phone case. The next day, a courier delivers a box where the case is floating in an ocean of bubble wrap. The customer is annoyed, you're paying for oversized shipping, and the planet gets another dose of waste.
The EU has decided to regulate this: the PPWR regulation (Regulation (EU) 2025/40) applies from 12 August 2026 (it entered into force on 11 February 2025), with further requirements phasing in through 2040. And this isn't an ordinary directive open to loose interpretation — it's a regulation that works identically in every EU country.
Sounds like a topic for the legal department? Partly, yes. But in practice, it's a topic for anyone who packs boxes and ships them abroad — which describes most online stores in Poland, and across the EU.
Quick test — if you answer "yes" even once, keep reading:
Here's the surprise: the definition of "producer" under EU law is so broad it covers practically everyone — even if you're shipping a single item in a thin envelope to a customer in Berlin. Company size doesn't matter here.
Before going any further, work out your role: producer (you design and pack the product yourself), importer (you bring goods in from outside the EU), distributor (you resell a finished product), or online seller (you ship directly to the customer). Your obligations in each country depend on which one applies to you.
Remember this rule: one store does not equal one set of obligations. A Polish store selling into Poland, Germany, France, and Czechia is, in practice, four separate puzzles. For each country you need to check separately: where the product reaches the consumer, who is responsible for the packaging, whether registration is required, and whether a local representative is needed.
There is no single, shared EU-wide register — every country runs its own. If you don't have a legal entity there, you'll usually need to appoint a local representative who registers you and reports your volumes on your behalf.
One register, one set of rules, no representative needed.
Add registration in Germany's LUCID register and — if you have no entity there — the need to appoint a local representative.
Ten registers. Ten sets of fees. Ten reporting deadlines. Often several different representatives across different countries at the same time.
Add another layer of scrutiny: marketplaces are starting to verify sellers' registration numbers themselves (Amazon already requires this), and the EU's Digital Services Act obliges platforms to check a seller's registration data before they can even start selling. Missing or outdated registration can mean your listing disappears from the platform before any authority even takes notice.
Notice the pattern: the number of countries grows linearly (1, 2, 10…), but the number of things you need to track grows much faster, because the combinations of country × role × packaging type multiply.
Packaging, materials, countries, volumes, reporting. This whole puzzle is fundamentally a data problem before it's ever a legal one. Packaging data is typically scattered across your ERP, your online store, your warehouse, and one person's private spreadsheet — the one person who happens to know where everything is. The more products and markets you have, the harder it gets to keep all of that accurate. Once you're selling into ten countries, juggling it manually in spreadsheets simply stops working.
The solution is one consistent process:
In practice, this means a PIM system — Product Information Management. It's a single, consistent source of truth for a product and its packaging. Instead of hunting for the answer to "how many kilograms of this packaging did we ship to Germany this quarter" across five different systems, you have it in one place: material, weight, market, required markings, and compliance status — ready for reporting instead of having to be manually reconstructed from memory.
We organize product and packaging data in PIM systems so it's complete, consistent across markets, and ready for reporting — without manually rebuilding it from scratch every time. If you'd like to see how this could work for your store, we're happy to show you.
Learn about PIM implementationYes, without exception. The European Commission has explicitly confirmed that e-commerce packaging falls within the definition of transport packaging.
Yes. In fact, selling to multiple countries is exactly what creates the greatest complexity, since each country has its own register and its own rules.
Yes. If you place packaging on another country's market — meaning you ship goods there to consumers — that country's registration and EPR rules apply to you. This holds even though the substance of the regulation itself is harmonized across the whole EU.
Usually the entity placing the packaging on a given market — that is, the seller, or their local representative if the seller has no entity there. Marketplaces are increasingly verifying this themselves.
No, it doesn't replace it — it harmonizes the EPR legal framework across the EU. The registers and procedures themselves remain national.
Packaging type, material, weight, quantity, country of market placement, and packaging category.
Usually yes, since there is no single shared EU-wide register.
Connect your product, packaging, and country-of-sale data into a single automated reporting process, instead of keeping it in manual spreadsheets.
Explicitly, yes. Boxes, bubble mailers, films, and void fillers used to ship online orders are covered by the regulation.
Entry into force: 11 February 2025. Most provisions apply from 12 August 2026. Further requirements — including recyclability classes and the 50% empty-space limit — phase in through 2030 and 2035.
This article is for informational purposes only and does not constitute legal advice. Implementing rules for PPWR (including the methodology for calculating empty space and recyclability classes) are still being finalized — before making business decisions, verify the current legal status for each country where you sell, ideally with a local advisor.
