PPWR from August 2026: What online retailers need to know

On 12 August 2026 the new EU Packaging Regulation (PPWR) takes effect. For many small online retailers it brings real relief – for others it brings new duties when shipping cross-border within the EU. This practical guide shows what changes and what concrete steps to take.

Table of contents

• What is the PPWR?
• Good news: domestic-only retailers get relief
• Who still has to license after August 2026
• New duty: authorised representative in other EU countries
• Examples from your industry
• Your checklist until August 2026
• Frequently asked questions
• Conclusion
• Sources

What is the PPWR?

PPWR stands for "Packaging and Packaging Waste Regulation" – formally EU Regulation 2025/40. It was published in the EU Official Journal in December 2024 and applies directly in all member states from 12 August 2026. That means: it largely replaces what was previously regulated in national laws, without Germany or any other member state having to transpose it separately.

The regulation pursues three big goals: less packaging waste, harmonised rules in the single market, and more responsibility for producers. For you as an online retailer, the key change is this: the question of who counts as the "producer" of a piece of packaging is being redefined – with concrete consequences for your duties towards national packaging registers and dual systems.

Good news: domestic-only retailers get relief

Until now: as soon as you fill a shipping package with goods and send it to an end customer, you are a "producer" under packaging law – from the very first carton. You must register with the national packaging register (in Germany: LUCID at the ZSVR), sign a contract with a dual system (licensing) and report your volumes once a year.

The PPWR changes this. Under Art. 3 No. 15 lit. a) of the Regulation, the producer is the entity that first makes the shipping packaging available in a member state. For standard shipping cartons sourced domestically, this is no longer the retailer but the domestic packaging supplier.

It follows that if you

• buy shipping packaging from a domestic supplier and
• ship exclusively to end customers within your own country,

you will likely no longer have to register or license these shipping packagings yourself from 12 August 2026. The duty moves up the chain to the packaging producer. For part-time solo online retailers with manageable volumes, this can be a real bureaucratic relief.

What does that mean for you? The annual volume report and the licensing contract with a dual system can fall away – but only as long as you genuinely sell only domestically and use standard packaging (no printed own-brand packaging).

One important caveat

The relief applies to standard shipping packaging. As soon as you have cartons printed with your own logo or commission custom packaging, the assessment can change – depending on the setup, you may still count as a producer. If in doubt, have your local chamber of commerce or a specialised lawyer check before terminating your licensing contract.

Also: the PPWR allows member states to keep stricter national rules. As of early 2026, it is not yet definitively clear whether Germany or other countries will make use of this option. Keep an eye on announcements from your national packaging register and chamber of commerce.

Who still has to license after August 2026

The relief does not apply to everyone. In three constellations you remain in the duty after 12 August 2026:

1. You source shipping packaging from abroad (e.g. cheap cartons directly from China or from an online wholesaler outside your country) and ship domestically.
2. You ship to other EU countries – regardless of where the packaging comes from.
3. You sell products with your own product packaging (sales packaging), e.g. own-brand goods in mail order. According to the Central Packaging Register Office, this duty stays with the trade.

Packaging that you distribute via a marketplace and that is handled centrally there (e.g. certain fulfilment-programme constellations) may also have special rules. Clarify this with the marketplace before changing anything.

New duty: authorised representative in other EU countries

If you regularly ship to other EU countries, the PPWR adds a new hurdle: under Art. 45 PPWR you must appoint a written authorised representative in each member state where you deliver to end customers. This person takes over registration and licensing in that country.

In concrete terms: anyone selling to France, Italy, Spain, Poland, Belgium etc. needs an authorised representative in each of those countries. Marketplaces such as Amazon, eBay or Etsy are required by Art. 45(4) PPWR to obtain proof of registration and authorised representative status from sellers.

Providers typically charge an annual flat fee for the representative role, depending on the country and provider in the lower to mid three-digit range per country. For retailers with only a handful of cross-border parcels per month, this can make EU shipping economically unattractive.

Important context: In December 2025 the EU Commission proposed suspending the AR obligation for EU-based companies until 2035. Until that proposal is finally adopted, however, you should plan for the original rules and prepare in time.

Examples from your industry

Example 1: Etsy seller from Berlin. Maja sells handmade ceramics. She buys her shipping cartons from a wholesaler in her region. She only ships within Germany. From 12 August 2026 she will likely no longer have to report or license her shipping cartons – the duty moves to the carton supplier. It would look different if she regularly sold to Austria or France: then she would need an authorised representative there.

Example 2: Part-time Amazon FBA seller. Tobias sells outdoor accessories via FBA. He has his sales packaging produced in China and imported into Germany. The relief does not apply here: with packaging sourced from abroad he remains a producer under Art. 3 No. 15 PPWR and licensing applies. He also has to clarify how his FBA distribution to other EU countries plays out – Amazon will actively request the proofs under Art. 45(4) PPWR.

Example 3: Joinery with a small online shop. The Wagner family ships occasional handmade pieces from southern Germany via a WooCommerce shop, always within Germany, with standard cartons from the region. This is where the relief is greatest: likely no register obligation, no licensing contract, no volume report. Even so, the Wagners should follow the national implementation and document their supply chain.

Your checklist until August 2026

To avoid panic in August 2026, this preparation is worth starting now:

• Check your sources: do your shipping packagings really come from a domestic supplier – or do you order from an online retailer that imports from abroad? Get this confirmed in writing.
• List your shipping destinations: do you ship only domestically, or do some parcels go into the EU? Note the countries with volumes.
• Look at sales packaging separately: own-brand packaging often stays subject to licensing. Clarify for each product whether the sales packaging is own-brand or standard.
• Wait for marketplace announcements: Amazon, eBay, Etsy, Otto Market and others will communicate their requirements ahead of August 2026. Watch your accounts.
• Keep your packaging register entry – do not delete yet: as long as the national implementation has not been finally clarified, do not terminate any existing dual system contracts.
• Keep your records clean: good document management (supplier invoices, shipping records per country, licensing documents) helps you prove your position. With PepperTools Supplier orders and Invoicing you have these documents at hand at any time.

Frequently asked questions

When does the EU Packaging Regulation PPWR apply?

The central application date is 12 August 2026. Individual provisions (e.g. on recyclability or specific bans) take effect on later dates.

As a small business, am I exempt from all packaging duties from August 2026?

No. The relief only covers shipping packaging sourced and shipped purely within one country. Anyone selling own-brand products, shipping to other EU countries or sourcing packaging from abroad remains generally in the duty.

What is an authorised representative and is it expensive?

An authorised representative is a person or company based in the respective EU country who takes over your packaging-law duties there. Costs vary widely by country and provider and can noticeably increase the cost of an EU strategy.

Should I delete my packaging register entry?

No, rather the opposite: as long as the national implementation has not been finally clarified, keep your register entry and licensing contract.

What happens if I do nothing?

Until 12 August 2026 the existing rules of the national packaging law continue to apply. Anyone currently subject to duties stays subject. Only from that date does the legal situation change.

Conclusion

The EU Packaging Regulation brings real simplification for many small online retailers in pure domestic business – but it is no carte blanche. Anyone selling to other EU countries, shipping own-brand packaging or importing packaging should prepare in good time for new duties, above all the authorised representative in other EU countries. Clean documentation of your sources, shipping destinations and licensing documents is the most important preparation. With digital document management in PepperTools you have the proofs ready at the press of a button.

Sources

1. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), EUR-Lex — official regulation text including Art. 3 (definitions) and Art. 45 (extended producer responsibility).
2. IHK Schleswig-Holstein: Duties under the EU Packaging Regulation (PPWR) from 12 August 2026 — chamber of commerce overview for businesses.
3. DIHK information sheet on the EU Packaging Regulation (PDF) — detailed DIHK guide on duties and transition periods.
4. Stiftung Zentrale Stelle Verpackungsregister (ZSVR) — official German body for packaging registration; current PPWR implementation guidance.
5. Bavarian State Office for the Environment (IZU): Overview of Regulation (EU) 2025/40 — official environmental authority summary of PPWR.

Note: This article does not constitute tax or legal advice. For your individual case, please consult a tax advisor or lawyer.