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EU Packaging Regulation PPWR Mandatory 12 August 2026 – Ecommerce Brands Must Act

PPWR applies to 100% of packaged products entering the EU market, and it’s the manufacturer’s responsibility to ensure their packaging documentation is compliant.

In This Article

01What PPWR requires of brands
02The Authorised Representative option
03What's in scope under PPWR
04Marketplace accountability for sellers
05What to do before August

Key Takeaways

►Authorised Representative is optional for non-EU manufacturers
►100% of packaged products fall within PPWR's scope
►Marketplaces must verify seller PPWR compliance
►PFAS banned in food-contact packaging above 25ppb

Regulation (EU) 2025/40, the EU Packaging and Packaging Waste Regulation (PPWR), becomes mandatory on 12 August 2026. For US brands entering EU markets, it extends compliance beyond the product to the box it ships in. With typical Expandly onboarding running three to six months, brands that have not started PPWR planning should start this week.

100%of packaged products entering the EU market fall within PPWR's scope from 12 August 2026. The focus is on the packaging the manufacturer supplies with the product

PPWR entered into force on 11 February 2025. It applies to 100% of packaged products placed on the EU market, and the focus is on the packaging the manufacturer supplies with the product. Three things matter most for ecommerce brands: it is the manufacturer's responsibility to review that their packaging technical documentation meets PPWR's requirements, a PFAS ban applies to food-contact packaging above 25 parts per billion, and every packaging format needs a declaration of conformity (DoC). Non-EU manufacturers may also appoint an Authorised Representative for packaging, though this is optional rather than mandatory under PPWR.

Online marketplaces carry an explicit verification duty under PPWR. The regulation makes platform operators responsible for ensuring sellers meet packaging requirements, and provides for seller suspension where they do not. For brands selling on Amazon DE, Bol.com or other EU platforms, PPWR non-compliance creates a regulatory risk and a delisting risk at the same time.

  • Scope: PPWR applies to 100% of packaged products entering the EU market — the focus is on the packaging the manufacturer supplies with the product
  • Manufacturer responsibility: it is up to the manufacturer to review that their packaging technical documentation meets PPWR's requirements
  • Authorised Representative: non-EU manufacturers may appoint one for packaging, but this is optional, not mandatory, under PPWR
  • PFAS ban: food-contact packaging with PFAS above 25 ppb is prohibited, affecting greaseproof papers, pouches and food-safe containers
  • Online marketplace accountability: platforms must verify seller PPWR compliance, and non-compliant sellers face suspension

PPWR compliance is part of Expandly's standard EU market entry review. Our compliance team can share documentation templates and review packaging technical documents to help manufacturers issue their Declaration of Conformity before any stock moves to the EU.

Expandly helps US ecommerce brands expand into Europe — compliance, marketplaces and fulfilment, all handled. We’ve supported 2,000+ brands make the move.

Find out more
  • VAT registration handled across UK, Germany, Netherlands and all EU markets
  • EPR compliance managed from day one — packaging, WEEE, batteries and beyond
  • Product label review and Responsible Person service for EU and UK market entry

The bigger picture

What PPWR signals for EU market entry

PPWR extends EU environmental compliance from the product to the packaging around it, and it adds explicit marketplace accountability that creates a dual enforcement risk for non-compliant sellers. For a US brand, packaging decisions made at home now carry direct EU regulatory consequences, and it is the manufacturer's responsibility to review that their packaging technical documentation meets PPWR's requirements. Expandly's compliance-first onboarding runs product and packaging compliance with VAT setup in parallel from day one. Our compliance team can share documentation templates and review packaging technical documents to help manufacturers issue their Declaration of Conformity ahead of 12 August, reducing the risk of fines and marketplace suspension that both apply from that date.

  • Appointing an Authorised Representative is optional under PPWR, not mandatory — manufacturers remain responsible for their own packaging technical documentation either way
  • Expandly's compliance team supports PPWR compliance by sharing documentation templates and reviewing packaging technical documents to help with issuing a Declaration of Conformity
  • EPR registration, required separately under existing EU member state rules, runs in parallel with PPWR, and both must be considered before product reaches EU consumers

European Ecommerce Market

European ecommerce is projected at $895 billion in 2026. Marketplace accountability for seller packaging compliance is now written into EU law under PPWR, so brands without compliant packaging face both regulatory fines and marketplace suspension from 12 August.

$895B

projected EU ecommerce revenue in 2026 (Statista / Profitero, 2026)

PPWR Scope

PPWR applies to 100% of packaged products entering the EU market. The focus is on the packaging the manufacturer supplies with the product, and it's the manufacturer's responsibility to ensure that packaging's technical documentation meets PPWR's requirements.

100%

of packaged products in scope under PPWR from August 2026

Compliance-First Onboarding

Product compliance and VAT setup run in parallel from day one. From there, VAT registration, marketplace setup and EU-local fulfilment follow in the right order.

2,000+

brands expanded with Expandly

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