August 12 Has Passed. What Actually Happened?
The Packaging and Packaging Waste Regulation (PPWR) — Regulation (EU) 2025/40 — officially took effect on August 12, 2026 across all 27 EU member states. This is the date sellers have been hearing about for months: the moment when marketplaces would supposedly start mass-delisting non-compliant products.
The reality? No apocalypse — but no free pass either. Marketplaces have not started pulling products en masse. Instead, they're taking a more measured approach: requesting confirmation that sellers are aware of their EPR obligations and have initiated the registration process. Think of it as a warning shot, not a ceasefire.
Amazon's enforcement history is consistent: soft warnings first, then hard delistings. Germany LUCID (2022), WEEE (2023), Battery Regulation (2025) — the pattern is always the same. The PPWR will follow.
Marketplace by Marketplace: What's Happening Now
Amazon
NotificationsAmazon has been sending notifications to sellers in Poland and Sweden, and to some sellers in France, requesting confirmation of EPR compliance. No mass deactivations yet. In Germany and the Netherlands, the existing LUCID and packaging registrations continue to apply. Amazon confirmed that in countries where national EPR registers haven't opened yet (e.g. Italy), absence of a number will not affect listing status — for now.
eBay
MonitoringeBay has published updated seller guidelines referencing PPWR but has not yet started active enforcement or sending individual notifications. Sellers should expect verification requests in the coming weeks.
Temu & TikTok Shop
ActiveBoth platforms demonstrated they take enforcement seriously on August 18, 2025 when they deactivated non-compliant battery offers simultaneously with Amazon. For PPWR, both platforms are requesting EPR documentation from EU sellers. Temu is especially aggressive with Chinese sellers, requiring Authorized Representative proof upfront.
Zalando & Otto
MonitoringGerman-based marketplaces already required LUCID packaging registration. The PPWR broadens this to all EU countries. No additional enforcement actions observed beyond existing requirements so far.
Why This "Soft Start" Should Worry You
Amazon's enforcement history follows one pattern, every single time:
- Announce the requirement months in advance
- Send notifications and collect registration numbers
- Deactivate non-compliant listings — often on the deadline day itself
This happened with LUCID in June–July 2022. With WEEE throughout 2023. With batteries on August 18, 2025 — when Amazon, Temu, and TikTok Shop all deactivated non-compliant offers on the same day, in four countries simultaneously. Right now, we're in phase 2 for PPWR. Phase 3 is coming.
The EU Commission's own FAQ states that enforcement should be "practical and not disrupt trade." This means authorities will focus first on sellers who make zero effort. But if you haven't started anything, you're in the worst possible position when actual deactivations begin.
Pay-on-Behalf No Longer Saves You
Many sellers relied on Amazon's Pay-on-Behalf program, which collected eco-contributions on their behalf in countries like France. Under PPWR, marketplaces are now required to verify that sellers hold their own EPR registration in each country. Pay-on-Behalf continues to exist, but it does not replace the obligation to have your own registration number. Having Pay-on-Behalf without your own EPR registration means you're technically non-compliant.
Authorized Representative for EPR: Not Just for Non-EU Sellers
This is the part most sellers get wrong. Article 45(3) of the PPWR requires anyone who supplies packaging or packaged goods directly to end users in an EU country where they are not established to appoint an authorized representative there. This applies to EU companies too — not just Chinese or US sellers.
You need an authorized representative in each of those countries. One per country, established directly in that country. Your existing EPR registration is not enough — it's a separate obligation.
Why EU sellers too?
The regulation explicitly states that the obligation applies to producers "established in a Member State or in a third country." EU firms are named directly. To remove any doubt: the European Commission proposed in December 2025 to suspend this obligation for EU-established producers until 2035. But the Council ended negotiations in June 2026 — the delay never came. If the obligation didn't apply to EU firms, there would have been nothing to suspend.
Two obligations, not one
EPR registration (Article 44) and the authorized representative (Article 45(3)) are two separate obligations. If you register yourself and submit reports, you've fulfilled one. The second — having an authorized representative established in that country — remains. And your existing EPR service provider is not automatically your authorized representative. Most providers will offer this as an additional paid service.
Authorized representative by country
Each country uses a different legal term for the role. The representative must be established directly in that country — one for the whole EU is not enough.
| Country | Local Term | Notes |
|---|---|---|
| Germany | Bevollmächtigter | LUCID (ZSVR) + dual system. The dual system is not automatically your representative. |
| France | Mandataire REP | ADEME (SYDEREP), PRO Citeo. The representative is subrogated into the assumed obligations. |
| Spain | Representante autorizado | MITECO registry. NIF (Spanish tax ID) required. Ecoembes processes slowly. |
| Italy | Rappresentante autorizzato | National EPR register not yet open. Registration goes through a person established in Italy. Amazon confirmed no enforcement until the register opens. |
| Poland | Autoryzowany przedstawiciel | BDO registry. Severe backlog — processing takes 5–6 months. Annual reporting by March 15. |
| Sweden | Producentombud | Naturvårdsverket registry. Notification includes a copy of the power of attorney. |
| Netherlands | Gemachtigd vertegenwoordiger | Verpact system, ILT supervision. Registration for non-EU entities was temporarily suspended. |
| Belgium | Registered in EPRiBEL | Fost Plus / Valipac. Representative must be registered in EPRiBEL. |
The GPSR (General Product Safety Regulation) requires an EU Responsible Person for product safety. The PPWR requires an Authorized Representative for EPR. These are two different roles. In most cases, you need both.
What You Should Do Right Now
- Map your markets. List every country where you deliver to end users — including via FBA. Each country means a separate EPR registration and a separate authorized representative.
- Ask your EPR provider first. Most will offer the authorized representative service as an add-on. If you don't have a provider, look for one that covers both registration and representation.
- Start registrations in parallel. Each country has its own authority — there's no reason to do them sequentially. Start with Germany (fastest) and your highest-revenue markets. In Poland, expect 5–6 months.
- Document everything. If an authority or marketplace questions you later, proof that you initiated the process before or immediately after the deadline is far better than having nothing.
- Don't forget other EPR streams. Batteries, WEEE, and single-use plastics each have their own regime and may require separate representatives.
Need Help Navigating PPWR Compliance?
ekoniq handles EPR registration and compliance in 29 EU/EEA countries. We manage the entire process — from document preparation to registration, reporting, and Authorized Representative services. Don't wait for deactivations. Contact us today.
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