What's Happening: The Call to Delay PPWR

A growing coalition of European industry associations, including the Czech Association for Waste Management (ČAOH), has formally called on the European Commission to postpone the application of the Packaging and Packaging Waste Regulation (PPWR) by 24 months. Their argument: the regulation is not ready for implementation.

The initiative has gained significant political support. The Czech Minister of Environment, Petr Hladík, has backed the call, and multiple EU member states have expressed similar concerns. The core issues are clear: key delegated acts that define how the regulation should work in practice have not yet been published, leaving businesses without the technical guidance they need to comply.

Key concerns raised by industry:
  • Over 60 delegated and implementing acts are still missing — businesses cannot prepare for rules that do not yet exist
  • Estimated compliance costs of 18 billion EUR across the EU, disproportionately affecting small and medium enterprises
  • Technology requirements (e.g., digital product passports, recycled content thresholds) that are not yet feasible at scale
  • Legal uncertainty — companies risk investing in compliance systems that may change once the delegated acts are finalized

Will the Delay Actually Happen?

It is too early to say. The European Commission has acknowledged the concerns but has not yet indicated whether it will grant a postponement. Even if the Commission agrees, the legislative process to amend the PPWR timeline would take months. There is no guarantee of any delay, and the current official deadline remains August 12, 2026.

This is not the first time the EU has faced pressure to delay environmental regulations. And it is not the first time that marketplace platforms have moved faster than regulators. That distinction matters — a lot — if you sell on Amazon, Kaufland, or other major platforms.

What This Means for Marketplace Sellers

If you sell through Amazon, Kaufland, or similar platforms, the potential PPWR delay might seem like good news. You might be tempted to wait and see. That would be a mistake. Here is why.

1. Marketplaces set their own deadlines

Amazon, Kaufland, and other platforms are not bound by the official PPWR timeline. They can — and historically do — enforce compliance requirements ahead of government deadlines. Even if the EU grants a 24-month delay, Amazon could still require your EPR numbers on the original schedule. They have already announced their August 12, 2026 enforcement date, and there is no indication they will move it.

2. We have seen this before: the VerpackG precedent

When Germany introduced VerpackG in 2019, many sellers assumed they had time. Amazon did not wait for German authorities to start enforcement. The platform began blocking listings of sellers who lacked a valid LUCID registration number — months before the government itself took action. Thousands of sellers lost their listings overnight.

⚠️ The pattern is clear:

Marketplaces do not wait for governments. They enforce their own compliance deadlines, and they do it without warning. A PPWR delay at the EU level does not mean a delay on Amazon.

3. Pay-on-behalf is ending — the responsibility is now yours

Until now, Amazon and other marketplaces handled EPR obligations for many sellers through so-called pay-on-behalf programs. The marketplace paid the EPR fees on the seller's behalf and added a surcharge. Under PPWR, this model is being phased out. Sellers are now expected to handle their own EPR registrations directly. If you have been relying on Amazon to take care of this for you, that safety net is disappearing.

4. Registration takes time — and the clock is ticking

EPR registration in a single EU country typically takes 2 to 8 weeks. If you need registration in 5 or more countries — which most Amazon FBA sellers do — the process takes longer. Waiting for a delay announcement that may never come means you could find yourself scrambling in July 2026 with no time left to complete your registrations.

A Brief History of EU Regulation Delays vs. Marketplace Enforcement

2019 Germany's VerpackG takes effect. Amazon begins requiring LUCID numbers and blocks non-compliant sellers — before German authorities start enforcement.
2022 France's AGEC law expands EPR requirements. Amazon starts requesting French EPR numbers (UIN) from sellers shipping to France.
2024 PPWR adopted by the European Parliament. Marketplaces begin communicating new requirements to sellers.
2026 Industry calls for a 24-month delay. Meanwhile, Amazon confirms August 12 as the enforcement date for EPR numbers in all EU countries. The question: will they move it even if the EU delays?

What Sellers Should Do Now

Regardless of whether the PPWR deadline moves, the smartest approach is to prepare now. Here is a practical action plan:

  1. Check which EU countries Amazon ships your products to — go to Seller Central and review your FBA distribution. You need an EPR registration in every one of those countries.
  2. Start the EPR registration process now — do not wait for clarity on the delay. Registration in multiple countries takes weeks, and the earlier you start, the smoother the process.
  3. If the delay does happen, you are simply ahead of the game — your registrations will be valid regardless. There is no downside to being compliant early.

Do Not Wait for the EU — Get Your EPR Sorted Now

ekoniq handles EPR registration in all 27 EU countries. One partner, one process, starting from 29 EUR/month per country. Get a free consultation and find out which registrations you need.

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