The Big Picture
The Packaging and Packaging Waste Regulation (PPWR) takes effect on August 12, 2026 across all 27 EU member states. Unlike a Directive, which each country must transpose into national law, the PPWR is a Regulation — it applies directly and uniformly in every member state with no room for national variation.
The European Commission categorically rejected the industry's "Stop the Clock" petition, signed by more than 500 companies asking for a 24-month delay. There will be no grace period and no national exceptions.
- Producer registration in national packaging registers
- Declaration of Conformity for all packaging
- PFAS ban on food-contact packaging
What Amazon Requires
- Amazon currently verifies EPR numbers only for Germany (LUCID) and France (Citeo). From August 12, Amazon will verify packaging EPR registration in every EU country where you sell or store goods.
- No valid EPR number = listings deactivated in that country. There is no grace period.
- The Pay-on-Behalf program continues but does NOT exempt you from having your own EPR registration.
- Non-EU sellers must appoint an Authorized Representative for EPR (AR-EPR) in each member state.
- EPR registration typically takes 1–3 months depending on the country — time is running out.
Country-by-Country Status
Below is the current EPR registration status in key European markets. Status colors: green = normal processing, orange = slow or restricted, red = delayed or severe backlog.
Germany
NormalRegistration via LUCID within standard timeframes. However, VerpackG is being replaced by VerpackDG from August 12. B2B packaging now also falls under EPR. Existing systems must prove compliance by January 1, 2027.
France
NormalRegistrations proceeding normally. Separate development: Professional/commercial packaging EPR postponed to January 1, 2027. Consumer EPR via Citeo/Léko unchanged.
Italy
DelayedNational packaging EPR registry has NOT yet opened. Amazon confirmed sellers cannot register yet and absence of a number does NOT affect selling ability currently. No timeline announced.
Spain
SlowExtended apostille timelines combined with summer holidays. Lead time: 1–2 months (with existing VAT + apostille), 2–3 months (VAT but no apostille), 3–5 months (neither). DRS (deposit return system) postponed from November 2026 to 2029.
Netherlands
RestrictedDutch PRO (Verpact) currently completing registrations for EU-established companies ONLY. Non-EU company registrations suspended pending procedure harmonization with platforms.
Belgium
BacklogOver 11,000 applications received. System upgrades underway. Most clients receiving temporary membership numbers first, formal numbers to follow.
Poland
Severe DelaysBDO authority on rotating summer leave (mid-June to late August). Backlog exceeds 15,000 applications. Priority order: Polish companies, then EU companies, then non-EU companies. Timelines up to 5–6 months possible.
Sweden
Summer ClosureApplications before June 20 processed normally. Authority closed July 13 – August 17. Expect 1–2 month additional delay after reopening.
Ireland
SlowAuthority currently processing applications from early March. Significant backlog expected through summer.
Denmark
NormalEPR entered into force October 1, 2025 (one of the last EU countries). First compliance year runs through December 31, 2026.
Austria
NormalSimplified flat-fee option available for very small volumes. Standard registration processing without significant delays.
Czech Republic
NormalEKO-KOM system unchanged. PPWR will run in parallel with the existing national system.
United Kingdom
DelayedNot EU, separate system. Data resubmission deadline moved to September 2026. Fee notices delayed. New RAG-based recyclability fee modulation from 2026–2027.
Other Major EPR Changes
EU Battery Regulation
Due diligence obligations for battery supply chains have been postponed from August 2025 to August 2027 under the Omnibus IV package. However, EPR obligations (registration, take-back, and reporting) remain unchanged on their original timeline.
Textile EPR
The revised Waste Framework Directive entered into force in October 2025. Member states must transpose it by June 2027 and have operational EPR schemes for textiles by April 2028. This is a completely new obligation — no EU-wide textile EPR existed before.
Germany: VerpackG to VerpackDG
From August 12, 2026, the new Packaging Implementation Act (VerpackDG) replaces the existing VerpackG. B2B packaging is brought under EPR for the first time. The LUCID register will be adapted to the new requirements. Existing authorized dual systems must demonstrate compliance by January 1, 2027. New B2B PROs must be authorized by November 1, 2027.
What You Should Do Now
- Check your EPR registration status in every country where you sell — not just Germany and France.
- Start registration immediately in countries with long processing times (Poland, Spain, Belgium).
- If you are a non-EU seller, appoint an Authorized Representative before August 12.
- Prepare your Declaration of Conformity for all packaging.
- Check if your food-contact packaging contains PFAS — the ban takes effect August 12.
- Do not wait for Italy's registry to open — prepare your documents now so you can register as soon as the system launches.
Need Help With Multi-Country EPR Registration?
ekoniq handles packaging EPR registration and compliance in 29 EU/EEA countries. We manage the entire process — from document preparation to registration and ongoing reporting. Contact us for a free compliance assessment.
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