Why PPWR is stopping sellers from shipping to the EU and what larger brands should do differently

August 12, 2026 has passed, and the EU’s new Packaging and Packaging Waste Regulation (PPWR) is now part of the operating environment for any brand selling packaged goods into Europe. But if the past week has shown anything, it is that “one EU regulation” does not necessarily mean one simple process.

Across seller communities, independent merchants and artists are openly debating whether to pause EU shipping because the administrative burden feels larger than the revenue they make in some markets. Some sellers have already reported stopping cross-border shipments or considering switching EU destinations off entirely.

That reaction is most visible among small sellers, but the underlying issue matters just as much to larger ecommerce teams: PPWR turns packaging into a market-by-market operational question.

For established brands, the right response is not panic; it is visibility. Before you can decide what PPWR means for your business, you need to know exactly where you sell, who places packaging on each market, how orders are fulfilled, and which marketplace or logistics partner is involved.

What actually changed on August 12?

PPWR, formally Regulation (EU) 2025/40, replaces the previous EU packaging directive with a regulation that applies directly across Member States. It covers the full packaging lifecycle and introduces requirements around sustainability, labeling, recyclability, packaging minimization, reuse, and extended producer responsibility, or EPR. The regulation entered into force in February 2025 and applies generally from August 12, 2026.

Not every PPWR requirement started on August 12. The regulation phases in over several years. One requirement that is already active, for example, restricts PFAS above specified limits in food-contact packaging. Harmonized labeling and many packaging design requirements arrive later. The issue creating some of the most immediate friction in ecommerce is EPR.

EPR is the principle that the producer placing packaging on a national market carries financial and organizational responsibility for that packaging when it becomes waste. EPR itself is not new in Europe. Many countries already operated packaging EPR systems before PPWR. What PPWR does is bring EPR for packaging into a common EU framework while defining obligations around producer registration, cross-border selling, marketplaces, and fulfillment providers.

The important operational detail is that a common EU regulation does not mean a single EU registration. Article 44 provides for national producer registers, and producers must register in each Member State where they make packaging or packaged products available for the first time. 

Cross-border distance selling can also trigger authorized-representative requirements in destination markets. That is why the burden can escalate quickly. Selling into a single EU country creates a single operating context. Selling into 10 can create multiple registrations, reporting relationships, producer responsibility organizations, and local procedures.

The impact depends heavily on seller size

➡️For microbusinesses, this can become a simple economics problem. A seller making only a handful of sales in a particular country may decide that the fixed cost and administrative work of maintaining EPR arrangements there no longer makes commercial sense. That calculation is already appearing in seller discussions around PPWR.

➡️Mid-market brands face a different challenge. They are more likely to sell through several marketplaces at once, operate in multiple EU countries, and use a mix of their own warehouses, third-party logistics providers, and marketplace fulfillment. Their question is less likely to be “Can we afford to sell into the EU?” and more likely to be “Can we map responsibility accurately across every market and channel?”

That distinction matters because outsourcing fulfillment does not automatically outsource the brand’s obligations. Take marketplace fulfillment. If a fulfillment provider adds the shipping box, that provider may be responsible for the packaging it places on the market. 

But the brand can remain responsible for its product packaging and its own EPR obligations. PPWR also brings fulfillment service providers into the verification chain by requiring them to make best efforts to assess the producer information they receive.

➡️For larger brands, this creates a packaging responsibility map. Product packaging, shipping packaging, importer relationships, marketplace requirements, and EPR registrations may all have different owners, even within the same customer order.

Marketplaces are becoming part of the compliance layer

This is where PPWR becomes particularly relevant to marketplace operators. Under the regulation, online platforms that allow consumers to conclude distance contracts with producers must obtain producer registration information and a self-certification of EPR compliance, then make best efforts to assess whether that information is complete and reliable.

In practice, marketplaces are implementing that obligation differently. Amazon now tells sellers that if they sell packaging in the EU, they must prove their compliance to Amazon in each applicable country through its Seller Central compliance process. 

Zalando is collecting packaging EPR details through zDirect and tells partners they must be registered for packaging EPR in every EU country where they operate or plan to expand. Zalando has also said that from January 1, 2027, assortments will be blocked if required EPR details have not been provided.

Bol shows how fulfillment changes the picture. The marketplace currently says it is not yet actively enforcing PPWR registrations at scale. However, for sellers using Logistics via bol, bol takes responsibility for PPWR compliance for the bol-branded shipping packaging it adds during fulfillment. The seller remains responsible for its own product packaging and the related registration and documentation obligations. 

These differences are important. You're selling the same SKU on Amazon, Zalando, and Bol. Same product, same packaging, same EU regulation. But you're dealing with three different compliance workflows, three different data requirements, and three different enforcement timelines.

This also means marketplace compliance cannot be managed as a one-time legal project. Marketplace requirements, data fields, and enforcement timelines need to become part of channel operations.

The next PPWR deadlines are already an operational planning issue

From 2028, harmonized EU packaging labels are due to start applying, subject to the timing of the relevant implementing acts. These labels are intended to make material composition using harmonised pictograms, to make consumer sorting clearer and more consistent across Member States.

The larger design changes arrive around 2030. Packaging placed on the market will need to meet recyclability requirements, with the regulation introducing recyclability performance grades. Packaging minimization requirements also tighten.

Grouped, transport, and ecommerce packaging will also be subject to a maximum 50% empty-space ratio from January 1, 2030, or three years after the relevant implementing methodology enters into force, whichever is later.

That last point matters for ecommerce. Void fill does not make an oversized box “full” under the PPWR calculation. Materials such as paper cuttings, air cushions, bubble wrap, foam fillers, and similar materials are treated as empty space when calculating the ratio.

Brands therefore need to think beyond registration. Packaging specifications, supplier data, fulfillment rules, and marketplace logistics will increasingly intersect. There is also no reason to assume every practical detail is settled. The European Commission is continuing to develop the secondary legislation needed to implement different parts of PPWR. 

Industry groups such as EXPRA have also argued for more interoperable digital systems that make EPR easier to manage across Member States without eliminating the national systems behind reporting, fees, and enforcement. The direction is clear, but the operating model will continue to mature.

The compliance question is really operational

For ecommerce leaders, this is the more useful way to think about PPWR. You sell in Germany, France, the Netherlands, Belgium, and Spain. You use Amazon FBA in two of those markets, a 3PL in another, marketplace-managed fulfillment elsewhere, and your own warehouse for direct orders.

Simply asking “Are we PPWR compliant?” is too broad to produce a useful answer. The operational questions come first.

• Who placed what packaging on which market?
• Which fulfillment partner added the shipping box?
• Where are you registered, and where aren't you yet?

Once you have visibility on those questions, compliance becomes easier to manage. More importantly, so does expansion. Because PPWR doesn't change the fundamentals of entering a new European market - it adds another layer to a decision you were already making. Local assortment, pricing, fulfillment, tax, marketplace requirements: these have always been part of the picture. PPWR is one more dimension to factor in.

Starting to sell in a new country is not simply turning on a new listing. It’s adding another regulatory and operational environment that has to be understood and maintained. The brands best positioned for this are not necessarily the ones with the biggest compliance teams. They are the ones that know exactly where they operate and can make deliberate decisions about where to expand next.

Build EU growth on a clear market structure

PPWR should not stop brands from treating Europe as a growth opportunity. It should make them more deliberate about how they pursue it. Instead of expanding wherever a marketplace connection is technically available, brands have more reason to prioritize countries and channels based on demand, margin, operational readiness, and the effort required to support them properly. 

That can mean entering fewer markets at once, choosing fulfillment models more intentionally, or sequencing marketplace launches so operational complexity grows at a manageable rate. The regulation may be about packaging, but the strategic question is broader: how clearly can you see and control your European commerce footprint?