Shipping Strategies
EU Regulations
PPWR
Last Updated
June 25, 2023
7 min.
Written By
Krišs Ģērmanis
From 12 August 2026, new EU packaging rules under the Packaging and Packaging Waste Regulation (PPWR) start to apply across the European Union.
♻️🇪🇺 If you sell and ship to customers across the EU, you may now need to register and pay for the packaging you send in each country.
🌍 Start with where you actually ship. Make a list of the EU countries where you currently have customers — these are the markets you need to check first. PPWR registration is handled country by country.
📦 Even a few orders can matter. Don’t assume you’re too small or don’t ship enough for the rules to apply. Cross-border sales directly to end customers can make you the packaging “producer” in that destination country.
✅ Check each country separately. Registration, EPR/recycling schemes and the practical process can differ, so start with your biggest destination markets rather than trying to solve all of Europe at once.
💶 Expect some additional costs. Depending on the country, this could include registration, recycling/EPR fees and potentially representation or compliance-service costs.
🔎 Don’t panic, but don’t ignore it either. A lot is still being worked out. Start by understanding which countries matter to your business and what they require, and keep an eye on further updates.
If you run an e-commerce business and ship orders to customers in other EU countries, the changes may affect you — including very small businesses.
And if this all feels unusually complicated, you're not alone. The regulation applies across the EU, but registration, recycling schemes and some practical requirements are handled country by country. Some national systems are still being adapted, while parts of the wider EU framework remain under discussion.
We've been looking into what the changes mean in practice for businesses shipping with Swotzy. This is what we understand today.
At Swotzy, we're all about making shipping simpler. We're also looking at where we may be able to make this process easier. Nothing is promised at this stage, but if we find a practical way to simplify part of it, we'll do our best to make it available.
Important: Swotzy is a shipping platform, not a compliance adviser. This article is general information, not legal advice.
About the sources on this page
Throughout this page you will see notes like Source: Article 44(2). These are references to numbered sections of the law itself. You can find them in the full text at the link below. Where we use any other source, we say so.
What is PPWR?
PPWR is the EU's new Packaging and Packaging Waste Regulation. It starts applying from 12 August 2026 and replaces the previous EU packaging law. Because it is an EU regulation, it applies across all EU
countries from the same date.
Source: Article 70 and Article 71
For e-commerce sellers, one of the biggest changes is around extended producer responsibility — who is responsible for registering and paying towards the recycling of packaging in the country where it ends up.
Does it apply to small businesses too?
Usually, yes. The rules are based on whether you are selling as part of a commercial activity, not on how large your business is. That means they apply to:
companies;
sole traders and self-employed sellers;
one-person and micro businesses.
A private person selling their own used belongings is different.
What does this mean if you sell to customers in other EU countries?
If you send a parcel directly to an end customer in another EU country, you are likely to be considered the producer of that packaging in the destination country. This means you need to deal with packaging responsibility in each country where you sell.
For example, if a Latvian e-commerce business sells directly to customers in Estonia, Lithuania, Germany and France, the packaging obligations must be handled separately in each market.
What may you need to do?
→ Register in the countries where you sell
There is no single EU-wide registration.
Each country has its own packaging register, so registering in one country does not automatically cover the others.
Source: Article 44(2) and Article 44(4)
→ Pay towards packaging collection and recycling
Producers must contribute towards the collection and recycling of the packaging they send into a country.
This is commonly handled through a producer responsibility organisation, or PRO.
The exact process and fees differ by country.
Source: Article 45(1), Article 3(1)(66) and Article 46(1)
→ Appoint a local representative where you are not established
If your company is not established in the destination country, PPWR currently requires an authorised representative there for certain producer responsibility obligations.
There has been a proposal to change this requirement for EU-based businesses, but it has not yet been agreed. For now, the requirement applies from 12 August 2026.
Source: Article 45(3). On the proposal: COM(2025) 982 on EUR-Lex and the Council of the EU press release of 24 June 2026
→ Keep basic packaging records
Businesses need to be able to identify their packaging suppliers.
For many small businesses, normal supplier invoices may already contain the information needed.
Source: Article 22
What should you do now?
A practical starting point is:
List the EU countries you sell to.
Check the packaging registration requirements in each country.
Find out whether you need to join a local recycling scheme or PRO.
Check whether an authorised representative is required.
Keep information about the packaging you use and your packaging suppliers.
Because each country has its own system, there is unfortunately no single process covering all EU markets.
What could it cost?
There is no single PPWR fee. Costs can generally include:
national registration;
recycling / EPR fees;
an authorised representative, in countries where you are not established.
These costs can be different in every country. If you are already asking compliance providers for prices, it is worth getting more than one written quote.
Source: Article 44(2), Article 44(11)(d), Article 45(1) and Article 45(3)
What is still unclear?
Quite a lot is still moving. Some national systems are still being adapted, penalties are not yet set everywhere, and individual requirements may still change at EU level.
That means 12 August 2026 is clear, but not every practical detail is. We'll keep following the developments and update this article as the situation becomes clearer.
Where can you check official information?
The main source is Regulation (EU) 2025/40 itself.
For country-specific registration requirements, the European National Registers (EUNR) network is a useful starting point for finding the responsible packaging register or organisation in each country.
For free advice, small businesses can also contact the Enterprise Europe Network. In Latvia, LIAA and the Ministry of Economics can help with Single Market questions.
What happens next?
PPWR adds a lot of complexity for businesses selling across Europe, especially smaller e-commerce companies that may only send a limited number of parcels to several different countries.
We're looking at where Swotzy may be able to make this process easier.
Nothing is promised yet, but if we find a practical way to simplify part of the process for our clients, we'll do our best to make it available.
We'll also keep updating this page as the rules and national systems become clearer.
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