The EU's Packaging and Packaging Waste Regulation is creating a more consistent framework, but small businesses selling across borders still face national EPR systems, registration and reporting requirements. The EU's new packaging regime is intended to make rules more consistent across the single market. For small businesses selling products across borders, however, a common regulatory framework does not necessarily mean a common compliance process.
Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), entered into force on 11 February 2025 and generally applies from 12 August 2026. It covers packaging and packaging waste regardless of material or origin, with requirements covering packaging design, composition, reuse, recycling and waste management. The regulation aims to reduce packaging waste and its environmental and health impacts while improving the functioning of the EU internal market.
Yet one important part of the system – extended producer responsibility (EPR) – continues to rely on national registers and arrangements. For businesses selling packaged products across borders, compliance therefore depends not only on the EU rules but also on where packaging is first made available on the market, which national system applies and what information must be provided. For a large manufacturer with dedicated regulatory staff, this may be another routine compliance function.
For a small online seller shipping relatively few parcels into several EU countries, the administrative effort and fixed costs can be harder to absorb. EPR is based on a simple principle: businesses responsible for placing packaging on the market contribute towards the cost of managing it when it becomes waste. The PPWR requires producers to register in each Member State where they make packaging or packaged products available for the first time, or where they unpack packaged products without being the end user.
Each Member State is required to maintain a national producer register. The regulation seeks to make registration and reporting more consistent. It requires common formats and provides for information submitted to national registers to be interoperable, based on open standards and machine-readable.
But it does not replace national registers with a single EU producer register. That distinction matters to small businesses. A seller making occasional deliveries into several countries may put relatively small quantities of packaging on each national market while still having to establish its compliance position in each relevant jurisdiction.
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