EU Packaging Regulation (PPWR): what online sellers must do now
Short answer
The EU Packaging Regulation (PPWR) has applied since 12 August 2026; in Germany, with the VerpackDG, it replaces the Packaging Act13. Shipping boxes, filling material and tape must join a system without exception: registration, a contract with a system, quantity reports4. Stores without an establishment in Germany that sell directly to end customers there also need an authorised representative5.
This article is for information only. Not legal advice. Your lawyer or your legal‑text provider approves your legal texts.
What changed on 12 August 2026
Regulation (EU) 2025/40 has been in force since February 2025 and has applied directly in all EU countries since 12 August 20261. In Germany, the Packaging Law Implementation Act (Verpackungsrecht‑Durchführungsgesetz, VerpackDG) came into force on the same day2. Together, the two replace the previous Packaging Act (Verpackungsgesetz)3.
The basic duties for packaging that ends up as waste with your customers remain: registration, system participation and data reporting. What is new is who must meet them and under which conditions3.
The PPWR separates two roles here. The manufacturer (Erzeuger) shows with technical documentation and a declaration of conformity that the packaging meets the requirements. The producer (Hersteller) bears extended producer responsibility: it finances recycling and handles registration and reporting3. Your store is often both; in supply chains across borders, the two roles can fall to different parties.
Your shipping box counts as e‑commerce packaging
The PPWR calls transport packaging that takes products to the end user after an online purchase “e‑commerce packaging”1. This includes shipping boxes and mailing bags, but also labels, tape and filling material such as film, flakes or tissue paper4.
There is no exemption for this packaging: it must take part in a system without exception, even when you ship to business customers4. If your boxes carry your name, your logo or your brand, you are usually manufacturer and producer at the same time34.
If you put the parcel together yourself from box, tape and filling material, the complete packaging is only created by you. In that case, too, you are manufacturer and producer4.
Who does what
The overview shows the usual roles around an online store. Which of them applies to you depends on the individual case; the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) expressly treats its examples as a first assessment4.
| Who | Task |
|---|---|
| Your store as producer | Registration in the LUCID packaging register, contract with a system, reporting of packaging quantities4 |
| Your store as manufacturer | Technical documentation and declaration of conformity for the complete packaging4 |
| Packaging supplier | Gives you the information and documents you need for your duties (Art. 16 PPWR)4 |
| Authorised representative, only for stores without an establishment in Germany | Takes over all duties of extended producer responsibility except registration in LUCID5 |
| Marketplace and fulfilment service provider | Check your LUCID registration and a self‑declaration; without proof, a marketplace does not offer your products, and a fulfilment service provider suspends its service after an unsuccessful request4 |
The LUCID packaging register is public. Marketplaces and fulfilment service providers can therefore check your registration status automatically4. Keep your details there up to date; otherwise sales may stall.
Shipping from abroad: the authorised representative
If your company is based outside Germany, for example in Türkiye, and you ship directly to end customers in Germany, you are manufacturer and producer at least for the shipping packaging4. Since 12 August 2026 you must then appoint an authorised representative in Germany; there is no exemption from this5.
The authorised representative has its registered office or an establishment in Germany and does not belong to your company. You appoint exactly one, with a written contract in German, and name it in LUCID before your first sale25. Registration itself remains your task.
The ZSVR does not publish a list of registered authorised representatives; you choose the service provider yourself. Authorised representatives charge fees for their service, which you ask them about directly5.
If you deliver directly to end customers in other EU countries, the PPWR also requires an authorised representative for extended producer responsibility there, one per country1.
Checklist for your store
Packaging duties for online sellers
Let’s check this in your store.
In the review we look at this point too; on working days we write to you within 24 hours.
What is still to come up to 2030
Several PPWR duties start later. For some, the date also depends on a legal act of the European Commission; the later date then counts1. So check these dates again before any planning.
PPWR dates for shipping packaging
- The PPWR enters into force; it applies only from 12 August 2026.1
- The PPWR applies, in Germany together with the VerpackDG. Stores without an establishment in Germany need an authorised representative.3
- From this date at the earliest: a harmonised label on material composition, also on shipping packaging. If the duty only applies 24 months after the Commission’s implementing act, that later date counts (Art. 12).1
- By this date: packaging weight and volume reduced to the necessary minimum (Art. 10). From this date at the earliest, possibly later depending on the Commission’s legal acts: at most 50% empty space in shipping packaging (Art. 24) and recyclability under the EU design criteria (Art. 6).1
If you use sales packaging directly as shipping packaging, you are exempt from the empty‑space rule1.
Next step
About this article
- Written by
- Qante Assist team
- First published
- Last updated
- Sources
- 5 sources
Frequently asked questions
Do I need to do anything if I only sell through a marketplace?
Yes, if you are the producer for the packaging. Before a sale, marketplaces must obtain and check your LUCID registration and a self‑declaration; without this proof, your products may not be offered there.
Is there a minimum quantity below which nothing needs doing?
For shipping packaging, the ZSVR names no exemption: it must take part in a system without exception. There is also no exemption from the duty to appoint an authorised representative.
Can someone from my company be the authorised representative?
No. Only a person or company outside your company can be the authorised representative. Whoever looks after the registration in your company is entered in LUCID as the person handling it.
Sources (5)
- Amtsblatt der Europäischen Union (EUR‑Lex)Verordnung (EU) 2025/40 über Verpackungen und Verpackungsabfälle (PPWR), Art. 3, 6, 10, 12, 16, 24, 45 und 71 (opens in a new tab)Accessed: 1 October 2026
- Bundesgesetzblatt (recht.bund.de)Gesetz zur Anpassung des Verpackungsrechts und anderer Rechtsbereiche an die Verordnung (EU) 2025/40 vom 13. Juli 2026 (BGBl. 2026 I Nr. 207), Art. 1 VerpackDG § 5 und Art. 8: Inkrafttreten am 12. August 2026 (opens in a new tab)Accessed: 1 October 2026
- Zentrale Stelle VerpackungsregisterPPWR & VerpackDG: Das gilt seit dem 12. August 2026 (opens in a new tab)Accessed: 1 October 2026
- Zentrale Stelle VerpackungsregisterVersand- und Onlinehandel: Was ändert sich durch die PPWR? (opens in a new tab)Accessed: 1 October 2026
- Zentrale Stelle VerpackungsregisterAlles auf einen Blick: die Bevollmächtigung (opens in a new tab)Accessed: 1 October 2026
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What changes this year in Germany, the EU and Türkiye, with dates and sources.
