What applies to your store
If you ship products to buyers in the European Union, the EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 ("PPWR") — applies to the packaging you use.
Source: European Commission, "Packaging waste" — environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en (accessed 2026-10-01): "Status: In force since 11 February 2025. Application date: 12 August 2026."
| Date | What happens |
|---|---|
| 11 Feb 2025 | PPWR in force (entered into force) |
| 12 Aug 2026 | Main obligations apply from; Directive 94/62/EC "generally repealed" (some provisions continue) |
| 1 Jan 2030 | Commission-stated aim: all packaging on the EU market recyclable in an economically viable way |
E-commerce packaging is transport packaging
Under the PPWR, packaging used for online sales or other distance selling is e-commerce packaging, categorised as transport packaging — shipping boxes and bags, labels, adhesive tape, filler material.
Two consequences, stated by ZSVR (Germany's Central Agency Packaging Register):
- "Packaging intended for shipment is always subject to system participation, without exception" — no size-based carve-out for shipment packaging.
- Shipment packaging is viewed separately from the shipped product — the product's own packaging may create separate obligations.
Source: ZSVR, "Mail order companies and online retailers" — verpackungsregister.org/en/knowledge-bases/mail-order-companies-and-online-retailers (accessed 2026-10-01).
Manufacturer vs producer — the trap most sellers miss
ZSVR's guidance distinguishes two roles that may — but do not have to — belong to the same company:
- Manufacturer: technical documentation + declaration of conformity, for the packaging in its complete final form ("considering each packaging material individually is not sufficient").
- Producer: financing recycling in the Member State where packaging accumulates as waste, and system participation.
| Scenario | Outcome (ZSVR) |
|---|---|
| Packaging bears your brand | You are both manufacturer and producer — regardless of supplier location |
| You combine box + tape + filler | You are the manufacturer (completing the packaging) and the producer |
| You modify complete packaging | If it affects recyclability: manufacturer under Article 21 PPWR + producer |
| You ship directly to German end users from abroad | At minimum manufacturer and producer; must appoint an authorised representative (registration with LUCID stays with you) |
Micro-enterprise exception (narrow, ZSVR): fewer than ten employees and ≤ EUR 2 million turnover/balance sheet (2003/361/EC) — and only where the packaging supplier is in the same Member State.
Source: ZSVR page above (accessed 2026-10-01), scenario list is "not intended to be exhaustive".
Three obligations in Germany
If you are a producer required to fulfil obligations in Germany, ZSVR states you must:
- Register with LUCID — create/check/update registration; all brand names fully filed.
- Organise system participation — before first placing on the German market.
- Report packaging volumes — material type, weight, volume; obtain from suppliers early.
⚠️ This guide deliberately does not state specific filing deadline dates — verify deadlines against official sources before relying on them.
Marketplace checks (why platforms verify you)
ZSVR states: online platforms must — before services can be used — verify (1) LUCID registration confirmation and (2) a self-certification of EPR compliance. Without this evidence, packaged products may not be offered on the platform. Fulfilment providers have the same duty and must stop services if issues aren't resolved in time.
Source: ZSVR page above (accessed 2026-10-01), "Due diligence obligation for online platforms".
Common mistakes
- Assuming "small seller" means exempt — for shipment packaging, system participation applies "without exception".
- Treating one country's registration as covering the others — each Member State's system is separate.
- Assuming the packaging supplier's responsibility replaces yours — if packaging bears your brand, you are both roles.
- Ignoring the modify-packaging trap — adding tape/filler can make you the manufacturer (Art. 21).
- Not preparing documentation before marketplace checks — missing evidence can stop your listings.
Scope of this guide
EU-level facts + Germany (ZSVR/LUCID) guidance, verified October 1, 2026. France, Italy, and other Member State specifics are not covered — country guidance requires the same source verification before publication. This page is not legal advice; for binding guidance rely on official sources (EUR-Lex, ZSVR) and your own advisors.
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