- PPWR
- UK online sellers
Selling to EU customers from the UK? Here’s what PPWR asks of your packaging.
Short answer
Yes, PPWR applies to UK businesses for the packaging they sell into the EU and Northern Ireland; packaging placed only on the market in Great Britain stays under UK rules. If your box or mailer carries your brand, it needs a declaration of conformity and a technical file. Selling directly to consumers in an EU country also means registering for packaging EPR there.
Or forward your EU customer’s request to umutcan@evreka.co, and we’ll tell you what it asks for and who signs what. UMUTCAN ONAYI: e-postayla gelen müşteri taleplerini kim ve ne kadar sürede yanıtlar (öneri: 1 iş günü)
- Applies since 12 August 2026
- Updated: 27 October 2026
evreka.ai is a product of evreka.co.
How does the way you sell decide your role?
PPWR gives you a role for each packaging type and each country. For a UK online seller, three set-ups cover most cases, and many sellers use more than one of them at the same time.
| How you sell | Your role, usually | What you need to have |
|---|---|---|
| Wholesale to a retailer or importer in the EU | Manufacturer of your branded packaging. The EU importer places it on the market, checks your documents and is usually the producer for EPR in its country. | A declaration and technical file for each packaging type, the identification on the pack, and your suppliers’ information |
| Parcels from the UK directly to consumers in the EU | Manufacturer of your branded packaging, and the producer in each EU country where your customers are | The declaration and technical file; EPR registration and an authorised representative in each of those countries; registration numbers for marketplaces |
| Stock in an EU fulfilment centre, for example in the Netherlands, or in Amazon’s EU network | Manufacturer of your branded packaging, and usually the producer in each country you sell to. Who acts as importer depends on your set-up. | The same documents, available in the EU; registration numbers for your fulfilment partner and marketplaces |
Many UK brands now hold stock in EU warehouses, often in the Netherlands. That changes how the goods enter the EU, but the documents for your branded packaging stay with you.
Do you need EPR registration and an authorised representative in each country?
If you sell directly to consumers in an EU country, you are usually the packaging producer there. You register for packaging EPR in that country and appoint, by written mandate, an authorised representative there (Article 45(3) of the regulation). This applies today, country by country: selling to customers in Ireland, the Netherlands and Germany means registering in all three and having a representative in each of them.
On 20 October 2026 the European Parliament voted to pause the representative requirement for small businesses based in the EU. Nothing has been adopted yet, and none of the proposals changes the requirement for sellers based outside the EU, including the UK.
Registration and representation come from an EPR service or compliance scheme in each country. Evreka does not register you or act as your representative; it holds the packaging documents and supplier evidence that those services and your customers ask for. UMUTCAN ONAYI: kayıt ve temsilci için iş ortağı firmaya yönlendirme yapacak mıyız
Does your branded box need a declaration of conformity?
Yes. If your shipping box, mailer or product packaging carries your name or logo, you are its manufacturer under PPWR. Before it goes on the EU market, you carry out the conformity assessment, prepare the technical file and sign a declaration of conformity for each packaging type, in or translated into the language of the country where it is sold. For a plain standard box, the box maker is usually the manufacturer.
Here is what that means for one parcel you send to an EU customer, and what comes later.
Photo: Ron Lach, Pexels.
Since 12 August 2026
Your logo makes the box yours to declare
With your name or logo on it, you are the box’s manufacturer, wherever it was made. Before it reaches EU customers, you sign its declaration of conformity and keep the technical file.
Art. 3(1)(13), 15, 39
Since 12 August 2026
A batch code and your contact details
The box carries a type, batch or serial number. Your name and postal address, and an electronic contact where you have one, go on the box or behind a QR code; where neither is possible, an accompanying document is enough. Boxes made before 12 August 2026 do not need relabelling.
Art. 15(5)–(6) · Commission FAQ
Since 12 August 2026
Your suppliers’ evidence behind the file
The composition and test evidence for the board, the print and the glue come from your suppliers, and your technical file is built on it.
Art. 16(1) · Annex VII
August 2028 at the earliest
A sorting label, also shown before purchase
Unlike most transport packaging, e-commerce packaging carries the EU’s harmonised sorting label, and for online sales the label information also has to be available before purchase.
Art. 12
2030 at the earliest
The tissue paper counts as empty space
Whoever fills the box keeps empty space to 50% at most, and filling material counts as empty space. The dates are under What comes next for your parcels.
Art. 24
Your fulfilment centre does not sign for you. Its own duty is to make sure that storing, packing and dispatching do not undermine your packaging’s compliance. Zalando’s fulfilment service, for example, covers the shipping packaging it adds, while your product packaging stays yours. What goes into the declaration: PPWR declaration of conformity.
What do Amazon, eBay and Zalando ask for?
- Every marketplace
- Under the regulation, a marketplace has to collect your packaging EPR registration number for each EU country where your customers are, and a self-certification, before you sell there.
- Amazon
- Asks for proof of registration country by country in Seller Central, as it has done for Germany since 2022 and for France.
- eBay
- Asks for packaging EPR registration numbers for each EU country, shipping materials included, and says listings may be hidden from buyers in countries where a number is missing.
- Zalando
- Collects EPR details for each country; from 1 January 2027, products without them are blocked in the countries on its list.
These checks are about registration numbers. The declaration and technical file are what your business customers and the authorities ask for.
Does PPWR apply to parcels you send to Northern Ireland?
Yes, for the packaging rules. Under the Windsor Framework, much of PPWR applies to packaging placed on the market in Northern Ireland: the declaration of conformity, the limits on heavy metals and on PFAS in food-contact packaging, and later the sorting label. Packaging EPR, the reuse targets and the deposit return rules of PPWR do not apply there; Northern Ireland stays in the UK’s packaging EPR.
The UK government has not yet decided whether Great Britain will align with PPWR and plans a consultation in early 2027 (DAERA).
How do UK packaging EPR and EU PPWR compare?
The two regimes run side by side, and an online seller with customers on both sides of the Channel deals with both. UK packaging EPR is about reporting and fees; PPWR is also about the design and documentation of the packaging itself.
| UK packaging EPR | EU PPWR | |
|---|---|---|
| Where it applies | Packaging placed on the market in the UK, Northern Ireland included | Packaging placed on the market in the EU; in Northern Ireland, its packaging rules but not its EPR |
| Who it covers | UK businesses with a turnover of £1 million or more that supply more than 25 tonnes of packaging a year; large producers, above £2 million and 50 tonnes, have the most duties | Every manufacturer whose packaging reaches the EU market; producers register in each EU country they sell into |
| What you produce | Packaging data reports; large producers also pay disposal fees and buy recycling evidence | A declaration of conformity and technical file for each packaging type, plus EPR registration and reporting in each country |
| Online marketplaces | Report the packaging that sellers based outside the UK supply into the UK | Collect each seller’s registration number and a self-certification |
| Recyclability | Disposal fees are higher for packaging rated red: ×1.2 in 2026-27, rising to ×2.0 by 2028-29 | From 2030 at the earliest, packaging must reach recyclability grade C or better |
| Plastic | Plastic Packaging Tax of £228.82 a tonne since April 2026 on plastic packaging with less than 30% recycled plastic | Minimum recycled content in plastic packaging from 2030 at the earliest, 35% for most plastic mailers and films |
What comes next for your parcels?
- From August 2028 at the earliest
- A harmonised sorting label on packaging, including e-commerce packaging, which is otherwise exempt as transport packaging. For online sales, the label information must also be available before purchase.
- From 2030 at the earliest
- At most 50% empty space in grouped, transport and e-commerce packaging, applied by whoever fills the box. Filling material counts as empty space; products shipped in their own sales packaging are exempt. The limit starts on 1 January 2030 or three years after the EU calculation method takes effect, whichever is later; the method is due by February 2028.
- From 2030 at the earliest
- Packaging must be recyclable to grade C or better, plastic packaging needs a minimum share of recycled content, and packaging that only adds perceived volume, such as double walls or false bottoms, is not allowed. Cardboard boxes are exempt from the reuse targets.
Which PPWR assumptions do not hold for UK sellers?
Assuming a UK address keeps you outside PPWR
Instead: follow the packaging, not your address. Packaging you sell into the EU or Northern Ireland has to meet PPWR, and selling directly to consumers in an EU country usually makes you the producer there, even from outside the EU.
Art. 3(1)(15)(c)–(d)
Registering once for the whole EU
Instead: register in each EU country where you sell directly to consumers. There is no single EU register: each country keeps its own, and you need a representative in each of them.
Art. 44, 45(3)
Waiting for the representative requirement to be dropped
Instead: appoint one in each of those countries. The European Parliament’s vote of 20 October 2026 would pause the requirement only for small businesses based in the EU, and nothing has been adopted.
Art. 45(3)
Treating parcels to Northern Ireland like Great Britain
Instead: apply PPWR’s packaging rules to them: the declaration of conformity, the heavy-metal limits, the PFAS limits for food-contact packaging and, later, the sorting label. Packaging EPR there stays with the UK scheme.
Windsor Framework · DAERA
Example: from a Dutch retailer’s request to a declaration
Example · fictional
Ashby & Rowe, a homeware brand in Leeds, sells through its own webshop to consumers in Ireland, the Netherlands and Germany, and wholesale to a homeware retailer in the Netherlands. The retailer asks for PPWR documents for the packaging.
- Role. The shipping box, the mailer and the candle gift box carry the brand, so Ashby & Rowe is their manufacturer. It buys plain void fill and uses it as it is.
- Registration. For the webshop sales in Ireland, the Netherlands and Germany, it registers through an EPR service in each country and has a representative there. That part is not Evreka’s job.
- Suppliers. The board supplier, the mailer film supplier, the ink supplier and the gift box printer each get a short form.
- Declarations. The box declaration is issued, the gift box is in draft, and the mailer waits for the ink supplier’s heavy-metal evidence.
- Retailer. The retailer’s spreadsheet is filled from the same record, in Dutch.
How does Evreka help UK online sellers?
Evreka is PPWR software for the packaging side of the work: supplier evidence, a declaration and technical file for each packaging type, and answers to every customer from one record. In the brand view you see:
- Your role: which packaging you are the manufacturer of and which you only use, for each way you sell.
- Supplier requests: short forms that go out to your suppliers, and the evidence that has or has not come back.
- A declaration and technical file for each packaging type: in English, Dutch or German, from the same record.
- Export to your customer’s template: each retailer or importer gets the information in the format it asks for.
- Set up with our specialist: we enter your first packaging types and suppliers with you.
We already build software for EU rules. Evreka’s Wasteform product prepares the documents for cross-border waste shipments in the EU, the Annex VII, IA and IB forms, and works with DIWASS, the EU’s digital system under Regulation (EU) 2024/1157. More on evreka.co: Wasteform and DIWASS.
Sources
- Regulation (EU) 2025/40, official text (EUR-Lex)
- European Commission, FAQ on the Packaging and Packaging Waste Regulation
- business.gov.uk, EU Packaging and Packaging Waste Regulation
- DAERA, packaging and packaging waste (Northern Ireland)
- gov.uk, extended producer responsibility for packaging: who is affected
- gov.uk, Plastic Packaging Tax rates
- eBay UK Seller Centre, Packaging and Packaging Waste Regulation
- Zalando Partner University, what is PPWR
This page reflects the situation in October 2026 and is not legal advice. For the exact wording, see the official texts.
Testimonials
“This software provides us the ability to centralize and scale the tracking of waste shipments through each step of our global supply chain.”
Free 20-minute assessment
The call is with Umutcan Duman, founder and CEO of Evreka AI. We also show you the software.
Not ready for a call? Forward your customer’s request to umutcan@evreka.co and we’ll tell you what it asks for.
What you take away
- Your role for each packaging type. Which packaging you are the manufacturer of, and in which countries you count as the producer.
- What you will be asked for. Which declarations, technical files, supplier information and registration numbers your customers, marketplaces and fulfilment partners will want.
- One packaging type, checked. We go through one of your packaging types together and see what is ready and what is missing.
No preparation needed. If you have a customer’s request or the supplier list for one packaging type to hand, the call moves faster.
Calendar
The calendar with available times opens here.
If the calendar does not open, email umutcan@evreka.co.
UK online sellers
Frequently asked questions
To see what applies to you: 2-minute PPWR check · About the document itself: PPWR declaration of conformity
Do I need an EU authorised representative in every country I sell to?
If you sell directly to consumers in an EU country, yes: you need one for packaging EPR in each of those countries. EPR services and compliance schemes provide this, and some cover several countries.
Is UK packaging EPR enough for my EU sales?
No. UK packaging EPR covers packaging placed on the UK market. For packaging you sell into the EU you need the PPWR documents and, where you sell directly to consumers, EPR registration in each EU country.
My stock is in a Dutch fulfilment centre. Who is responsible for the packaging?
You stay responsible for the documents for your branded packaging. The fulfilment centre must not undermine compliance while storing and packing, and it will ask for your registration numbers. Who acts as importer depends on your set-up; we work it out with you in the assessment.
Do marketplaces check my registration numbers?
They have to collect them. eBay says listings may be hidden in countries where a number is missing, Zalando blocks products without EPR details from 1 January 2027, and Amazon asks country by country. bol.com says it does not enforce this yet.
Does PPWR apply to parcels I send to Northern Ireland?
Yes, for the packaging rules such as the declaration of conformity and the limits on heavy metals and PFAS. Packaging EPR in Northern Ireland stays under the UK scheme.
When does the 50% empty-space limit start?
On 1 January 2030 or three years after the EU calculation method takes effect, whichever is later. It applies to whoever fills the box, and filling material counts as empty space.