On 12 August 2026, the PPWR turned marketplace EPR verification from a two-country exception into the law across all 27 member states. If you sell on Amazon, the question is no longer whether they'll check — it's whether your numbers are already in.
TL;DR — Since 12 August 2026 Amazon verifies EPR registration in all 27 EU countries under Article 45(4) — a missing number means suspended listings.
What changed on 12 August
Article 45(4) of the PPWR obliges online platforms in scope of the Digital Services Act to obtain — before letting a producer sell — the producer's EPR registration number for the member state where the consumer is located, plus a self-certification of compliance, and to make best efforts to verify them. Germany and France ran this check for years on their own; now it is EU law everywhere.
Amazon's record: six deadlines, six enforcements
Amazon has enforced every comparable EPR deadline on or around day one since 2022:
- Jun–Jul 2022 — Germany LUCID: blocked listings without packaging registration numbers, in two waves.
- 31 Dec 2022 — France: auto-enrolled unregistered sellers into Pay on Behalf.
- Jan–Jul 2023 — Germany WEEE: delisted unregistered sellers; fines reach €100,000.
- 1 Jan 2025 — Single-use plastics: enforcement began on schedule.
- 18 Aug 2025 — Batteries: deactivated non-compliant offers in DE, NL, PL and SE the same day; Temu and TikTok Shop held the same line.
- 12 Aug 2026 — PPWR packaging: verification duty in every member state.
For non-EU sellers, representation comes first
There is no single EU number. You need a registration number per country — and as a non-EU seller you cannot get one without first appointing an authorised representative in each member state of sale. The sequence is fixed: representation → registration → number → verification.
Don't wait for the deactivation email
Recovery is slower than prevention: a registration filed after suspension still takes 2–8 weeks. Every week of delay is a week your competitors keep selling while your listing sits dark.
The practical takeaway: if you sell into the EU without a local establishment, appoint your authorised representative and register now — before the enforcement wave, not after it.
Sources: Gramta — EPR for Amazon sellers and Eldris — Amazon EPR verification 2026.
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