PPWR for US sellers: what the EU packaging rules mean for you

If you sell packaged goods from the US into the European Union, the Packaging and Packaging Waste Regulation (PPWR) applies to you in full — no US entity, no volume threshold, no exemption. Here's what that actually means.

You're a producer — even from across the Atlantic

Under the PPWR (Regulation (EU) 2025/40), a "producer" is the entity that first makes a packaged product available on a national market. If your packaged goods ship from the US and reach an EU consumer, you are the producer — regardless of where your company is incorporated, where your warehouse sits, or whether you have a European office.

Using Fulfillment by Amazon doesn't change this. Amazon is your fulfillment provider, not the producer. You placed the packaged product on the market, so the EPR obligations are yours.

The authorised representative obligation

Article 45(3) requires any producer not established in the country of sale to appoint an authorised representative (AR) there — a company based in that EU member state that assumes the producer's EPR obligations and stands jointly liable before the national authorities.

This is not a formality. The AR is the named, locally accountable party that registers you, files your annual packaging declarations, and answers to the regulator when something goes wrong. EU authorities cannot practically pursue a US company — the AR is how they enforce.

One AR per country — there is no EU-wide shortcut

This is the detail most US sellers miss. Unlike VAT (IOSS) or product safety (GPSR), there is no single EU-wide representative under the PPWR. Each member state requires its own AR established in that country:

• Selling to Germany, France and Belgium? That's three ARs, one per country.
• Each AR files a separate registration in that country's national register (LUCID in Germany, Fost Plus in Belgium, ADEME/SYDEREP in France).
• Each has its own fees, its own declaration calendar, its own ID numbers.

In practice, most sellers appoint one coordinating partner who manages the whole set — so you deal with one contact instead of five providers.

Registration, PROs and eco-fees

Once the AR is in place, the obligations run like this:

1. Register in the national register of each country of sale.
2. Join a Producer Responsibility Organisation (PRO) — Fost Plus in Belgium, a dual system in Germany, Citeo in France — that handles collection and recycling.
3. Pay eco-fees based on the weight and material of your packaging passed through at cost.
4. File annual declarations of the packaging volumes you placed on the market.

What marketplaces actually check

From 12 August 2026, Article 45(4) obliges online marketplaces — Amazon, eBay, Etsy, and others — to verify that sellers hold valid EPR registration numbers before allowing them to list in a given country. This is the enforcement mechanism that bites fastest: if you cannot produce a registration number, your listings in that country are suppressed.

Amazon has enforced EPR deadlines on the day every time — LUCID in 2022, WEEE in 2023, batteries in 2025. It will do the same for the PPWR.

What it costs

AR fees vary by country and by the packaging volumes you declare. Eco-fees pass through at cost. The fee is always a fraction of what a suspended listing costs in lost sales — for a tailored quote, tell us your target countries and volumes.

Sources: PPWR (EU) 2025/40 and the EU authorised representative guide.