EPR & PPWR 2026: How Amazon Sellers Survive the August 12 Deadline

On August 12, 2026, EU Packaging Regulation 2025/40, better known as PPWR (Packaging and Packaging Waste Regulation), comes into force. It replaces the old Packaging Directive 94/62/EC, applies directly in all 27 member states without national transposition, and it fundamentally shifts the compliance burden toward platforms like Amazon. For you as a seller this means: the last weeks before August 12 decide whether your listings are still live in fall 2026 or whether you spend weeks dealing with suspensions, late registrations, and service fees.

In this article we show what the PPWR concretely changes, which EPR obligations actually apply in which country, where Amazon's "Pay on Behalf" service helps (and where it doesn't), and which steps you need to take now to be cleanly set up pan-European.

What the PPWR Is and Why It Changes Everything

The PPWR (Regulation 2025/40) entered into force on February 11, 2025 and becomes binding after an 18-month transition period on August 12, 2026. Unlike the old Directive 94/62/EC, it is a regulation, meaning it applies 1:1 in all member states without transposition into national law. That means: no more 27 different national interpretations, but one unified framework.

The Three Hard Tightenings

• Article 45(4) Online Marketplace Obligation: Amazon, eBay, Otto, Zalando and co. must verify before the first listing whether the seller holds a valid EPR registration in every country of sale, and must monitor this verification continuously. In practice this runs via API connections to the national registers. Missing or expired evidence leads to automatic suspension.
• Authorised Representative obligation: Anyone placing packaging on the market in an EU country where they don't have a registered office must name an authorised representative there. This person takes legal responsibility for compliance with national EPR rules. For third-country sellers (e.g. China) this already applied. New is the extension to EU-internal cross-border sales.
• Recyclability as a design requirement: From January 1, 2030 packaging must be recyclable, from 2035 economically recyclable in the national sorting and recovery facilities. Not yet acute for 2026, but relevant for everyone developing new packaging now.

For day-to-day operations in your Amazon account, point 1 is the most important lever. Without a valid registration number per country, no listing. This is not a threat, this is the marketplace's legal obligation, enforced through automated suspensions.

Amazon's Internal Deadlines: Where You Need to Stand Already

Amazon set its own deadlines alongside the PPWR that already lie in the past. Anyone who missed them isn't automatically suspended, but lands in the so-called "Pay on Behalf" program, which sounds comfortable from Amazon's side but means service fees and reduced control.

Amazon's 2025/2026 Deadlines

• December 31, 2025: WEEE number (electrical and electronic equipment) had to be entered in all relevant marketplaces.
• March 31, 2026: Numbers for packaging, batteries, tires, oils, and polyethylene had to be entered.
• August 12, 2026: Hard PPWR deadline, from this date automatic marketplace checks run across the board.

If you missed one of these deadlines and sell in a "Pay on Behalf" country (see below), Amazon takes over the EPR contributions for you, charges them plus a service fee directly from the disbursement account. This is more expensive than self-registration, but covers the compliance risk. In Germany, Austria, and the Netherlands, this safety net does not exist. There, a missing registration leads directly to suspension.

You can see the complete country status of your account in Seller Central under "Account Configuration > Compliance Portal > EPR Compliance". Check there before every quarter-end whether new marketplaces have been added or storage locations have changed.

EPR Country-by-Country: What Needs to Be Registered Where

The PPWR unifies the framework, but the concrete registration systems stay national. This is the most important myth-buster: there is no "EU EPR number" in 2026, but still national registers per waste stream and per country.

Germany: LUCID + EAR + GRS BattG

• LUCID (packaging): Registration with the Stiftung Zentrale Stelle Verpackungsregister at verpackungsregister.org. Free of charge. Additionally requires a contract with a dual system (e.g. Reclay, Interzero, Landbell) that bills license fees per material and tonnage.
• EAR / WEEE-Reg.-Nr. (electrical): Registration with Stiftung Elektro-Altgeraete-Register. Processing time 4 to 8 weeks. Cost: about 230 euros flat plus guarantee per device type.
• GRS BattG (batteries): Registration with Stiftung Gemeinsames Ruecknahmesystem Batterien. Processing time 2 to 4 weeks.

Important for importers: if your product comes from China and you place it on the German market for the first time, you are the "producer" in the sense of the German Packaging Act. The obligation therefore doesn't lie with the Chinese supplier, but with you.

France: ADEME Identifiant Unique + CITEO

• The French environmental agency ADEME has issued the "Identifiant Unique" (UID) since 2022 to all companies that have to comply with French recycling laws.
• The UID is applied for via the take-back system (in practice almost always CITEO for packaging).
• New from July 1, 2026: transport and industrial packaging is also subject to registration and reporting requirements.
• Amazon Pay on Behalf is available here, but does not cover the TGAP eco-modulation filings.

Italy: CONAI + EPR for Electrical and Batteries

In Italy, registration with CONAI is mandatory for packaging, in many cases with a tax representative. Online merchants without an Italian office require an authorised representative. Amazon Pay on Behalf is available, but sorting fees are calculated individually per material.

Spain: Ecoembes / Ecovidrio / SCRAP System

Spain significantly tightened its EPR system with RD 1055/2022. Registration is through the relevant SCRAP (Sistema Colectivo de Responsabilidad Ampliada del Productor), usually Ecoembes for paper/cardboard/plastic and Ecovidrio for glass. Amazon Pay on Behalf is available.

Belgium, Netherlands, Austria

• Belgium: Fost Plus (packaging). Amazon Pay on Behalf available.
• Netherlands: Afvalfonds Verpakkingen. Amazon Pay on Behalf NOT available, self-registration mandatory.
• Austria: ARA AG or other licensed systems. Amazon Pay on Behalf NOT available.

UK: Producer Responsibility Obligations + Extended Producer Responsibility for Packaging (pEPR)

With the "Extended Producer Responsibility for Packaging" (pEPR) reform, since 2024 the producer bears the full net cost of household waste collection. Registration with the Environment Agency. Amazon Pay on Behalf has been available for the UK since March 2024.

Amazon Pay on Behalf: When It Helps, When It Doesn't

Amazon's Pay on Behalf service is available in five countries in 2026: UK, France, Spain, Italy, Belgium. By Amazon's own count, the company acts as registered contribution payer for over 300,000 sellers in these five countries.

How Pay on Behalf Concretely Works

If you don't have your own EPR registration in one of these countries, Amazon automatically becomes your authorised contribution payer. Amazon reports your packaging volumes to the responsible PRO (Producer Responsibility Organisation), pays the contributions, and invoices you via the disbursement account. In addition to the pure EPR fee, Amazon charges a service fee (typically 5 to 20 percent of the EPR fee, depending on country).

When Pay on Behalf Makes Economic Sense

• Low volumes / test market: Anyone doing under 1,000 orders per year in a country usually fares cheaper with Pay on Behalf than with self-registration plus annual mandatory reporting.
• Compliance risk avoidance: Anyone without internal resources for annual reporting buys peace of mind with Pay on Behalf.
• Multi-channel sales NOT covered: Important: Pay on Behalf only applies to Amazon volumes. If you sell in parallel via DTC shop, Otto, or Zalando, you need your own registration for those channels. Amazon only reports what's sold via Amazon.

When Self-Registration Pays Off

• High volumes: From about 5,000 orders per year and country, the ratio flips. Self-registration with a direct PRO contract is cheaper.
• Multi-channel: Anyone selling on multiple platforms can't avoid self-registration anyway.
• Brand control: Self-registration gives you control over material classification and therefore over the contribution amount.

For Germany, Austria, and the Netherlands, Pay on Behalf does not exist. This is by far the biggest trap in 2026, because many sellers assume Amazon will also take care of it here. The reality: anyone selling on Amazon.de without a LUCID number plus dual-system contract will be suspended from August 12, 2026.

The New Authorised Representative from August 2026

A central lever of the PPWR that many sellers still don't have on their radar: from August 12, 2026, every seller placing packaging on the market in an EU country where they don't have a registered office must name an Authorised Representative in that country. This is the bridge between PPWR and national EPR law.

Who Needs an Authorised Representative

• Third-country sellers (e.g. China, USA, UK) selling into EU countries need an AR in every EU country they ship to.
• NEW from August 2026: EU sellers selling into other EU countries also need an AR in the destination country if they don't have a registered office there.

Concretely: a German seller selling into France, Italy, and Spain needs from August 12, 2026 either their own office in each of these countries or an Authorised Representative there. The usual solution is specialised service providers like Lizenzero EU, Deutsche Recycling, Ecosistant or eucompliance who take this over for typically 800 to 2,500 euros per year and country.

What the AR Legally Takes Over

• Registration in the national EPR register in the seller's name.
• Annual reporting of volumes placed on the market to the PRO.
• Receipt of official letters and audits.
• Liability for compliance with national rules (jointly and severally with the seller).

Without an AR, market access in the destination country is legally no longer permitted from August 12, 2026. In Amazon's marketplace verification, naming the AR will be part of onboarding validation.

Pan-EU FBA: Seven Registration Systems at Once

Anyone using Amazon's Pan-EU FBA program has storage locations in Germany, France, Italy, Spain, Poland, and (depending on program status) Czech Republic. From Amazon's logistics logic that makes sense, from an EPR view it's a massive multiplication of obligations.

The EPR Consequences of Pan-EU FBA

• As soon as goods are stored in a country, they count as "placed on the market" in that country, even if the sale goes to a customer in another country. This triggers EPR obligations there.
• Concretely: Pan-EU FBA typically triggers EPR obligations in at least 7 countries (DE, FR, IT, ES, PL, CZ, plus at least one UK or Benelux country depending on shipping).
• Poland and Czech Republic are NOT among the Pay on Behalf countries. Here self-registration is required.

Realistic Compliance Costs for Pan-EU

From our work with brands in the 5 to 50 million euro annual revenue range, we see typical annual costs of 6,000 to 18,000 euros per brand for EPR compliance at Pan-EU level:

• Self-registrations and dual-system contracts in DE, NL, Austria, PL, CZ: about 2,500 to 5,000 euros
• Authorised Representative in 4 to 6 countries: about 3,500 to 9,000 euros
• Pay on Behalf service fees in FR, IT, ES, BE, UK: about 1,000 to 4,000 euros (varies strongly with assortment and packaging material)

More on the Pan-EU logic in our article on multi-marketplace strategy and in detail on EU expansion on Amazon.

Penalties, Suspensions, and the Worst Case

The legal consequences for missing or incomplete EPR registration have been significantly tightened over the last 18 months. The most important numbers:

Fines per Country (Selection)

• Germany: Fines up to 200,000 euros per violation under VerpackG (reference: per material ton and unregistered placing on the market).
• France: Up to 30,000 euros per violation plus additional TGAP surcharges.
• Italy: Up to 26,000 euros per violation, plus possible penalty measures for repeated offenses.
• Spain: Up to 3.5 million euros for serious violations of RD 1055/2022 (Packaging Waste Regulation).
• UK: Variable penalties, plus possible personal liability of directors.

What Amazon Does in a Suspension Case

• Automatic suspension of the affected ASINs in the respective marketplace (usually within 24 to 72 hours after data sync).
• For repeated or serious violations: temporary account suspension for the entire country.
• Restoration only after presenting a valid registration number, in practice 4 to 12 weeks delay due to processing times of national registers.

A suspension during Q4 business typically means 15 to 40 percent annual revenue loss, depending on seasonality. By far the most expensive way to deal with EPR compliance.

Checklist: EPR Compliance by August 12, 2026

• Check Compliance Portal in Seller Central: which marketplaces are active, which storage locations exist?
• Germany: LUCID registration plus dual-system contract, EAR number for electrical products, GRS BattG for batteries
• France: ADEME Identifiant Unique via CITEO, plus TGAP filing as needed
• Italy: CONAI registration, possibly with tax representative
• Spain: registration via SCRAP system (Ecoembes, Ecovidrio per material)
• Benelux + Austria: self-registration, NO Pay on Behalf available
• Name Authorised Representative in every EU country without own office (mandatory from August 12)
• Pan-EU FBA usage: check and cover EPR obligations in DE, FR, IT, ES, PL, CZ
• Multi-channel setup: self-registration for DTC, Otto, Zalando sales despite Amazon Pay on Behalf
• Establish annual reporting setup (volume tracking per material and country)
• Compliance service provider comparison: Lizenzero EU, Deutsche Recycling, Ecosistant, eucompliance (typically 800 to 2,500 euros per year and country)

Common Mistakes and How to Avoid Them

Mistake 1: "I have LUCID, I'm done"

LUCID is the registration number, not the actual compliance. You additionally need a contract with a dual system (Reclay, Interzero, Landbell etc.) that bills license fees per material and tonnage. A LUCID number without contract leads to suspension at the next check.

Mistake 2: "Amazon Pay on Behalf covers everything"

Pay on Behalf exclusively covers Amazon volumes, exclusively packaging (in most countries), exclusively in 5 countries. If you sell in parallel via DTC, Otto, or Zalando, you need your own registrations for those channels. If you sell electrical products (WEEE) or batteries, Pay on Behalf often doesn't cover those either.

Mistake 3: "Pan-EU FBA handles EPR automatically"

Pan-EU FBA does the opposite: it multiplies EPR obligations. Anyone wanting to benefit from Pan-EU must be EPR-compliant in at least 7 countries. From our experience, some brands deliberately exclude Poland and Czech Republic from the Pan-EU program to reduce compliance costs. This works via the storage location configuration in Seller Central.

Mistake 4: Authorised Representative is forgotten

Until July 2026, the AR was mainly relevant for third-country sellers. From August 12, 2026, the obligation also hits EU-internal cross-border sellers. Anyone who ignores this has no legal market entry in the destination country, regardless of EPR registration.

Mistake 5: Volume tracking is not established

EPR contributions are calculated based on volumes placed on the market, separated by material (cardboard, PE, PET, glass, aluminum etc.) and country. Without clean tracking you can't report accurately, and incorrect reports lead to recalculations and fines. Anyone without their own ERP interface should outsource tracking via the compliance service provider or via tools like eprio.eu.

Outlook: DPP and the Next EPR Waves

The PPWR is not the end of compliance tightening, but a step in a longer sequence. Three developments that become relevant in the next 18 months:

• Digital Product Passport (DPP): From 2027 for textiles, from 2028 for electronics, long-term for almost all product categories. Every product gets a QR code with origin, material, and recycling data. A first big step toward full integration of EPR data into the product itself.
• Textile EPR: France tightened textile EPR in 2025, Germany follows from January 2027. Anyone selling fashion on Amazon should already factor in the fashion-specific requirements now.
• Recyclability as market access requirement (2030): From January 1, 2030, packaging must be recyclable. This already feeds back into packaging design and supplier selection. Anyone developing new packaging in 2026 should make 2030 recyclability a mandatory criterion.

More on strategic context in our article on Amazon sustainability strategy and on the related compliance topic GPSR obligation, which has applied since December 2024.

Conclusion: Compliance Is No Longer a Side Project

The PPWR and its marketplace obligation from August 2026 makes EPR compliance an operationally top issue. Anyone still assuming today that Amazon "will somehow handle it" will have to deal with suspensions, Pay-on-Behalf fees, and expensive late registrations in fall 2026. The good news: the structures are known, the service providers established, and the effort for clean Pan-EU compliance moves in a manageable annual budget of 6,000 to 18,000 euros, depending on assortment breadth.

The most expensive option is the one many sellers afford themselves today: wait and hope. A single suspension in Q4 typically costs more than three years of clean compliance. And in the PPWR regime, these suspensions are no longer an exception from August 12, 2026, but the default.

If you need support setting up Pan-EU EPR, our marketplace agency assists with choosing the right compliance partners, setting up national registrations, and volume tracking across all sales channels. Book a free consultation.

Sources

• EUR-Lex: Regulation (EU) 2025/40 (PPWR) Full Text
• Lovat Compliance: PPWR Requirements 2026 Full Guide
• Lovat Compliance: EPR Compliance in Europe 2026
• Ecosistant: EPR Registration Number for Amazon
• Amazon Seller Central: EPR Requirements EU Packaging
• Amazon Seller Central: EPR Pay on Behalf Overview
• Lizenzero EU: Authorised Representative from 2026
• FLEX Logistik: PPWR meets LUCID in Germany
• Deutsche Recycling: EPR Compliance for Amazon Vendor Central
• Deutsche Recycling: Amazon Pan-EU EPR Compliance Guide
• Haendlerbund: Verpackungsverordnung PPWR
• Stiftung Zentrale Stelle Verpackungsregister (LUCID)
• Stiftung Elektro-Altgeraete-Register (EAR)
• About Amazon EU: Small Business EU Packaging Study