PPWR since 12 August 2026: what actually changed, and what did not

What binds you now, and what was already binding

Six things bind packaging placed on the EU market today, and two of them were binding well before 12 August. They do not all land on the same operator, which is the detail most summaries flatten:

1. The national registration and scheme duties you already had. None of these started on 12 August 2026, and they are not one uniform thing. Germany runs a state register you enter yourself, LUCID, operated by the ZSVR. France works the other way round: you join an approved eco-organisation such as Citeo, and your unique identifier (IDU) is then issued by ADEME through the SYDEREP teleservice, so the registration normally happens via the scheme rather than by you filing into a register. In the Netherlands the duty runs through Verpact, the producer responsibility organisation you affiliate with. Austria requires a contract with an approved collection and recovery system, and for ordinary participants that system does the reporting into EDM, with direct EDM reporting reserved for specified cases. Whether any of it bit you at all also varied, because some countries set volume thresholds and others set none. What matters after August is that whatever you already owed, you still owe. PPWR's own national packaging register is a separate and later step: Article 44 gives member states 18 months from the implementing act that sets the registration format to establish it. Verpact states that the Dutch PPWR register must exist from 12 August 2027. Other member states will land on their own dates, and this guide is not going to guess them for you.
2. An authorised representative for EPR, whose reach depends on where you are established. An EU-established producer must appoint one, by written mandate, in each member state it sells into and is not established in. A non-EU producer follows each member state's own choice: several require a local representative, while Germany has you register in your own name instead.
3. Conformity assessment, a declaration of conformity, and technical documentation behind each type of packaging on the market. This is the CE-marking pattern applied to packaging, and PPWR splits it: Articles 15 and 18 give manufacturers and importers different duties. Who counts as the manufacturer depends on the packaging. For unbranded transport and e-commerce packaging, the party that makes the packaging normally is. For sales packaging and grouped packaging, the filler or the product brand owner normally is, which frequently means the merchant. Branding, control of the design and a micro-enterprise exception can move the answer, so decide it per packaging type rather than once for the whole store. What to ask each supplier for, and what you have to hold yourself, is set out in the PPWR declaration of conformity.
4. New PFAS limits in food-contact packaging. PPWR sets concentration limits for PFAS in packaging that comes into contact with food. This is the genuinely new substance restriction from August 2026, and it is a supplier question: ask what your food-contact packaging is coated or treated with.
5. The 100 mg/kg heavy-metals cap, which is not new. The sum of lead, cadmium, mercury and hexavalent chromium in packaging is capped at 100 mg/kg. That limit predates PPWR and carries over from the packaging directive PPWR replaces, so if you already met it, nothing changed for you in August.
6. Checks by everyone downstream. Distributors have to verify that the producer is registered, fulfilment providers have to check compliance before handling goods, and online marketplaces have to make best efforts to verify producer registration information.

One duty routinely added to lists like this does not belong on it. The general requirement to reduce packaging to the minimum weight and volume needed for function, safety and hygiene sits in Article 10 and applies from 1 January 2030. Article 24's duty to keep empty space in sales packaging to the minimum necessary is due by 12 February 2028. Neither started in August 2026. Where a member state already had national rules on excessive packaging, those carry on applying, so an obviously oversized parcel was never free of risk. What did not happen is a new PPWR packaging-size duty landing on 12 August 2026.

What did not land in August, whatever you have read

Most coverage compressed the whole regulation into one date. The obligations that would genuinely change your packaging are staggered over the following four years.

The empty-space rule, specifically

You will still see the void-space cap quoted as an August 2026 obligation, and sometimes at 40%. Both are wrong. Article 24 sets a maximum empty space ratio of 50% for grouped, transport and e-commerce packaging, and it applies by 1 January 2030, or three years after the relevant implementing acts if that is later. Ahead of that, Article 24 requires empty space in sales packaging to be kept to the minimum necessary by 12 February 2028, and the general minimisation duty in Article 10 applies from 1 January 2030. So PPWR put no new limit on the size of your parcels in August 2026. An authority that challenges an obviously oversized parcel today is doing it under national packaging rules that predate the regulation, not under Article 10 or Article 24.

If you are past the date and still not registered

A lot of stores are. Packaging EPR has never had a moment when every seller in scope registered at once, and national registers have been onboarding late arrivals for years. No enforcement switch flipped at midnight on 12 August. What changed is that the obligation is current rather than approaching, so the exposure now accumulates with every parcel you ship.

The exposure is per country, and that is the part that decides what you should do first. There is no single EU registration to be missing and no EU-wide penalty to be exposed to. You are unregistered in Germany, or in France, or in both, and each of those is a separate national obligation with its own scheme, its own register and its own enforcement appetite. Volume changes how much you owe and how likely anyone is to look. It does not change whether the duty applies. A store sending a handful of parcels a year to Portugal is unregistered in Portugal in the same sense that it is unregistered in Germany, and the difference is that a small market gives you a second option: you can close it and stop the exposure growing, even though closing it does not undo what you already sold there.

So the first job is scope, not paperwork. Pull your actual order history by destination country for the last twelve months, not your Shopify Markets settings, which usually list far more countries than you sell into in any volume. Rank the list, register at the top of it, and work down. Be clear about what that ranking does, though. It sets the order you fix things in. It does not make the bottom of the list compliant while you get there, and a country you are still shipping to without a registration is a country you are in breach in. For anything you are not going to register in soon, the practical option is to turn shipping and checkout off for that country until you are covered. Be precise about what closing checkout does. It stops the obligation growing from new sales. It does not erase the period in which you were selling there, and registration, reporting and fees for those sales can still be owed. Closing a market limits the damage. It is not a clean exit.

When you are catching up, take registration and scheme membership before conformity documentation. Registration is what a marketplace, a distributor or a fulfilment provider actually asks for, and it is the thing that gets checked. The declarations of conformity matter and you will need them, but chasing five packaging suppliers for paperwork while you are still unregistered in your biggest market is the wrong order. If you have no entity in a country, appointing the representative is part of that first step rather than a later one: what appointing one involves.

Register late rather than not at all. Continuing to sell into a country you know you are not registered in is the choice that keeps making the position worse: the volume you may eventually have to account for grows, and the commercial risk sits there the whole time. Schemes commonly ask newly registered producers about packaging they have already placed on that market, so gather your weights and materials first. Be accurate about what registering achieves, though. It reduces one category of ongoing non-compliance, the one where you keep placing packaging on a market you hold no registration in. It does not complete scheme participation, reporting or representation, and it does not erase what has already accrued on the parcels you have shipped. It is the right first move, not the end of the job.

The suspension that did not happen

On 10 December 2025 the Commission published its Environmental Omnibus. One of the six proposals, COM(2025) 982, would have suspended the EPR authorised-representative rule in Article 45(3) of PPWR until 1 January 2035. A lot of supplier newsletters picked that up and told sellers the requirement was going away.

It did not. The suspension was aimed at producers already established somewhere in the EU, and in June 2026 the Council reported that negotiations had been discontinued because a large majority of member states had strong reservations. The adopted text stands. Plan against the law in force, not against a proposal that stalled.

What this means if you sell on Shopify

PPWR does not create a single EU packaging registration. It harmonises the rules and then leaves you registering, reporting and paying country by country, through the national scheme and the national register in each market. If your Shopify Markets settings let customers in Germany, France, Italy, Spain and the Netherlands check out, that is five registers, five schemes, five sets of representative paperwork, and five annual declarations.

The volumes you declare come from your packaging, not your products, so the data you need is unglamorous: for every SKU, what it ships in, what that packaging is made of, and roughly what it weighs. Most stores have never recorded this anywhere. That is the real work behind every registration, and it is the part nobody else can assemble for you.

A realistic sequence from here

• Confirm which EU countries you actually ship to, and in what volume, from order history rather than Markets settings
• Turn shipping and checkout off for any member state you are not going to register in soon, knowing that this stops new exposure rather than clearing what already accrued
• Appoint an authorised representative in each remaining country where you have no entity
• Register in each national producer register and keep the numbers where a marketplace can be shown them
• List every packaging type you ship in, including tape, void fill and inserts
• Record material and weight per packaging type, then map it to your SKUs
• For each packaging type, work out whether you or your supplier is the manufacturer, then obtain or draw up the declaration of conformity and the material data, and keep it on file
• Diarise 12 February 2028 for empty space in sales packaging, 12 August 2028 for the harmonised sorting label, and 1 January 2030 for recycled content, the 50% empty space cap and the general minimisation duty

How Assuro helps

Assuro connects to your Shopify store, totals packaging by material across your catalogue, and flags where you ship into one of its six supported countries without a registration on record: Germany, France, the Netherlands, Austria, Italy and Spain. Obligation tracking covers those six, so a destination outside that list is still yours to check by hand. If you are catching up, it answers the scope question for those markets from your own data instead of a guess. It organizes and flags. It does not act as your authorised representative, register you, issue a declaration of conformity, or certify packaging.