ppwr regulation: what small businesses need to know

Confused by the EU PPWR regulation? Learn how new packaging rules, EPR, and Authorised Representatives affect EU and non-EU small businesses.

In August 2026, a new EU packaging regulation came into force, causing widespread confusion for thousands of small businesses in the EU and beyond. The Packaging and Packaging Waste Regulation (PPWR) extends packaging rules across the whole bloc. One of its most disruptive changes requires sellers without a base in a given country to appoint a local Authorised Representative there before they can keep selling into it. Lots of small businesses did not know about this obligation until it was already in effect, causing many to pause selling to customers abroad.

Given the outpouring of questions and complaints from small business owners across social media, it's important to understand the facts around PPWR and the current state of play. In this article, we'll break down what it means for business owners who want to sell products to customers in the EU, and the latest developments and responses from the EU and various member states.

What is the PPWR regulation

The European Parliament gave its final approval to the PPWR in April 2024, and the Council of the EU formally adopted it in December 2024. It entered into force in February 2025, but most of its rules only started applying from 12 August 2026, after an 18-month transition period.

PPWR replaces the EU's old packaging directive, so instead of each country writing its own version into national law, it sets one set of rules on packaging design, recyclability, labelling and producer responsibility. The EU says this:

• Cut packaging waste
• Make all packaging in the EU market “recyclable in an economically viable way by 2030”
• Reduce the amount of virgin materials used in packaging
• Create a harmonised set of rules for packaging across the EU

PPWR versus Extended Producer Responsibility

PPWR works alongside something called Extended Producer Responsibility (EPR). EPR is the principle that a business that sells packaged goods pays for the packaging’s collection, sorting, and recycling. 

Before PPWR, national EPR schemes operated under a mix of different national laws. PPWR replaces that framework with EU-wide rules governing how EPR operates. Despite this, it does not create a single centralised EU registration portal. Sellers have been told they must register with national packaging registers and pay specific fees in every member state where they sell their products. Compliance requires having an Authorised Representative (AR) in each of those countries where the company does not already have a legal presence.

Who does PPWR affect?

PPWR applies to anyone who places packaging on the EU market, regardless of where their business is based. This includes:

• EU-based online sellers shipping packaged goods to customers in other member states
• Non-EU businesses, including UK sellers, selling packaged goods to EU customers
• Estonian companies run by e-⁠residents that trade across borders
• Importers, distributors and fulfilment partners handling packaged goods on someone else's behalf
• Online marketplaces, which must check that sellers hold valid packaging registrations

Crucially, while PPWR offers micro-enterprises exemptions from certain packaging reuse targets, it provides no size-based exemptions for Extended Producer Responsibility (EPR) or the Authorised Representative (AR) requirement. This means businesses with few or even zero employees have the same requirements as large businesses. Many have said they had no choice but to stop selling to other EU countries because they cannot afford the new requirements.

What has the EU Commission said about enforcement of PPWR?

Confusion reigned after the new rules came into effect. While the EU has tried to address questions and complaints from small business owners and national governments across the EU and beyond, it still isn’t completely clear what obligations are currently being enforced.

The European Commission has responded to a number of entrepreneurs in a comment on their social media posts, saying:

• “The initial implementation phase is about helping businesses adjust, not penalising them”.
• The Commission has proposed a suspension of the obligation to appoint an AR for EU businesses until 2035.
• The new EPR framework under PPWR “will not be fully operational for businesses from August 2026”, and for now businesses should comply with national EPR rules as usual.

On the Commission’s packaging waste website meanwhile, it says the proposal to suspend the AR obligation is currently being examined by the European Parliament and the Council of the European Union. There is no indication of exactly when this will be cleared up. Any suspension will relate to EU-based businesses, so if you are a UK-based seller, you would still have to follow the AR requirements.

When are the changes implemented?

Aside from the confusion above, there is a timeline the EU is working towards.

Do sellers need to register in every destination country?

There is no single yes or no answer, as it depends on how you sell and where you’re based. 

• Direct B2C sales: If you sell directly to a customer in another EU country, you generally count as the producer for that market, and you need to register there. For example, in Finland, since January 2024, the previous €1 million turnover exemption was removed, with its producer responsibility body Rinki confirming that any foreign online shop selling directly to Finnish customers must register in Finland's producer register.

• Marketplace sales: Marketplaces are required to check that sellers hold valid registrations before listing them, so non-compliance can lead to the risk of a delisting.

• EU and non-EU sellers: Both are in scope, as the obligation is tied to where the packaging is first made available, not where the seller is based.

• Authorised Representatives: If you have no legal presence in a country, you need to appoint someone there to register and report on your behalf. For example, an Estonian company selling into Finland that has no Finnish base needs a Finland-based AR. The European Commission has proposed suspending this duty until 2035 for producers already established in the EU, which would cover a case like this. But that is an ongoing discussion, not something in effect. Penalties for non-compliance are set nationally, and some countries already have draft rules about this.

• Importers and distributors: Selling through a local importer or distributor can shift the registration duty onto them, since they become the one placing the packaging on that market. Whether that actually applies depends on the specific contract.

Practical checklist for sellers

Before making any changes, think through this checklist:

• Map the countries where you sell packaged products
• Identify who places the packaging on each market
• Check national registration, reporting, fee and representative requirements
• Collect packaging composition and compliance data from suppliers
• Review contracts with marketplaces, importers, distributors and fulfilment partners
• Document your compliance decisions
• Seek specialist advice where needed
• Monitor Commission guidance, implementing acts and national updates

If you're looking for a setup to streamline e-commerce administration, check out our e-commerce checklist for e-⁠residents.

What does this mean for e-⁠residents?

e-Residency gives you a secure digital ID and access to Estonia's fully digital business environment, wherever you're based. While it doesn’t grant automatic access to other EU markets or exempt you from packaging rules, it does give you access to the e-⁠Residency Marketplace. Here you can find vetted service providers by country if you need help finding local compliance support or an authorised representative, among a host of other services.