For brands selling into Europe, product compliance is not one process. It is four separate regimes running in parallel: packaging EPR, WEEE for electricals, battery registration, and GPSR on the product safety side. None of them replaces another. Each one means its own registration, its own paperwork and, in most cases, a separate obligation in every country you sell in.
The reason this matters right now is 12 August 2026, the date the EU's new Packaging and Packaging Waste Regulation ((EU) 2025/40, or PPWR) becomes applicable. But the calendar is the smaller half of the story. The bigger half is what is happening on the ground: registration queues in several member states are badly backed up, and in some of them an application started today will not produce a number in time. The Netherlands is not processing non-EU applicants at all. Poland has more than 15,000 applications waiting. Italy's national packaging registry has not opened yet.
That is worth reframing straight away. If your registration is late, it is usually not because you were slow, it is because the authority on the other side is. Knowing which countries those are lets you plan around them instead of panicking about them. This article covers what each of the four regimes actually covers, what the country-by-country picture looks like today, and what your options are when a registration will not land before the deadline.
The most common mistake is treating all of this as a single heading called 'compliance'. In practice you are dealing with separate legislation, separate bodies and separate registration numbers.
| Regime | What it covers | Who it binds | When it is needed |
|---|---|---|---|
| Packaging EPR | Product packaging, shipping cartons, void fill, labels | Anyone selling a packaged product, whatever the category | At account opening |
| WEEE | Electrical and electronic products | Any product with a plug, a battery or a circuit, including light-up toys | At account opening |
| Batteries | Batteries inside the product or supplied with it | A separate regime; your WEEE registration does not cover it | At account opening |
| GPSR | Product safety: responsible person, technical file, labelling, traceability | Anyone selling a consumer product | At the listing stage |
The last column is the one to read twice. EPR and WEEE registrations are asked for before the marketplace account opens; GPSR comes into play when you list products. Sellers who put together their GPSR documentation for account opening and leave EPR for later end up with no account at all. In our experience that mix-up is one of the most frequent causes of delay.
PPWR pulls the EU's packaging rules into a single regulation. The previous instrument was a directive, which every member state transposed into its own national law, and that is exactly why implementation varied so much from country to country. A regulation applies directly.
Even so, 'everything changes on 12 August' is the wrong reading. The timeline is staged:
| When | What happens |
|---|---|
| 11 February 2025 | The regulation entered into force (application had not begun) |
| 12 August 2026 | The regulation becomes applicable. Member states stand up producer registers, with registration and reporting obligations; PFAS ban on food-contact packaging |
| Mid-2028 | New mandatory labelling rules: harmonised EU symbols, material-based icons, separate labels on multi-component packaging |
You do not need to redesign your packaging today. Labelling is in a transition period and the mandatory rules are scheduled for mid-2028. What is urgent today is the registration side.
One deliberate omission: we are not quoting a figure for empty-space ratios in packaging, because sources disagree on both the threshold and the date it starts to bite. If you are about to commit to a packaging redesign, check that against the regulation text or a compliance adviser rather than a blog post.
An authorised representative. In many cases a seller established outside the EU cannot complete an EPR registration without appointing an authorised representative in that country. The representative registers with the scheme on your behalf, files the declarations, and in some country and category combinations legally takes on part of the obligation itself.
It is not compulsory for every country and every category. Whether you need one depends on which country you are registering in and under which EPR category. 'If you are outside the EU you always need a representative' is not accurate, and paying for representatives you do not need is a real cost line.
The GPSR responsible person. On the product safety side the position is firmer: every consumer product must have a responsible person established in the EU. An EU-established manufacturer, importer, authorised representative or fulfilment service provider can take that role. A product without one cannot legally be placed on the EU market, and that person's name and contact details have to appear on the product or its packaging.
Add these up and the structural point is hard to avoid: some form of presence or representation inside the EU is not a nice-to-have, it is a precondition at most of the doors. It is also why we treat legal compliance as something to settle before logistics and fulfilment. A warehouse you cannot list products into is an expensive ornament.
This is the section that will age fastest, which is also what makes it worth reading. As the PPWR date approaches, applications are piling up in every member state, and authorities and PROs (producer responsibility organisations) are working through backlogs. On top of that, the summer holiday period lands right in the middle of it. The table below reflects the position as at 6 July 2026, compiled from our compliance partner TBA Global, whom you can also work with directly, and from applications we are running ourselves.
| Country | Status | What it means for you |
|---|---|---|
| Germany, France | Working normally, numbers issued within standard timeframes | No problem here. Start with these |
| Italy | The national packaging register has not opened yet | You cannot register, but Amazon has confirmed officially that the missing number does not affect your sales or trigger a suspension |
| Netherlands | The PRO is currently registering EU-established companies only; non-EU applications are not being processed | With a non-EU entity you cannot even join the queue. An EU company removes the obstacle |
| Poland | 15,000+ applications backed up; the authority is on summer leave. Priority order: Polish companies, then EU, then non-EU | At the current rate, 5 to 6 months is possible. You are at the back of the queue |
| Spain | Apostille times have lengthened, plus the summer period | With a Spanish VAT number and an apostilled document, 1 to 2 months; VAT but no apostille, 2 to 3 months; neither, 3 to 5 months |
| Belgium | 11,000+ applications; a system upgrade is under way | A provisional membership number is issued first, and it can be used as evidence that registration is in progress |
| Sweden | The authority is closed from 13 July to 17 August | Applications filed before 20 June run normally; later ones face 1 to 2 months of extra delay |
| Ireland | Currently processing applications from the start of March | Roughly a four-month backlog |
Three conclusions follow from this table:
It is worth being straight about this, because there is plenty of exaggeration in circulation.
Listings can be blocked, but not automatically and not everywhere. Germany is the hardest example: Amazon Germany has long blocked listings from sellers without a valid LUCID number. Italy is the opposite case, where the register has not opened and Amazon does not treat the missing number as a problem. In other words, enforcement follows the state of the system in that country more closely than it follows the legislation. Where the authority cannot issue a registration, marketplaces generally acknowledge that.
The obligation does not wait for your registration to come through. The EPR contribution is calculated on the volume of packaging you place on the market. A registration delay does not postpone the obligation; declarations and payment for the period you sold unregistered can still come up. That is why keeping accurate records of your sales volumes from today makes the retrospective declaration far easier once the number arrives.
Liability stays with the seller. The marketplace checks your compliance but does not assume the obligation. The enforcement authority goes directly to the producer or seller.
The most expensive scenario is the one where your account is open, you are selling, and your listings get blocked. Revenue stops while you wait for a registration. A delay for a brand still in setup and a delay for a brand already trading are not the same event; in the second case it converts into lost money every week.
| Order | Step | What it unlocks |
|---|---|---|
| 1 | Split your product inventory by regime: packaging / electricals / battery-containing / textiles | Determines which registrations you actually need |
| 2 | Finalise your country list and sequence it with the queue situation in mind | Filing early in the slow countries shortens the total timeline |
| 3 | Establish, per country and category, whether an authorised representative is required | Where it is, it is a precondition of the registration |
| 4 | EPR / WEEE / battery registrations plus the dual system licence | Opening the marketplace account |
| 5 | GPSR: responsible person, risk analysis, technical file, labelling | Getting the product listed |
| 6 | Country-specific marking (Triman today; the harmonised EU label from 2028) | Legal selling in that country |
| 7 | Annual declarations and volume reporting | Keeping the registration valid |
Step 7 is the most forgotten one. EPR is not a job you do once and close. Every year you have to declare the volume of packaging you placed on the market. Miss the declaration and the registration can lapse, which puts you back in front of the same blocked-listing risk. Compliance is not a setup task, it is an operation that has to keep running.
The sequencing advice in step 2 is genuinely new. The classic approach says start with the largest market. On today's picture that is wrong: Germany and France already issue numbers quickly, while Poland and Spain take months. Filing in the slow countries now and running the fast ones in parallel can cut months off your total time to launch.
The rest of this article is about the burden; here is a piece of news running the other way.
For a brand opening in several countries, one of the largest lines on the compliance bill is repeated laboratory testing. Testing the same product again for every market costs both money and calendar time. Amazon has announced a service under which a single conformity test is accepted across 16 marketplaces: the United States, Germany, Italy, Spain, France, Poland, the Netherlands, Sweden, Belgium, the United Kingdom, Canada, Japan, Australia, Mexico, Saudi Arabia and the UAE. It starts with the toy category, with electronics and baby products next in line.
It is important to understand the limit correctly. This is a convenience within Amazon's own acceptance process. It does not remove EPR, WEEE, battery or GPSR registrations; those obligations come from legislation and continue country by country. What changes is that the cost of proving a product's technical conformity drops to a single exercise within the Amazon channel. It lowers the threshold for opening a new market; it does not lift the compliance obligation.
The honest answer: it depends on the number of countries and your product category, and it is not a single cost line. It helps to think of the structure in three layers.
On top of that sit the other fixed items that come with selling abroad: a foreign entity, warehousing, integrations, local customer service and tax representation. Compliance is one line in that table, but without it none of the other lines does anything, because the product cannot be listed.
On timing, the most misleading assumption is this: 'I will do the registration, it takes a week.' For one category in one country, perhaps. For three categories across eight countries, each with its own representative and its own register, this is a project.
| Your situation | Priority before 12 August |
|---|---|
| Already selling in the EU, registered in Germany only | The most urgent group. Start the registrations for the other countries you sell in immediately; your existing revenue is at risk |
| Selling in the EU with complete registrations | Check that the annual declarations are current and the packaging-type reporting is accurate |
| Planning to launch, not selling yet | You are in the better position, but the queues are long. Choose your countries with registration time factored in |
| Selling electronics or products with batteries | Three regimes at once: packaging plus WEEE plus batteries. Have the category matching verified by a specialist |
| Targeting the Netherlands or Poland | Both are the most blocked markets for a non-EU seller today. An EU legal entity removes that obstacle directly |
If you have read this far, the picture is clear enough: four separate regimes, registration country by country, an authorised representative in some places, annual declarations, and on top of it all a set of registration queues that are currently jammed.
None of this is individually unsolvable. The real difficulty sits in two places: the rules keep changing and the obligation multiplies country by country. This article is its own evidence. A directive turns into a regulation, one country's register never opens, another stops processing non-EU applications, a third closes for the summer. Knowing how that table looks in each country is more useful in practice than knowing the legislation, and it is only learned by running the process every day.
There is also this: if you build the structure alone, you carry the cost of an authorised representative and a register in every country on a single brand, yours. When the same structure is shared across several brands, both the cost and the monitoring burden are divided.
MegaMerchant works as your brand's cross-border e-commerce department, with an established EU structure, working compliance processes and a team that has run these registrations many times over. We manage the compliance side together with TBA Global: you deal with one point of contact, and country-by-country register tracking stays with us. Have a look at our legal compliance service, or talk to us directly.
A note on transparency: this article is not legal advice. Registration obligations vary with your product category, your packaging structure and the countries you sell in; take advice from a compliance consultant or a lawyer before any critical decision. All sources are either official texts or publications from the party running the process directly.
The information on this page was updated as at 21 July 2026. The country-by-country registration status table is as at 6 July 2026 and changes within weeks, so confirm it at source before any critical decision.
MegaMerchant is the seller of record abroad: accounts, compliance, logistics and returns run on our side.
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