The new EU Packaging Regulation (PPWR): What you as a seller need to know
Important note:
This information does not constitute legal or PPWR compliance advice from Kaufland Global Marketplace. It is solely your responsibility as a seller to ensure that your products, packaging, offers and sales comply with all applicable laws, including the obligations arising from Extended Producer Responsibility (EPR). As a sales partner, you are required to know and comply with all applicable laws, standards, and regulations.
Background
The new EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) is the basis of the new packaging legislation in Europe. Under the Extended Producer Responsibility (EPR) framework, the PPWR obliges all EU member states to establish mandatory EPR systems for packaging.
While some countries have already established such systems, they are now becoming the standard across the EU. From August 12, 2026, these uniform rules will replace previous national regulations and are intended to improve waste prevention and recycling.
The PPWR pursues three main objectives:
- Reduce waste: Reduce the total amount of packaging waste generated
- Strengthen the circular economy: Ensure that packaging is reused or recycled.
- Standardise labelling: EU-wide uniform recycling and sorting instructions
The PPWR is an EU regulation that is directly and uniformly applicable in all member states without prior transposition into national law. Individual requirements (e.g. regarding recyclability, recycled content or labelling) will come into force in staggered phases in subsequent years.
What does this mean for you?
If you sell in the EU, you must be EPR registered for packaging in every country where you operate or plan to expand.
Applying for your EPR registration numbers (EPR IDs) may take some time. If you haven’t already done so, we strongly recommend that you start the process early.
Important! You are responsible for yourself:
As the seller or distributor of products, the responsibility for fulfilling all EPR obligations (registration, quantity reporting, payment of fees) lies solely with you. This applies regardless of whether and how a marketplace verifies the information.
Who is considered the manufacturer?
For the purposes of the EPR, the “manufacturer” is the company that first places the packaging on the market in a national market in the supply chain – regardless of who produced the packaging. In the case of direct sales to end customers, this is usually the distance seller, i.e. the company selling online.
Please note: The PPWR distinguishes between manufacturer and producer. Both require registration – therefore, check whether either role applies to you and what this means for you. We will use both terms in the following information.
However, if a seller obtains their goods from an upstream supplier in the same country (e.g. an importer or manufacturer based there) who is already considered a manufacturer within the meaning of the EPR, the seller himself is not the manufacturer.
EPR refers to primary packaging (product packaging), secondary packaging (shipping packaging added by you), tertiary packaging, and service packaging. Since virtually every shipment in online selling is packaged, almost every seller is affected.
Connection to national EPR registration
The PPWR does not replace country-specific EPR registrations, but makes EPR mandatory for packaging across the EU. This means for you:
- There is no EU-wide collective registration. You must register separately in each country where you are considered a manufacturer/producer and join a Producer Responsibility Organization (PRO).
- You report your packaging volumes and continue to pay recycling fees per country.
- According to the PPWR, manufacturers who place packaging on the market in a country where their own company headquarters are not present must appoint an Authorised Representative in that country. As the exact procedures are still being implemented across the EU, we recommend contacting your respective PRO or a service partner early on.
Please note: The immediate risk is not only in future PPWR requirements, but is already evident in a missing or incomplete EPR registration. Therefore, first ensure that you are correctly registered in all relevant markets and compliant with your reporting obligations.
Overview of manufacturer registers and packaging IDs by country
The following overview shows the responsible manufacturer register or the relevant PRO for each country, as well as the format of the packaging registration number. Registration for packaging is relevant for almost all sellers; depending on the product range, further categories (electrical appliances/WEEE, batteries, etc.) may be added.
| Country | Register / authority | PRO (examples) | Packaging number format |
| Germany | Packaging register LUCID (Stiftung Zentrale Stelle Verpackungsregister, ZSVR) | Interzero, BellandVision, Reclay, etc. | 13-digit LUCID number (format: DE…………) |
| France | National register SYDEREP of the Environment Agency ADEME | Citeo, Léko, Adelphe | UIN / IDU (Unique Identifier), assigned by ADEME (format e.g. FRxxxxxx_xxxxxx) |
| Spain | RPP – Registro de Productores de Producto (MITECO ) | Ecoembes, ProCircular | ENV/YEAR/XXXXXXXXX |
| Netherlands | Central processing via PRO (notification to ILT if necessary) | Verpact (formerly Afvalfonds Verpakkingen) | No standardised public number format; PRO contract/participant number |
| Czech Republic | List of persons at the Ministry of the Environment (MŽP) EKOM & VISOH2 | EKO-KOM | EKO-KOM client number (contract-dependent) EK-R+8 digits EK-F+8 digits For CZ Seller X…/X…/X…/X… |
| Slovakia | Register of the Ministry of the Environment (ISOH) | NATUR-PACK, ENVI-PAK etc. | Registration number of the Ministry of the Environment (contract/register dependent) PO_+ 7 digits RV + 12 alphanumeric characters |
| Poland | BDO register (Baza danych o produktach and opakowaniach) | via approved organisations | BDO number (usually a multi-digit registration number) |
| Austria | Packaging Coordination Office (VKS)* | ARA, AGR, ERP Austria, Interzero, Reclay | VKS number (assigned via the system/PRO) |
| Italy | Entry via the consortium system | CONAI (and associated material consortia) | CONAI membership/contract number (no standardised public format) |
*VKS number (Austria): Collection and recycling systems (SVS) are responsible for the collection and recycling of packaging waste in Austria. If you are registered with one of these systems, you will be assigned a VKS number. You can find your number in the VKS register.
Please note: Kaufland Global Marketplace currently uses the VKS number and the VKS register as proof on a provisional basis. Since the responsible Austrian authority has not yet established an official register in accordance with the PPWR requirements, Kaufland Global Marketplace reserves the right to adjust the requirements at a later date.
Note regarding number formats:
Only in certain countries (e.g. Germany with the LUCID number or Spain with the ENV format) does a clearly standardised, publicly uniform number format exist. For other countries, no fixed format has yet been specified – here you will receive a register- or contract-related identifier from the responsible authority or PRO. The number that is officially assigned to you after successful registration is always the determining factor.
What information do I need to enter in the Seller Portal to sell with Kaufland Global Marketplace?
- Enter the packaging registration number: Once you have a valid packaging registration number (and numbers for other categories, if applicable) for a country, enter it in the Seller Portal:
- In the Seller Portal, go to Shop Settings and select theEPR Compliance tab.
- Select the relevant sales country using the selection in the upper right corner.
- Click on “Add another EPR number”, select the product category (e.g. packaging) and enter your number. The system will display the expected format.
- Click on “Submit for review”. Your number will then be validated and listed in the overview.
Repeat the process for each country and category in which you sell.
- Confirmation and self-certification: You confirm the agreement in accordance with Regulation (EU) 2025/40 via the legal texts. By doing so, you commit to offering only packaging that meets the requirements of extended producer responsibility according to Article 45(1), (2) and (3) of Regulation (EU) 2025/40.
What you need to do now:
- Register with the local PROs: In all countries where you sell, make sure you are registered with the local PRO for packaging.
- Plan your expansion proactively: Initiate registrations for new markets early – regulatory lead times can often take several weeks.
- Enter EPR numbers: Enter your country-specific EPR numbers in the Seller Portal.
- Authorised representatives: Clarify in which countries you need an authorised representative as a non-resident seller.
Support from service partners
Our partner, take-e-way, can assist you with EPR registrations, packaging declarations, and the appointment of authorised representatives in the individual EU countries. As a Kaufland Global Marketplace seller, you receive a 10% discount on the service fee! You can find more information in the Marketplace Services.
FAQ
What is Extended Producer Responsibility (EPR)?
EPR is an environmental policy approach in which manufacturers/producers assume physical or financial responsibility for the disposal of their products and packaging at the end of their life cycle. Anyone who places certain products or packaging on the market for the first time in the supply chain on a national market is subject to EPR regulations and fulfils this obligation by participating in an EPR system (a PRO): registration, quantity reporting and payment of the respective fee.
What does the new PPWR regulate?
EPR for packaging has been in place in most European countries for years. The PPWR now makes EPR mandatory for packaging in all EU member states. From August 12, 2026, all member states must enable manufacturers/producers to register their packaging. The PPWR also includes a mandatory testing system for marketplaces.
Which countries are subject to the new EU packaging regulation?
The PPWR makes EPR mandatory for packaging in all EU member states. Most member states have already introduced EPR for packaging. The PPWR date of application is August 12, 2026.
Which types of packaging are affected?
EPR refers to primary packaging (product packaging), supplementary secondary packaging (shipping packaging), tertiary packaging and service packaging.
How many registrations do I need to be able to sell in the EU?
If you are considered a manufacturer, you must register separately for EPR in each country where you sell products. There is no EU-wide collective registration. Please also note that in addition to packaging, there may also be other EPR obligations, for example for batteries, electrical appliances (WEEE) and textiles.
What happens if I don’t enter a valid registration number in the Seller Portal?
The PPWR provides a mandatory testing system for marketplaces. If a required registration number is missing, this can lead to the affected products no longer being allowed to be sold and corresponding offers having to be hidden on the Kaufland marketplaces. Therefore, please ensure in good time that your registrations are complete and the numbers are entered in the Seller Portal.
What changes are there regarding the packaging labelling?
The PPWR is introducing EU-wide standardised labelling for material, sorting and separate collection. Additional labelling requirements apply to reusable packaging and packaging in deposit and take-back systems. The exact requirements and deadlines will be regulated gradually by the EU Commission through implementing acts.
What are the rules regarding packaging size in shipment-based selling?
From 2030 onwards, the PPWR stipulates a maximum empty space quota (usually 50 percent) for collection, shipping and e-commerce packaging and prohibits unnecessary double or oversized packaging. This is particularly relevant for online selling: Check your shipping packaging early on to ensure it is dimensioned appropriately.
What other staggered packaging requirements will come into effect from 2030 onwards?
From 2030 onwards, packaging must be recyclable and meet defined design criteria. Plastic packaging is also subject to mandatory minimum recycled content requirements. Furthermore, certain single-use plastic packaging is prohibited (e.g. certain outer packaging or single-use packaging for fresh fruit and vegetables under 1.5 kg). You should independently verify whether and to what extent these requirements apply to your products.
Where can I find more information?
The full text of the EU Packaging Regulation (PPWR) as well as an overview of the EU rules, implementation and timetable can be viewed at the European Commission. The Commission’s final guidelines and FAQ (March 2026) are available here.
Disclaimer
This information does not constitute legal advice and does not serve as a substitute for such advice. Please ensure that you are informed about your own responsibility and, if necessary, obtain legal advice regarding whether any of the products you offer fall under applicable categories and requirements.