What are my EPR obligations under the EU's Packaging and Packaging Waste Regulation (PPWR)?

The Packaging and Packaging Waste Regulation 2025/40 (PPWR) introduces new rules across all EU countries to increase the sustainability of packaging, reduce waste, and advance the circular economy.

The requirements of the legislation apply from 12 August, 2026. As national implementation continues to evolve, country-specific Extended Producer Responsibility (EPR) requirements may differ. PPWR applies across the EU from August 12th, 2026. Member States are at different stages of aligning their national EPR frameworks and implementing the necessary PPWR-specific rules and administrative mechanisms. Existing national EPR requirements continue to apply to the extent they remain applicable during this transition. We will continue monitoring regulatory developments and plan to provide updates on our website as further clarity becomes available. 

PPWR is also setting additional requirements on packaging, including sustainability of materials and limits to empty space in packages, but these will come into force in 2030. Printful’s packaging is well-aligned with the minimum requirements set out for 2030, and we are working to improve our packaging even further.

Why EPR responsibilities depend on where you sell, not where you’re based 

Your EPR responsibilities are determined by your sales destinations, not by where your business is located. For example, a US-based seller with no legal entity in the EU is still considered a producer under the PPWR. This means that even if you’ve never had EPR registration or reporting obligations before, you may have them now. 

What "manufacturer" and "producer" mean under the PPWR 

Two legal terms used by regulators are most relevant to merchants: 

• Manufacturer: Under the PPWR, this generally refers to the entity that manufactures packaging, or has packaging designed or manufactured, and markets it under its own name or trademark. The manufacturer is responsible for packaging conformity requirements, including the applicable technical documentation and EU Declaration of Conformity. Based on the EU Commission’s current guidance as of July 31, 2026, the Manufacturer role likely falls to Printful. 
• Producer: The party that invoices the end customer. Producers must register with national registries, report the physical weight of materials shipped, and pay recycling eco-fees in the country where the packaging becomes waste. Whether you as a merchant carry producer responsibilities yourself in a specific EU member state or you can defer certain producer responsibilities to Printful is dependent on national legislation. The same business may hold different roles in different supply chains or EU countries. You should therefore assess your role based on the applicable legislation and the facts of your own sales and fulfillment model. 

What’s changing for merchants selling into the EU 

• Merchants selling into the EU can provide Printful’s registration number for countries where Printful has completed the relevant Producer registration. Currently Printful is registered for packaging in Germany, and merchants who use Printful exclusively can use the LUCID number DE4402313676935. Printful is working on expanding its EPR registrations across the EU, however, Member States are at different stages of implementing the relevant national requirements and registration mechanisms, so Printful is unable to share additional EPR information for other EU Member States at this stage.
• Marketplaces are tightening enforcement independently of us. Amazon, TikTok, and others are increasingly requiring sellers to upload their own valid EPR registration numbers, and are legally required to restrict sales if a seller doesn’t have one on file. 

Steps to prepare for EPR requirements as a merchant 

1. Review which EU countries you sell products to and conduct a legal assessment on whether the national EPR legislation sets Producer obligations for you. While you may refer to our EPR informational guidance above, we recommend consulting a professional adviser to assess your legal obligations in the EU countries you sell to. Merchants who use Printful exclusively can use the LUCID number DE4402313676935. 
2. Watch for communications from the marketplaces you sell on, since those platforms set their own requirements and timelines and sometimes offer pay-on-behalf schemes for EPR reporting. 
3. Prepare to report packaging volumes to the national authorities. Printful will prepare information needed for reporting any packages fulfilled through Printful. We will share more information as soon as possible.