What changes on 12 August 2026
Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR, applies from 12 August 2026 and is being phased in gradually over the following years[1]. If you operate a Dutch webshop or sell physical products across European borders, this date introduces direct EU-wide packaging rules, including initial requirements for conformity documentation and material restrictions[2].
The surge in platform verification checks rests on two binding layers at once, and it helps to keep them apart. The packaging-specific one is Article 45(4) of the PPWR itself: since 12 August 2026 a provider of an online platform that lets consumers conclude distance contracts with producers must obtain the producer's extended producer responsibility registration number for each member state of sale and make best efforts to assess whether that information is complete and reliable before allowing the producer to use its service[6]. This is why marketplaces now ask for a registration number per country rather than a single EU one.
The second layer is older and broader. Article 30 of the Digital Services Act (Regulation (EU) 2022/2065) requires platforms to make best efforts to assess trader information through a freely accessible official database or interface made available by a Member State or the Union, or by requesting supporting documents from the trader[3]. It covers trader identity in general rather than packaging, and it is fully in force: platforms had twelve months from 17 February 2024 to collect the data for traders already using their service, so that transitional window closed on 17 February 2025[3]. Public EPR registers such as the German LUCID register are exactly the kind of official database both layers point a platform at[4].
What genuinely remains open is not whether platforms must check, but the technical detail around the checking: the national producer registers the PPWR assumes are not all live, and the Commission still has to fill in formats and methodologies through secondary acts. That is a very different statement from saying the duty has not started.
| Regulatory layer | Primary legal driver | Status for marketplaces as of 2026 |
|---|---|---|
| Trader traceability | Digital Services Act (EU) 2022/2065, Art. 30 | Fully active: platforms must verify seller identity and compliance credentials, including for traders onboarded before February 2024[3] |
| National packaging EPR | National laws such as the German VerpackDG regime and its LUCID register, plus Dutch rules on the packaging waste management fee | Active: marketplaces block unverified sellers without valid registration numbers |
| PPWR platform verification | Regulation (EU) 2025/40, Art. 45(4) | Active since 12 August 2026: the platform must obtain and check the producer's EPR registration number per member state of sale[6] |
| Authorised representative | Regulation (EU) 2025/40, Art. 45(3) | Binding since 12 August 2026 in every member state where you sell and are not established[6] |
While the PPWR harmonises definitions across all member states, the administrative burden on cross-border sellers increases immediately because platforms enforce national compliance to protect their own liability.
Who is affected: a test for webshops and brands
Whether your company faces immediate platform checks depends on your physical supply chain, where you hold stock, and how you distribute your products. Under PPWR requirements, the economic operator who first makes packaging available in a specific national market is treated as the producer responsible for compliance.
You are likely subject to active verification if your business meets any of the following operational criteria:
- You are established in the Netherlands and ship packaged goods directly to end consumers in other EU member states, such as Germany.
- You sell via third-party digital platforms (such as Amazon, bol.com, or Kaufland) where the platform demands verified national producer numbers before listing.
- You import finished products or empty transport packaging from outside the European Union into the Dutch market.
- You operate as an own-label brand owner commissioning goods packaged under your own trade name.
The platform duty under Article 45(4) does not distinguish between EU and non-EU sellers: in both cases the marketplace has to obtain the producer's EPR registration number for the member state of sale and make best efforts to check it before letting the listing run[6]. What differs is how hard the number is to obtain: a seller without an establishment in the member state needs an authorised representative there first, so for non-EU sellers the check tends to surface a missing appointment rather than a missing number. Which obligations apply in each country depends on your exact role in the chain and on where you are established. These distinctions cannot reliably be resolved through a general checklist alone. Contact ClearoSystems for PPWR consulting to evaluate your specific setup and identify which requirements actually apply to your business.
What to do now that the date has passed
The 12 August 2026 date is behind us, so this is no longer preparation. Securing uninterrupted market access means closing your existing national obligations and having the technical data ready that marketplaces and commercial partners are already asking for. While adjacent EPR tracks for electronics and batteries require separate compliance steps, packaging compliance demands immediate priority.
We recommend working through four concrete action points to ensure compliance:
- Complete all existing national packaging registrations: Ensure your company is registered with Verpact in the Netherlands, where the packaging waste management fee applies once you bring more than 50,000 kilograms of packaging material onto the Dutch market in a calendar year[5], and that you hold a LUCID registration as a producer for sales into Germany, plus a system participation agreement where your packaging is subject to system participation[7]. Note that neither threshold helps you here: Verpact applies no declaration threshold at all to deposit packaging or packaging under the single-use plastics rules[10], and the German duty starts at the first sales package.
- Appoint an authorised representative where you are not established: Article 45(3) requires a written mandate for extended producer responsibility in every member state where you make packaging available for the first time and have no establishment[6]. The Commission proposed suspending this until 1 January 2035 for producers already established in the EU on 10 December 2025, but the Council discontinued negotiations on 24 June 2026[11], so plan on the obligation, not on the relief.
- Audit packaging specifications against the PPWR standards now in force: Check that your packaging files document material composition, empty-space ratios, and compliance with the PFAS restriction for food-contact materials, which has applied since 12 August 2026[8].
- Organise compliance documentation for platform retrieval: Compile your national registration numbers and producer declarations into a central compliance dossier so you can submit them promptly upon platform request.
Establishing this documentation early prevents sudden listing suspensions when platforms automate their compliance sweeps across cross-border accounts.
What has not changed: national EPR continues
A common misconception among online retailers is that the European regulation immediately replaces national environmental registers. It does not. The PPWR adds a unified framework of packaging requirements on top of existing national systems; it does not abolish national schemes such as Verpact registration in the Netherlands or the LUCID register in Germany.
In the Netherlands, the statutory 50,000 kg annual volume threshold under Dutch packaging law remains in force today: below it, an exemption applies and you pay no waste contribution to Verpact[9]. You are not required to pay packaging fees below this threshold in 2026, though administrative record-keeping duties apply from the first parcel you ship.
| Obligation element | Current Dutch regime (Verpact) | Status under PPWR in 2026 |
|---|---|---|
| 50,000 kg fee threshold | In force: a threshold of 50,000 kg per calendar year applies to taxable packaging other than SUP and deposit packaging | Remains active until national transition instruments take effect |
| National reporting | Mandatory for companies above threshold | Continues alongside PPWR documentation duties |
| Cross-border sales to Germany | Requires registration in the German LUCID register as a producer, plus a system participation agreement | Unchanged: German registration duties remain fully active |
National reporting cycles and fee structures continue as normal. Meeting your local duties under packaging EPR remains the baseline requirement for selling legally on any marketplace.
Outlook: how the rules will develop from here
The regulatory architecture will continue to evolve significantly after August 2026. Verpact counts at least thirty further documents setting out detailed legal requirements through 2029, covering technical methodologies, recyclability performance grades, and harmonised labelling formats[9].
At the national level, the timeline for structural changes remains subject to ongoing legislative processes. Verpact pressed the pause button on 22 July 2026 for shipping, service and primary production packaging, because who counts as the producer of those is unsettled, and it has asked companies to keep working on the basis of the situation as it stood before 12 August 2026 while definitions and the allocation of duties are clarified at EU level[9]. Note what that pause does and does not cover: it concerns who reports the Dutch kilograms for those three packaging types, not the product rules for the packaging itself, and not the platform checks described above.
On the volume question, Verpact expects the national producer register from 12 August 2027 at the earliest, with 2028 as the first reporting year, to be declared before 1 June 2029, and expects the declaration threshold to lapse at that point with a simplified declaration for companies under 10,000 kg per year[12]. Dutch guidance points the same way[1]. All of it is scheme operator expectation: how much those contributions will be and how they will be calculated has not been determined in any enacted Dutch instrument.
Which obligations apply in each country depends on your exact role in the chain and on where you are established: importer, own-label seller, or reseller each lands differently across European markets. These distinctions cannot reliably be resolved through a general checklist alone. To understand your PPWR position today and be on the safe side, contact ClearoSystems for PPWR consulting to evaluate your specific setup and ensure ongoing compliance as the legal requirements evolve.
Frequently asked questions
- Am I affected by the PPWR changes from August 2026?
- Yes, if you manufacture, import, or ship packaged products into the EU. The PPWR applies from 12 August 2026, and your exact obligations depend on your specific role in the supply chain and your sales channels, including marketplaces.
- The date has passed. What do I have to do now?
- Complete your national packaging registrations, such as Verpact in the Netherlands and LUCID for Germany, and appoint an authorised representative in every member state where you sell without an establishment. Hold the registration numbers ready per country: marketplaces must obtain and check them under Article 45(4), on top of the DSA traceability data.
- What happens if I do nothing?
- A platform that cannot obtain and verify your EPR registration number may not let you use its service for those listings, so in practice they are suppressed or removed in the affected market. Separately, national regulators can enforce penalties for missing registrations under existing national EPR laws.
- Does the PPWR replace Verpact or LUCID?
- No. National EPR registration and reporting duties continue. The PPWR adds an overarching EU framework, but it does not replace the national registers like Verpact in the Netherlands or LUCID in Germany.
- Will the 50,000 kg threshold in the Netherlands disappear in 2026?
- No. The 50,000 kg threshold for taxable packaging other than SUP and deposit packaging remains in force today. It is expected to lapse only once the PPWR producer register and reporting duties actually apply, and no Dutch implementing instrument has yet fixed that date, so the current threshold continues to apply until one is published.
