PPWR for Amazon and Shopify Sellers: Your Complete Compliance Guide

If you sell on Amazon, Shopify, eBay, or any other marketplace that ships to EU customers, the new EU Packaging and Packaging Waste Regulation (PPWR) directly affects your business. Ignoring it is not an option -- marketplaces are preparing enforcement mechanisms that could suspend your listings.

This guide breaks down exactly what PPWR means for online sellers, what packaging counts, what you need to do, and the timeline you are working against.

What Is the PPWR and Why Should Marketplace Sellers Care?

The PPWR (Regulation (EU) 2025/40) replaces the old Packaging Directive with a directly applicable regulation across all 27 EU member states. Unlike the previous directive, which each country implemented differently, the PPWR creates a single set of rules. For PPWR Amazon seller compliance and PPWR Shopify ecommerce operations, this means one regulation to follow instead of 27.

The regulation entered into force on 11 August 2025. Key obligations for e-commerce sellers start phasing in from August 2026, with the most impactful requirements landing between 2026 and 2030.

Why should you care right now? Because Amazon, eBay, and other marketplaces operating in the EU are legally required to ensure that sellers on their platforms comply. If you do not comply, marketplaces will restrict or remove your listings. This is not speculation -- Article 45 of the PPWR places explicit obligations on online marketplace operators.

What Packaging Counts? All of It.

This is where many PPWR marketplace seller obligations catch people off guard. Under the PPWR, every layer of packaging you use counts:

Packaging Type	Examples	PPWR Applies?
Primary (sales) packaging	Product box, bottle, blister pack	Yes
Secondary (grouped) packaging	Cardboard sleeve around 3 units	Yes
Transport packaging	Shipping box, poly mailer	Yes
E-commerce packaging	Shipping box sized for the product	Yes
Void fill	Air pillows, paper fill, foam peanuts	Yes
Ancillary elements	Tape, labels, staples	Yes

If you sell a product in a branded box, wrap it in bubble wrap, place it in a poly mailer, and ship it in a corrugated box with air pillows -- that is five separate packaging components, each subject to PPWR requirements.

FBA Sellers: You Are Not Off the Hook

If you use Fulfillment by Amazon (FBA), Amazon handles the outer shipping box and void fill. However, you remain responsible for your product packaging -- the primary and any secondary packaging that arrives at the Amazon warehouse. Amazon's FBA packaging does not absolve you of your obligations for the packaging you designed and produced.

For FBM (Fulfilled by Merchant) sellers and Shopify store owners shipping directly, you are responsible for every layer.

The 50% Empty Space Rule for E-Commerce

Article 24 of the PPWR introduces a rule that hits e-commerce sellers especially hard: transport and e-commerce packaging must not exceed 50% empty space relative to the packaged product. This applies from 1 January 2030.

What this means in practice:

• If your shipping box is more than 50% air, you are non-compliant
• Void fill does not count as "filling" the space -- the product itself must occupy at least 50%
• You need to right-size your packaging for each product or product combination
• Multi-item orders need particular attention: throwing three small items in a large box will likely violate this rule

For Shopify sellers and PPWR e-commerce packaging requirements, this means auditing your box sizes now and planning for right-sized packaging solutions.

EU Authorized Representative: Required for Non-EU Sellers

If your business is established outside the EU, you must appoint an EU authorized representative before placing packaging on the EU market. This applies to sellers based in the US, UK (post-Brexit), China, or anywhere else outside the EU.

Your authorized representative:

• Must be established in the EU
• Acts as your compliance contact for market surveillance authorities
• Must have a written mandate from you
• Their name and contact details must be on or accessible via your packaging

Without an authorized representative, your packaging is non-compliant by definition, regardless of whether the packaging itself meets all technical requirements.

EPR Registration: Extended Producer Responsibility

Extended Producer Responsibility (EPR) for packaging is not new -- it existed under the old directive -- but the PPWR strengthens and harmonizes it. If you introduce packaging into an EU member state, you must register with that country's EPR scheme and pay fees that fund packaging collection and recycling.

For Amazon and Shopify sellers, this means:

• You must register in every EU country where your products are delivered to end consumers
• Registration is typically done through the national Producer Responsibility Organization (PRO)
• You must report packaging volumes (weight and material type) periodically
• Fees vary by material: plastic is the most expensive, paper/cardboard is cheapest

In practice, most sellers focus on Germany (largest market) first, then expand registration across key markets like France, Italy, Spain, and the Netherlands.

How Marketplaces Will Enforce PPWR

Under Article 45, online marketplaces must:

1. Verify that sellers have valid EPR registrations before allowing product listings
2. Display EPR registration numbers on product listings
3. Remove listings of sellers who fail to provide proof of compliance within a set timeframe
4. Cooperate with national authorities on enforcement

Amazon already enforces German VerpackG requirements through its Seller Central interface. If you sell on Amazon.de, you have already experienced this: Amazon requires your LUCID registration number and will suppress listings without it. Expect this model to expand EU-wide under the PPWR.

eBay, Cdiscount, and other marketplaces are building similar systems. Shopify sellers selling into the EU through their own stores face the same obligations but without marketplace-driven enforcement -- meaning you must self-police, which also means authorities may audit you directly.

Your Compliance Action Plan

Here is what you need to do, step by step:

Step 1: Inventory Your Packaging

List every packaging component you use:

• Product packaging (boxes, bags, containers)
• Protective packaging (bubble wrap, foam, tissue)
• Shipping packaging (mailers, boxes)
• Void fill (air pillows, packing paper)
• Ancillary elements (tape, labels)

For each component, record: material, weight, dimensions, supplier.

Step 2: Get a Declaration of Conformity for Each Packaging Type

Under the PPWR, every packaging unit placed on the EU market needs a Declaration of Conformity (DoC). This document declares that your packaging meets:

• Substance restrictions (heavy metals, PFAS limits)
• Recyclability requirements (applicable from 2030)
• Minimum recycled content targets (for plastic packaging, phased in from 2030)
• Labelling requirements

Step 3: Register with EPR Schemes

Start with Germany (VerpackG via LUCID), then expand:

• Germany: LUCID register + dual system contract
• France: Register with an approved PRO (CITEO, Leko, etc.)
• Italy: CONAI registration
• Spain: Register with an authorized SCRAP
• Other markets: Check each country's requirements

Step 4: Appoint an Authorized Representative (If Outside the EU)

If you are based outside the EU, engage an authorized representative. Ensure they are named on packaging or in documentation accessible via QR code.

Step 5: Plan for the 50% Empty Space Rule

Audit your packaging-to-product ratio. If any shipping configuration exceeds 50% void, plan for:

• Right-sized box options
• Adjustable packaging systems
• Review multi-item order packaging

Step 6: Implement Labelling

New harmonized labelling requirements are coming. Packaging must display:

• Material identification
• Sorting instructions for consumers
• QR code linking to further information (digital product passport provisions)

Key Deadlines for E-Commerce Sellers

Date	Requirement
11 August 2025	PPWR enters into force
12 August 2026	Declaration of Conformity requirements apply
12 August 2026	Authorized representative required for non-EU sellers
2030	50% empty space limit for e-commerce packaging
2030	Recyclability and recycled content targets begin

Do Not Wait Until Enforcement Hits

The Amazon seller community learned this lesson with the German VerpackG: when Amazon flipped the switch on enforcement, thousands of listings were suppressed overnight. Sellers who had not registered with LUCID lost days or weeks of sales while scrambling to comply.

The PPWR will follow the same pattern, but across all 27 EU member states simultaneously. Whether you are an Amazon seller, Shopify store owner, or eBay merchant, the time to act is now.

Start Your PPWR Compliance Today

Complydex helps you generate Declarations of Conformity for your packaging, covering all material types and packaging formats used in e-commerce. Get compliant before the deadlines, not after the enforcement.

Start your free PPWR assessment and get your first Declaration of Conformity in minutes.