Most coverage of this treats “the EU” as one place. It is not, and that is the whole difficulty. There is an EU-wide rule arriving on 12 August 2026, and underneath it there are national schemes — two of which have been enforcing a marketplace check since 2022. If you sell into Germany today and have never heard of LUCID, the 2026 date is not your problem. Your problem is four years old.
So rather than a timeline, what follows is a ledger: what each layer requires, who issues the number, and what actually happens when you do not have one. At the end there is a separate section for the things that are genuinely unresolved, which we have kept out of the main text so they cannot be mistaken for settled law.
First: does the law think you are a “producer”?
Everything downstream depends on this word, and it does not mean what it sounds like. You do not have to manufacture anything. Under Regulation (EU) 2025/40 a producer includes any manufacturer, importer or distributor who
“… is established in a Member State or in a third country and makes available for the first time on the territory of another Member State, directly to end users, products packaged in packaging …”
Regulation (EU) 2025/40, Article 3(1), point (15)(d)Read that against what you actually do. You are in the UK, or the US, or Poland. A customer in Spain buys a candle. You put it in a box with tissue paper and post it. You have made a packaged product available in Spain, directly to an end user, for the first time. You are the producer in Spain — of the box, the tissue, the tape and the mailer, regardless of who made the candle.
The packaging is the regulated thing here, not the product. That is the mental switch most sellers have to make, and it is why “I only sell digital-adjacent handmade items” is not an answer: if it ships in something, the something is in scope.
The ledger
Three layers apply to the same parcel. The EU layer is new; the two national layers below it are already live and already being enforced by the marketplaces you sell on.
| EU-wide (PPWR + DSA) | Germany | France | |
|---|---|---|---|
| Live from | 12 August 2026 | 1 July 2022 | 1 January 2022 |
| Register | A national register in each member state, under Article 44 | LUCID, run by the Zentrale Stelle Verpackungsregister | SYDEREP; the number is the identifiant unique (IDU), issued by ADEME |
| What the marketplace must do | Obtain your registration number for the buyer's member state plus a self-certification, before letting you use the service | Must not enable packaging to be offered for sale by a producer who is not properly registered | Becomes liable for your EPR obligations itself unless it holds evidence you have complied |
| Threshold for small sellers | None for registration. Under 10 tonnes a year reduces what you report, not whether you register | None. ZSVR states explicitly there is no exemption for small volumes if you act commercially | No registration exemption found; a flat-fee option for small quantities is a fee reduction, not an exemption |
| Can someone register for you? | Member states may allow an authorised representative to do it (Article 44(3)) | No. A German representative can take on your other duties but expressly not registration | Unclear — the article that created the French representative was annulled in 2023 (see below) |
| If you are not registered | Platform must ask you to fix it, then suspend your offering to EU consumers if you do not | Offering is prohibited; fines run to €100,000 | The marketplace pays your eco-contribution — which is why it will delist you first |
| Legal source | Reg. (EU) 2025/40 Arts. 44–45; Reg. (EU) 2022/2065 Art. 30 | VerpackG §§ 7(7), 9(5), 35(2) | Code de l'environnement, Arts. L541-10-9 and L541-10-13 |
The France row is worth pausing on, because it explains marketplace behaviour that otherwise looks like overreach. French law does not tell the platform to check you. It tells the platform that it is on the hook for your packaging obligations — unless it can show you already met them, and holding your IDU is deemed to be that showing. A marketplace enforcing French EPR aggressively is not being officious. It is declining to pay your eco-contribution.
What the EU rule actually says
The operative sentence is short, and it is worth having in front of you rather than paraphrased.
“… providers of online platforms … that allow consumers to conclude distance contracts with producers shall obtain the following information from producers that offer packaging or packaged products to consumers located in the Union prior to allowing those producers to use their services:
(a) information on the registration of the producers referred to in Article 44 of this Regulation in the Member State where the consumer is located and the registration number(s) of the producer in that register;
(b) a self-certification by the producer confirming that it only offers packaging with regard to which the extended producer responsibility requirements … are complied with in the Member State where the consumer is located.”
Regulation (EU) 2025/40, Article 45(4)Three things follow from the wording. “In the Member State where the consumer is located” is the expensive phrase: there is no single EU number. Article 44(2) requires you to register in each member state where you first make packaging available. Sell into six countries and you have six registrations to hold, not one.
“Prior to allowing those producers to use their services” makes this a gate rather than an audit. And Article 45(6) requires the platform to “make best efforts to assess whether the information received is complete and reliable” — with Article 44(13) obliging member states to publish their registered-producer lists in a machine-readable, searchable form. The design intent is automated lookup. A plausible-looking number you typed in yourself is not going to survive it.
What happens next is not in the packaging regulation at all. Article 45(4) is written “for the purposes of compliance with Article 30(1), points (d) and (e)” of the Digital Services Act, and the DSA supplies the consequence:
“Where the trader fails to correct or complete that information, the provider of the online platform … shall swiftly suspend the provision of its service to that trader in relation to the offering of products or services to consumers located in the Union until the request has been fully complied with.”
Regulation (EU) 2022/2065 (Digital Services Act), Article 30(3)Note what is suspended: your ability to offer to consumers in the Union. Not, on the face of the text, your whole account. And Article 30(4) preserves your right to complain through the platform's internal complaint-handling and out-of-court dispute mechanisms. Whether any given marketplace draws the line that finely in practice is another matter, but the legal instrument is a targeted suspension, not deletion.
Two things that look like exemptions and are not
The 10-tonne figure. Article 44(8) gives producers who make available under 10 tonnes of packaging in a calendar year a lighter reporting dataset. It is written as a reporting simplification and nothing in Articles 44(2) or 44(4) carries a quantity qualifier. If you have seen “under 10 tonnes, you are exempt”, it is a misreading of this paragraph. You still register; you just file less.
The micro and small platform carve-out. Article 45(4) only binds platforms that fall within Section 4 of Chapter III of the DSA, and DSA Article 29 excludes providers that qualify as micro or small enterprises from that section unless they have been designated a very large online platform. So the obligation lands squarely on the big marketplaces and not on a two-person niche platform. This is a carve-out for the platform, though — not for you. Your own duty to register under Article 44(2), and the prohibition in Article 44(4) on making packaging available while unregistered, are unaffected by where you list. Selling through a small platform, or your own Shopify store, removes the gatekeeper, not the obligation.
Article 44(11)(b) gives the competent authority up to twelve weeks to grant a registration and issue a number, counted from the point at which you have supplied everything required. Twelve weeks from a late start in June is not 12 August. If you sell into the EU and hold no registration, the lead time — not the deadline — is the binding constraint.
Unsettled as of 26 July 2026
These four items are live and unresolved. We have separated them out deliberately: none of them is something to plan around, and two of them are being reported elsewhere as though they were already decided.
The authorised-representative requirement may be suspended until 2035
Article 45(3) requires cross-border producers to appoint an authorised representative for EPR in each member state where they first make packaging available, other than the one they are established in. On 10 December 2025 the Commission proposed, as part of the Environmental Omnibus, to suspend that article until 1 January 2035. As of 26 July 2026 the file (2025/0395(COD)) is still with the European Parliament — amendments were tabled on 1 July 2026 and a first-reading plenary is indicatively forecast for October 2026. It is not law. Article 45(3) applies from 12 August 2026 unless and until that changes.
When the new national registers actually exist
There is a gap in the drafting that nobody has cleanly resolved. Article 44(14) required the Commission to adopt an implementing act setting the registration format by 12 February 2026, and Article 44(1) then gives member states eighteen months from that act to establish the national register. On that arithmetic the Article 44 registers need not exist on 12 August 2026, even though the marketplace duty in Article 45(4) refers to them. We could not confirm whether the implementing act has been adopted. The practical reading is that the operative registers remain the existing national ones — LUCID, SYDEREP and their equivalents — but treat the transition mechanics as unconfirmed.
What happens to your existing LUCID registration
Germany is replacing the VerpackG with a Verpackungsrecht-Durchführungsgesetz to implement the PPWR. The ZSVR states that this is currently in the legislative process. It says nothing about the status of existing LUCID registrations after 12 August 2026. Do not assume they lapse; equally, do not assume they carry across untouched.
France has no working representative mechanism
The French article that let a foreign producer appoint a mandataire for EPR, Article R541-174, was annulled by the Conseil d'État on 10 November 2023, and we found no replacement article in force. If you are outside France, this points towards registering with ADEME in your own name rather than relying on an intermediary — but the position is genuinely unsettled and worth a direct question to whoever you use.
What to do with the next fortnight
The useful ordering is not alphabetical by country. It is by exposure.
- Pull your last twelve months of EU orders and sort by destination country. Most small sellers find that three or four member states carry almost everything. Register there first. A country you shipped two orders to in March is a smaller problem than a twelve-week queue.
- Check Germany and France before anything else — not because they are largest, but because their marketplace checks have been enforceable since 2022. If you are exposed there, you are exposed now, not in August.
- Start the registration, then price it. Registration itself is typically free or cost-based, but the recurring eco-contribution is a real per-order cost that most sellers have never had in their margin. Fold it in the same place you handle import VAT and duty — our EU import VAT and duty estimator will show you what headroom a given destination actually leaves once the tax side is accounted for.
- Put the number where the marketplace expects it. Each platform has its own compliance section for EPR numbers, per country and per product category. A number you hold but have not entered will not save your listing from an automated check.
One last thing worth saying plainly: this is the second EU compliance regime in as many years to work by making the marketplace responsible for policing you. The general product safety rules did the same thing, which is why listings started needing a named EU responsible person — covered in our guide to what has to go on a GPSR label, and buildable with the GPSR label builder. On the cost side the direction is identical: the EU also removed its €150 duty exemption this month, which we cover in the €3 parcel duty explained. Treating these as three separate emergencies is how they become three separate emergencies. They are one shift, arriving in instalments.
Facts verified 2026-07-26 against the sources below. This is a summary for sellers, not legal advice.
Primary sources: Regulation (EU) 2025/40 on packaging and packaging waste — full text via EUR-Lex (Articles 3(1)(15), 44, 45, 71); Regulation (EU) 2022/2065 (Digital Services Act), Articles 29 and 30; European Commission, packaging waste policy page (entry into force 11 February 2025, application from 12 August 2026); Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40, OJ C, 10 June 2026; Commission proposal COM(2025) 982 final and procedure file 2025/0395(COD); Germany — VerpackG § 7 and § 9, and the Zentrale Stelle Verpackungsregister on obligations for online retailers; France — Code de l'environnement Article L541-10-9 and the Ministry's marketplace FAQ. Where a point could not be confirmed on a primary source it is flagged as unconfirmed in the text above rather than stated.