Regulatory + marketplace review17 September 2026

EU MARKETPLACE EPR · PPWR ARTICLE 45

Marketplace approval is not the starting point. Producer status and the destination country are.

Amazon, Etsy, eBay, Kaufland and Allegro increasingly collect packaging EPR evidence. But the platform does not create one EU-wide registration. First determine who is the Producer in each destination Member State, then establish the national EPR position, then provide the evidence the marketplace asks for.

Direct answer

If you sell packaged goods to EU consumers through a marketplace, do not begin with the marketplace form. Begin with Producer status and the consumer's Member State. A marketplace can verify, restrict or operationalise evidence; it does not by itself replace registration, reporting, financing or other national EPR duties.

Country-firstEvidence-readyEU27 logicNon-EU seller aware

Six marketplace operating tracks

One legal baseline. Six different evidence workflows.

The parent hub is live first. Dedicated platform guides will be published as full, source-backed pages rather than thin placeholders. Until then, use the platform-specific operating notes below together with the country layer.

ACCOUNT HEALTH + EPRLive guide

Amazon

Amazon operates country and category-specific EPR compliance controls. Seller Central can request registration evidence and, in some markets, offers platform programmes that handle selected payments on a seller's behalf. Those programmes must not be confused with a universal transfer of Producer obligations.

Operational focus: identify the destination-country requirement first, then submit the correct registration evidence through Amazon's current compliance workflow.

Dedicated guide route/marketplaces/amazon →

SHOP MANAGER + EPRDedicated guide next

Etsy

Etsy publishes country-specific EPR guidance and directs qualifying sellers to provide registration information in Shop Manager. Public guidance currently includes packaging workflows for markets such as Germany, France and Spain.

Operational focus: map the shop's EU destinations, determine Producer status, complete national registrations and keep Shop Manager evidence aligned with the underlying records.

Dedicated guide route/marketplaces/etsy

BUSINESS INFO + EPRDedicated guide next

eBay

eBay's 2026 PPWR guidance tells packaging Producers to arrange registration in each relevant EU country, add packaging registration numbers to the account and self-certify applicable packaging compliance.

Operational focus: country-by-country registration number management plus accurate self-certification; missing numbers may affect listing visibility in relevant countries.

Dedicated guide route/marketplaces/ebay

SELLER PORTAL + COUNTRY FIELDSDedicated guide next

Kaufland

Kaufland Global Marketplace distinguishes national EPR requirements rather than treating the EU as one registration area. Its seller guidance uses country-specific packaging registration evidence and seller certification.

Operational focus: maintain a country evidence matrix and submit the identifier required for each marketplace country in the applicable Seller Portal workflow.

Dedicated guide route/marketplaces/kaufland

LEGAL OBLIGATIONS + EPR PPWRDedicated guide next

Allegro

Allegro has added EPR PPWR controls to its Legal obligations area. It asks qualifying sellers for a separate EPR number by country and for a packaging conformity declaration within its platform workflow.

Operational focus: do not treat Allegro's platform declaration as a substitute for the separate legal documentation that may apply under PPWR or national law.

Dedicated guide route/marketplaces/allegro

ARTICLE 45 FALLBACKDedicated guide next

Other marketplaces

A platform does not become irrelevant merely because it has no polished EPR form. Where PPWR Article 45 and the linked DSA scope apply, the legal information layer exists independently of a marketplace's interface maturity.

Operational focus: document destination-country obligations, contact the platform where necessary, preserve correspondence and avoid treating a missing field as an exemption.

Dedicated guide route/marketplaces/other-marketplaces

The core distinction

The country creates the EPR position. The marketplace consumes evidence of it.

Country compliance layer

This is the legal and operational layer behind the marketplace account. It is assessed by Member State and by the specific packaging stream and business facts.

Producer status
Producer register / identifier
PRO or individual-system participation where applicable
Authorised-representation position
Reporting and quantity records
Financial contributions and payment evidence
National deadlines, declarations and retention

Marketplace verification layer

This is the platform-facing evidence layer. It should mirror the underlying country truth, not become a parallel invented version of compliance.

Registration number submission
Country and category mapping
Self-certification or platform declaration
Validation / rejection status
Listing or destination restrictions
Evidence screenshots and support correspondence
Re-submission after number or entity changes

PPWR Article 45

What does PPWR actually require from online platforms?

For online-platform providers within the relevant Digital Services Act scope that allow consumers to conclude distance contracts with Producers, Article 45 creates a marketplace verification layer tied to the Member State where the consumer is located.

Registration information

Before allowing covered Producers to use the service, the platform must obtain information on Producer registration in the Member State where the consumer is located, including the relevant registration number or numbers.

Producer self-certification

The platform must obtain a self-certification that the Producer only offers packaging for which the applicable EPR requirements in Article 45(1)–(3) are complied with in that Member State.

Best-efforts assessment

After receiving the information and before enabling the Producer to use the service, the platform must make best efforts to assess whether the information is complete and reliable.

Possible mandated financing role

Where a Producer sells through an online marketplace, Article 45 allows the platform, on the basis of a written mandate, to fulfil the financial obligations in Article 45(2) on the Producer's behalf. That is an optional mandated arrangement, not an automatic rule for every seller.

Do I need one EPR number for the whole EU?

No. PPWR harmonises important rules, but Producer registration and EPR operation remain tied to Member States. The number you submit to a marketplace must correspond to the relevant country, packaging stream and legal entity.

Germany may require a LUCID packaging registration relationship.
France uses national EPR identifiers and sector arrangements.
Spain uses its national Producer register and packaging EPR system.
Poland uses BDO for relevant obligations.
Other Member States use their own registries, schemes, identifiers or transitional arrangements.

Before any portal field

Who is the Producer for this sale?

Do not equate Producer with manufacturer. Under PPWR, Producer status is a defined legal role and can shift with establishment, first making-available activity and cross-border distance sales. Test the actual route to the end user.

Where is the selling entity established?

Which Member State is the consumer in?

Who first makes the packaging or packaged product available in that Member State?

Is the sale a direct distance sale across borders?

Is an upstream supplier already the registered Producer for the same packaging in that country?

Does a national rule, mandate or current PPWR provision require an EPR authorised representative?

Operating sequence

Use the same eight controls for every marketplace.

Platform interfaces change. The control sequence should not.

01
Map destinations
List every EU Member State to which the marketplace can deliver your packaged products.
02
Determine Producer status
Assess the selling entity and transaction route for each destination country rather than assuming one status across the EU.
03
Resolve representation
Check the current EPR authorised-representation rule and any Member-State requirement before registration.
04
Register correctly
Obtain the country-specific Producer registration and any required PRO or system participation.
05
Bind packaging data
Keep SKU, material, weight, category and placed-on-market data capable of supporting reporting and marketplace evidence.
06
Submit marketplace evidence
Enter the correct country/category identifier and make only certifications you can support.
07
Monitor validation
Track accepted, rejected, pending and restricted states; preserve platform messages and remediate mismatches.
08
Operate after approval
Continue reporting, fee payment, evidence retention and change control. Platform approval is not the end of EPR compliance.

Marketplace Evidence Pack

Build the evidence before the platform asks for it.

A defensible evidence pack connects the marketplace submission back to the legal and operational records that generated it.

Registration record

Official registry extract or confirmation, legal entity name, identifier, category and effective status.

PRO / system evidence

Participation agreement, membership evidence or individual-system documentation where applicable.

Representation evidence

Written mandate and representative identifiers where an EPR authorised representative is legally required or used.

Packaging data

SKU-level packaging composition, weight and classification records that reconcile to declarations.

Marketplace submission

Submitted values, date, country/category mapping, validation result, screenshots and support case history.

Ongoing proof

Reports, invoices, payments, corrections, renewals and change history showing that the registration is not merely a static number.

Dangerous assumptions

Five shortcuts that create avoidable exposure.

“Amazon approved my number, so I am EPR compliant.”

Approval shows a platform control passed. It does not prove that every registration, report, fee, representation or packaging-data obligation is satisfied.

“I need one PPWR number for Europe.”

Registration remains country-specific. A marketplace may centralise its interface, but the underlying identifiers are not one EU-wide number.

“The marketplace will pay EPR for me.”

Some platforms or markets offer specific pay-on-behalf or mandated arrangements. Never generalise them across countries, product streams or all legal obligations.

“No EPR field means no obligation.”

A missing platform field may simply mean the interface or national register is not yet integrated. The legal assessment exists separately.

“The packaging conformity checkbox is the PPWR EU Declaration of Conformity.”

A marketplace checkbox or Article 45 self-certification must not automatically be treated as the manufacturer's separate conformity documentation under PPWR.

Legislative watch · authorised representation

Do not build a 2026 marketplace workflow on an assumed future amendment.

The current PPWR text contains Article 45(3) rules on EPR authorised representation for specified cross-border Producers and permits Member States to require an EPR authorised representative for third-country Producers in stated circumstances.

The Commission proposed COM(2025) 982 to suspend the application of Article 45(3) until 1 January 2035. As of this page's 17 September 2026 review, EUR-Lex lists procedure 2025/0395(COD) as ongoing. Treat the proposal as a legislative watch item, not as law already in force, and verify the applicable national position before acting.

2025/0395(COD) · EUR-Lex ↗

Move from platform question to country answer

Use the country layer before you submit marketplace evidence.

These existing Beyoğlu Professional resources help define the legal scope behind the platform field.

EU Country GuidesOpen the destination-country operating page for registration, system, reporting and representation context.Producer Status CheckerTest whether your selling entity is likely to be the packaging Producer for the route in question.EU Country Obligation CheckerMap countries before entering registration numbers into marketplace portals.EPR AR CheckerAssess the authorised-representation layer without assuming that every country follows one rule.Marketplace EPR ChecklistPut operational evidence tasks in a controlled sequence for marketplace sales.Free AssessmentStart with establishment, sales model and destination countries to define the compliance scope.

Answer engine FAQ

Questions sellers ask before a marketplace restriction appears.

Do I need EPR to sell on Amazon in Europe?

Potentially, yes, if you are the packaging Producer in a Member State where you sell. The legal assessment is country-specific. Amazon's compliance workflow is evidence collection; it does not create the underlying obligation.

Does Etsy, eBay or Amazon approval mean I am fully compliant?

No. Platform acceptance only confirms a platform control. National registration, PRO participation, reporting, financial contributions, authorised representation and recordkeeping may still apply.

Is there one packaging EPR registration number for the EU?

No. PPWR is an EU Regulation, but Producer registration and EPR operation remain Member-State based. Marketplaces therefore collect country-specific identifiers.

Who is the Producer when I sell through a marketplace?

Producer status is determined by the PPWR definition and the facts of the transaction, including establishment, first making available and destination Member State. It is not automatically the brand owner, manufacturer or marketplace.

Does a marketplace pay EPR fees for the seller?

Not automatically. Some platform programmes or written mandates can cover defined payment functions in defined markets, but their scope must be checked. Other Producer obligations may remain with the seller.

What does PPWR Article 45 require from covered online marketplaces?

For platforms in the relevant DSA scope, Article 45 links marketplace onboarding to Producer registration information, registration numbers and Producer self-certification for the Member State where the consumer is located, with a best-efforts completeness and reliability assessment.

Do non-EU sellers always need an EPR Authorised Representative in every EU country?

Do not use that blanket rule. The current PPWR text, Member-State rules and the seller's exact Producer category must be checked. A Commission proposal would suspend part of Article 45(3), but the legislative procedure remained ongoing at this page's review date.

What if the marketplace has no EPR field for my country?

Do not treat a missing field as an exemption. Determine the national obligation, preserve the evidence, contact the platform if necessary and control sales destinations while the platform or national register catches up.

Are FBA and FBM treated differently for Producer status?

Fulfilment method can change operational facts, but it does not by itself decide Producer status. Assess who first makes the packaging available in the destination Member State and the applicable national framework.

Should I upload a supplier's EPR number?

Only when the legal and platform rules support that upstream relationship for the exact country and packaging. Do not reuse a supplier number merely because a portal accepts a string.

Source discipline

Primary law first. Platform documentation second.

Marketplace interfaces evolve quickly. This page separates the binding legal baseline from platform implementation and dates its review so changes can be audited.

Regulation (EU) 2025/40 · PPWRBinding EU legal text, including Article 45.European Commission PPWR Guidance · June 2026Commission guidance supporting interpretation and implementation.EUR-Lex procedure 2025/0395(COD)Legislative status of the proposed Article 45(3) suspension.Amazon Seller Central · EPR / PPWR seller updateCurrent Amazon seller-facing packaging EPR implementation signal.Etsy Help · EPR in GermanyCountry-specific Etsy registration and Shop Manager workflow.eBay Seller Center · EU PPWR2026 packaging EPR registration, self-certification and listing controls.Kaufland Global Marketplace · PPWRCountry-specific seller portal evidence and certification model.Allegro Help · PPWREPR PPWR numbers and packaging declaration workflow.

Need a clean marketplace evidence route?

Start with the countries you sell into, not the portal that sent the warning.

We can map Producer status, national registration, representation, reporting and marketplace evidence into one country-by-country operating file.

Start free assessment Explore EU country guides

Regulatory information, not individual legal advice. Marketplace interfaces, national registers and legislative status can change; verify the current country-specific position before filing or certifying.