PPWR (the EU's Packaging and Packaging Waste Regulation) applies from 12 August 2026 across all 27 EU member states, replacing the old national packaging laws with one directly-applicable set of rules. If you sell products to EU customers, no matter where you're based, this affects you.
What the PPWR regulation means in practice
Under the regulation, you are the "producer" of your packaging in every EU country you ship to, regardless of where your business is based. The obligation that matters right now is packaging Extended Producer Responsibility (EPR): registering with the national producer register in each EU country you ship to, and appointing a local authorised representative in any country where you don't have your own legal presence.
Most of what you may have seen written about PPWR — limits on empty space in packaging, recyclability rules, minimum recycled content — isn't in force yet. Those requirements phase in between 2028 and 2030.
You can read official guidance from the EU commission on their website.
Below are some answers to the questions we're hearing most.
Frequently asked questions
"Do we need to stop shipping to the EU?"
No. PPWR does not restrict the movement of goods into the EU, and there is no routine border check for packaging compliance. Parcels are not being stopped. The obligations that apply from 12 August are registration and documentation obligations, not shipping restrictions.
"Are our parcels going to be held at customs?"
No. PPWR is enforced by national market surveillance authorities, and there is no routine border screening for packaging compliance — no PPWR field in the customs declaration and no carrier clearance check for it. The EU market surveillance framework does in principle allow authorities to suspend release of non-compliant goods, but that is a targeted enforcement power rather than a systematic check, and we are not seeing parcels held.
"Who is responsible — us or Swap?"
You are. Under Article 3(1)(15) the "producer" is whoever first makes packaging available in a given EU Member State, including through distance selling. Because you remain Merchant of Record on Swap, that is you, in each Member State you ship to. Swap provides the technology and logistics; it does not place your packaging on the market.
"What do we actually have to do right now?"
Two things. First, make sure you are registered for packaging EPR in every EU Member State you ship to. Second, where you have no legal establishment in a Member State, appoint an authorised representative for EPR established in that country, who registers and reports on your behalf. Everything else in PPWR has a later date.
"Is this the same as our GPSR Responsible Person?"
No. They are separate regimes with separate appointments. Your GPSR Responsible Person does not discharge any PPWR or EPR obligation.
"Can we appoint one representative for the whole EU?"
Not as a single legal appointment. Under Article 45(3), the representative must be established in each Member State where you make packaging available for the first time and are not yourself established. Some providers offer a commercial service that appoints representatives for you across multiple countries, which is a practical way to solve it — but it is several appointments under one contract, not one EU-wide appointment.
"Isn't a compliance scheme or PRO enough?"
A producer responsibility organisation can handle fee calculation, reporting and the relationship with national authorities on your behalf. It does not take over your legal obligation to be registered as a producer in that Member State, and it is not the same thing as the authorised representative required under Article 45(3).
"We've been told our boxes are too big and we have a 40% void space limit from today."
That is incorrect on both counts. The empty-space limit is 50%, not 40%, and it applies from 1 January 2030 at the earliest — later if the Commission's calculation methodology is delayed, which is currently likely. There is no packaging sizing requirement in force today. It is also worth knowing that the rule exempts sales packaging used directly as ecommerce packaging, so if you ship in your own retail box you may be outside it altogether.
"Do we need to change our packaging or labels now?"
No. Harmonised material-composition labelling starts 12 August 2028 at the earliest, and design requirements start 1 January 2030. The only day-one packaging requirement is traceability information — a batch or serial number plus the manufacturer's name and address — and the Commission has confirmed this can be provided on an accompanying document rather than printed on the packaging.
"What about packaging we've already bought?"
Packaging produced before 12 August 2026 but not yet placed on the market does not have to be destroyed, remanufactured or relabelled. The Commission confirmed this in its August 2026 FAQ update. You are still expected to make reasonable efforts to obtain the compliance documentation for that stock.
"What happens if we're not compliant?"
Penalties are set nationally by each Member State, not by the regulation, and Member States have until 12 February 2027 to notify their rules to the Commission. The Commission has instructed authorities to be supportive rather than sanction-oriented, to issue a warning and allow a reasonable period for correction, and to use prohibition, withdrawal or recall only where non-compliance persists. The more realistic near-term risk is commercial — marketplaces have gated listings on valid EPR registration numbers for several years.
"Does Swap handle this for us?"
Not currently. Packaging EPR registration and representation sit with you as the producer. We can point you at what the requirement is; we are not able to register or act as your representative.
Swap does not provide legal or regulatory advice. This information is provided to help you scope the requirement, and you should confirm your specific obligations with your own compliance adviser or an EPR provider.