PPWR 2026 Update for Amazon Sellers: Do You Need EPR Registration in Every EU Country?

Don't rush into EPR registrations across Europe. Check what you actually need before spending money.

The EU's Packaging and Packaging Waste Regulation (PPWR) introduces new rules for packaging recycling and reporting. For online sellers, this could mean registrations, reporting, and recycling contributions in multiple EU countries.

Which countries should Amazon sellers prioritize?

Germany and France. Both have established packaging EPR requirements. Especially Germany was very quick to implement PPWR’s requirement to have a local representative.

Should I register if Amazon hasn't asked me to?

Don't spend money unnecessarily. Check Amazon Seller Central for compliance requests. For other countries, we recommend to hold off until requested. National EPR obligations can apply even without an Amazon notification, but most national governments as of this writing (Oct 27, 2026) either haven’t implemented the technical solutions to enable registrations on scale or they haven’t enforced the requirements (e.g. local representative) or both.

Since the EU Parliament and the Commission are moving to amend the law to scrap the local representative requirement, and the change is likely to pass given broad political consensus, enforcement of PPWR in its current form is likely to remain lax until legislative activity settles and an updated law is in place.

Is the EU simplifying PPWR requirements?

Yes. In October 2026, the European Parliament advanced proposals to reduce administrative burdens on smaller businesses, including removing the requirement for appointing local representatives.

However, this is not yet the law. These developments do not suspend existing national EPR obligations.

Should I pay for EPR registration services now?

Only when you've confirmed they're necessary. Registration services can cost hundreds of euros per country, with additional recurring reporting and recycling fees.

Amazon also offers EPR Pay on Behalf services in certain countries and categories, which may reduce administrative work. We recommend deferring to Amazon for the time being.

What does Minefield Navigator recommend?

Keep Germany and France compliant. Get registered there now. For other countries, verify your obligations before spending money.

We believe Europe needs a single, standardized EPR registration and reporting workflow rather than dozens of fragmented national systems. And we are following the legislative process very closely.

We'll continue monitoring PPWR developments and Amazon's requirements to help sellers avoid unnecessary compliance costs.

Any questions or concerns? Create a free account and get in touch with our support.