I sell on Amazon or other marketplaces – does the PPWR apply to me?

Yes – the PPWR (Regulation (EU) 2025/40) applies from 12 August 2026 to marketplace sellers as well, though the specific obligations depend on your concrete role in the supply chain.

Own packaging = full placing-on-market obligation If you ship your products in your own packaging (cardboard box, cushioning material, mailing bag), you are legally the entity placing those packaging units on the market. This means: labelling obligations (including a machine-readable QR code pursuant to Article 11), proof of recycled content, minimisation requirements, and registration in the national register.

Fulfilment by Amazon (FBA) or other service providers If you use fulfilment services where the provider uses its own dispatch packaging, Amazon or the fulfilment provider is responsible for labelling those packaging units – not you. You remain responsible, however, for the packaging in which you deliver your goods to the fulfilment warehouse (inbound packaging).

Product packaging remains your responsibility Regardless of the shipping route: the primary product packaging (outer packaging, sales packaging) always remains your responsibility, provided you act as manufacturer, importer, or first seller in the EU.

Practical implication Assess each packaging level separately: who first places it on the market in the EU? That party bears the PPWR obligations for that specific packaging.

For a binding assessment of your specific business model, please contact your relevant Chamber of Commerce and Industry (IHK).