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PPWR August 12, 2026: What Every Amazon Seller Must Do

DutyScope TeamJune 28, 20268 min read

What is PPWR and Why Now?

The Packaging and Packaging Waste Regulation (Regulation EU 2025/40) — commonly called PPWR — was adopted in 2025 and becomes enforceable on August 12, 2026. Unlike a Directive, which member states transpose at different speeds, a Regulation applies directly and uniformly across all 27 EU member states. There is no grace period for transposition.

If you sell physical products in the EU — whether through Amazon, eBay, your own Shopify store, or any other channel — PPWR affects you.


Who Is Affected?

PPWR applies to any economic operator placing packaged products on the EU market. This includes:

  • Manufacturers (EU and non-EU)
  • Importers bringing packaged goods into the EU
  • Distributors and fulfilment service providers
  • Online marketplaces — and by extension, their third-party sellers

If you're an Amazon FBA seller shipping inventory to a German or French warehouse, you are subject to PPWR. Amazon has already begun verifying packaging compliance data from sellers in select categories.


Key Deadlines You Cannot Miss

|----------|-------------|

August 12, 2026PPWR full enforcement begins. Declaration of Conformity becomes mandatory for all packaging placed on the EU market.
January 1, 2030All packaging must achieve recyclability grade A, B, or C. Grades D and E are banned from the market.
January 1, 2038Recyclability requirements tighten: only grades A and B are permitted.
2030 / 2040Mandatory recycled content targets kick in for plastic packaging (see below).

The August 12, 2026 date is the immediate priority. After this date, non-compliant packaging cannot be placed on the EU market.


Recyclability Grades Explained (A–E)

PPWR introduces a five-tier recyclability grading system:

  • Grade A — ≥95% of the packaging unit (by weight) is recyclable at scale
  • Grade B — ≥90% recyclable at scale
  • Grade C — ≥80% recyclable at scale
  • Grade D — ≥70% recyclable at scale (banned from 2030)
  • Grade E — <70% recyclable at scale (banned from 2030)

*From 2038**: Only grades A and B will be allowed. Every percentage point matters. Multi-material laminates, dark-coloured plastics (undetectable by NIR sorters), and PVC packaging are all at risk of falling below the thresholds.


Declaration of Conformity

Starting August 12, 2026, every packaged product on the EU market requires a Declaration of Conformity that covers the packaging. This is separate from any CE marking or product-safety declaration — it's a packaging-specific document.

The Declaration must confirm:

  • Recyclability grade of each packaging component
  • Recycled content percentages (where applicable)
  • Compliance with substance restrictions (PFAS, heavy metals)
  • Empty-space ratio compliance

Marketplaces will require this documentation. Without it, your listings may be blocked or de-listed.


Recycled Content Targets

For plastic packaging:

|------|--------------------------|

203010–35% (varies by packaging type and polymer)

Contact-sensitive packaging has lower initial targets but must still comply. This creates supply-chain pressure because demand for food-grade recycled plastics will outstrip supply.


PFAS Restrictions (August 2026)

From August 2026, PFAS (per- and polyfluoroalkyl substances) in food-contact packaging are restricted above defined thresholds. PFAS are commonly used in greaseproof paper, pizza boxes, microwave-popcorn bags, and moulded-fibre takeaway containers.

If your product uses any of these packaging formats, verify with your packaging supplier that PFAS levels are below the thresholds. Non-compliance = product withdrawal.


Empty-Space Ratio Cap

PPWR caps the empty-space ratio at 40% for grouped, transport, and e-commerce packaging. This affects:

  • Subscription boxes with excessive filler material
  • Amazon-standard oversized boxes for small items
  • Gift sets and multi-pack configurations

If the empty-space ratio exceeds 40%, the packaging does not comply, triggering the same market-access restrictions as a failed recyclability grade.


Marketplace Verification: What to Expect

Amazon, eBay, and other marketplaces are required to verify seller compliance. In practice, expect:

1. Documentation requests via Seller Central / account health dashboards 2. Packaging declarations as a new compliance field in product listings 3. Potential listing suppression for non-compliant ASINs 4. Integration with national EPR registers (LUCID, ADEME, etc.)

Early preparation is your best defence. Collect your packaging specs, recyclability grades, and supplier declarations now — not the week before enforcement.


Action Checklist for Sellers

  • Audit all your packaging materials by SKU
  • Request recyclability assessments from your packaging suppliers
  • Verify PFAS levels for food-contact packaging
  • Measure empty-space ratios for your e-commerce packaging
  • Prepare your Declaration of Conformity template
  • Monitor Amazon Seller Central for compliance fields
  • Check your national EPR registrations are current (LUCID, ADEME, CONAI, etc.)

This article provides general information and does not constitute legal advice. PPWR requirements are complex and fact-specific. Consult your compliance counsel.

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