Question about the new PPWR packaging law | Seller Lounge | eBay.de Community

Skip to main content

Question about the new PPWR packaging law | Seller Lounge | eBay.de Community

Trade & Discuss Commercially

Question about the new PPWR packaging law

Summary: A discussion regarding the PPWR packaging law highlights the responsibilities of those placing packaging on the market, emphasizing the need for licensing and compliance with sustainability requirements. victor-vinyl outlines the obligation to license even if the carton manufacturer has already done so, and discusses the conditions under which packaging can be considered 'placed on the market.' mounibonboni clarifies misconceptions about the conformity declaration, mentioning a personal experience with a compliance resource, useful for others dealing with similar regulatory obligations.

Hello everyone
Since the new PPWR law comes into force on 12.08.26, which applies to all traders. And then you need a conformity declaration for your packaging materials.
I wanted to ask how you implement all of this?
As I have found that many B2B traders/suppliers, when asked, either don't know what is meant or you are told/read that the conformity declaration would only be necessary if the packaging materials come into contact with food.
Although the law states that this applies to all traders/suppliers who sell their products, with the appropriate packaging, to end consumers.

Best regards

strass4me

420 View listings

Posted 5 months ago·Last reply 1 month ago

18 comments

mounibonboni

·1 month ago

Good point, and this is a common mix-up. The PPWR conformity declaration isn't limited to food-contact packaging — that's leftover confusion from older rules. Any packaging reaching end consumers falls under scope, and whoever places it on the market needs to be able to demonstrate conformity, in writing (verbal assurances from suppliers won't hold up if liability comes into question).

I went through this myself and used packrep-germany.com to sort it out — worked well for me, might be useful for others here too.

victor-vinyl

·2 months ago

Hello everyone,

as I understand it, the following applies:

Anyone who packages the goods and puts them into circulation is also the manufacturer and must license this.

Regardless of whether the "carton manufacturer" has already licensed it. However, the manufacturer’s details can be taken over in the declaration of conformity.

Packaging should only be placed on the market if it complies with the sustainability and labeling requirements laid down in or pursuant to this Regulation. Packaging should be deemed to be placed on the market when it is first made available on the Union market, which means that it is supplied by the manufacturer or importer in the course of a commercial activity, whether for payment or free of charge, for distribution, consumption or use. Therefore, packaging that was already placed on the market in the Union before the date of application of the relevant requirements and is in the stock of distributors, including retailers and wholesalers, should not have to comply with the sustainability and labeling requirements laid down in or pursuant to this Regulation.

Packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC

Kind regards

cosmoretroshop

·4 months ago

I understood the whole thing as a big mess that no one understands, no one wants, and that apparently everyone is trying to stop from all sides.

The first step is the suspension of the authorized representative until 2035, which will presumably come. If every online retailer in every EU country had to pay authorized representatives/fees, there would be a “flat rate” of 10 to 15k per year just so you can sell within the EU at all.

It also seems the whole thing is so unclear that not even bodies (such as the EU or trade associations) can give any information on this nonsense, and that 2 months before “implementation”.

As it is being presented at the moment: license, report, pay, but somehow everything is “can” and nothing is “must”, it seems to me like a rip-off to generate a few more revenues again.

miriam@ebay

eBay Team

Admin4 months ago

Community TeamView listings

Hello @strass4me and everyone! Since the PPWR (= Packaging and Packaging Waste Regulation) is a statutory regulation, unfortunately we cannot provide legal advice or make a binding assessment of the individual obligations that arise from it for individual companies.

As soon as new legal requirements have concrete effects on sales on eBay or certain information needs to be stored at eBay, we will inform you via the appropriate channels. In addition, eBay will send out a communication in June to inform you about the regulation and relevant developments.

Until then, we recommend keeping an eye on developments around the PPWR as well as the information from the relevant authorities and industry associations.

Kind regards

Miriam

cosmoretroshop

·5 months ago

Used cardboard boxes are explicitly excluded here, because you can never prove that they are licensed.

This is not about environmental protection or anything like that. The EU has a parliament that has been infiltrated by lobbyists, and they feed these great ideas to the parliamentarians.

This is about making the rich even richer.

strass4me

OP5 months ago

The only issue is that with used or reused cardboard packaging and, if applicable, filling material, you still have to prove that they were already licensed with a dual system beforehand, so that you don't have to license them twice.
What also comes on top of that, from the specified point in time, is that all the shipping materials you need should then comply with the PPWR regulations, i.e. be PPWR-compliant.

mmstore74

·5 months ago

Hello everyone,

@gebraucht-ist-gut wrote:

The manufacturer of the packaging must provide a declaration of conformity.

As a seller, you may only need to prove that your boxes have already been licensed (if you are not yourself responsible for that).

Since everyone is always talking about sustainability to save the world, what about used cardboard boxes?

We use only used cardboard boxes, and how are we supposed to be able to prove anything there?

Kind regards

cosmoretroshop

·5 months ago

Since right now no one really seems to be stirring, and somehow no one knows how the whole thing should be handled anyway, I’m getting the feeling that this is all a lot of hot air and nothing else.

itec-systems

·5 months ago

It’s similar to the GPSR law. Somehow nobody has been interested in that up to today either....

gebraucht-ist-gut

·5 months ago

What I find much more concerning, though, is that most commercial sellers will then exclude sales to other EU countries (or have to).

From the cutoff date on, a sale to Asia will basically be easier (and cheaper) than one within the EU.

Isn't there some kind of changes or support somewhere still, or is this basically the END of trade within the EU for many sellers.

strass4me

OP5 months ago

Yes, that's true. That's really problematic for sellers who sell in the EU. Because, as I read, they would then need an EPR authorized representative for each country.

gebraucht-ist-gut

·4 months ago

@strass4me wrote:
Yes, that's true. That really is problematic for sellers who sell in the EU. Because, as I read, they would then need an EPR representative for each country.

You can book it quite easily - a bargain ... and that per country.

For me, shipping to the EU is then basically done with.

Screenshot 2026-06-03 130351.png

strass4me

OP4 months ago

Hello
@gebraucht-ist-gut

" Bargain doesn't even begin to describe it "

But now it may have been suggested that there could possibly be a legislative draft. Exactly where this law with the EPR authorized representative is to be suspended until 2035. But that's not finalized yet.
Hope that it gets passed quickly for the dealers who sell into the EU, so they can keep selling into the EU.

gebraucht-ist-gut

·5 months ago

Hello @strass4me ,

Somehow you seem to be mixing things up here, I’d say.

The manufacturer of the packaging must provide a declaration of conformity.

As a seller, you may only need to prove that your boxes have already been licensed (if you are not responsible for that yourself).

Those are two different things.

strass4me

OP5 months ago

Hello @gebraucht-ist-gut

Thanks for the reply.

As I read it, the dealer where I buy my boxes, for example, issues me a declaration of conformity. Then I have to store it in my eBay account, in addition to the Lucid number. Since I am required to provide evidence and documentation, I have to prove that the product and shipping materials are PPWR-compliant.

sammlerkiste-1-2-3

·4 months ago

@strass4me wrote:
Hello @gebraucht-ist-gut

Thanks for the answer.
As I read it, the dealer where I buy my boxes, for example, issues me a declaration of conformity. I then have to store that in the eBay account. In addition to the Lucid number. Since I am obliged to provide proof and documentation, that the product and shipping materials are PPWR-compliant.

Even if the topic is older, I think it is veeeery current 😋
As things stand as we have understood them:
As of the cutoff date 12.08.26:
1. Newly purchased packaging (envelopes, boxes, filling material) MUST be offered by the SELLER with a license and an appropriate proof must be provided
2. These quantities no longer have to be reported to LUCID
3. You do not have to upload any extra data here anywhere at eBay (or A B C)

4. BUT: Of course, the obligation remains to continue licensing packaging you still have yourself and to report the quantities to LUCID ... this also applies to used boxes and newspapers

That is how WE have understood it .... Any objections? Agreements? Additions?
😎

strass4me

OP4 months ago

I understood it that way too.
Just one addition:
The shipping materials should be purchased domestically and also go to the end consumer domestically.
So that they do not have to be reported to Lucid.

sammlerkiste-1-2-3

·4 months ago

@strass4me wrote:
That's how I understood it too.
Just one addition:
The shipping materials should be bought domestically and also go to the end consumer within the country.
So that they do not have to be reported to Lucid.

Great addition!
I can imagine that many of the material suppliers based abroad offer licensing for their German customers as well (at least if they sell on eBay Germany), BUT then you have to pay attention to that in the listing yourself and, if necessary, continue licensing that quantity yourself.

For shipping abroad, of course, you have to observe the respective country regulations; we have already limited shipping to Germany. Austria and France were our biggest foreign markets ... both have now basically ruled themselves out with the regulations, I think from August all small sellers will only ship to Germany and, if necessary, non-EU countries 😋