Printed packaging, labels and shipping materials

• Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation
• Directive 94/62/EC — until repeal
• Regulation (EC) No 1935/2004 where the packaging contacts food
• Regulation (EC) No 2023/2006 — good manufacturing practice for food contact
• National EPR laws

Who has to appoint one

Anyone who first makes packaging or packaged goods available in a member state. For a non-established seller this means an authorised representative for extended producer responsibility in each country, registration in the national register and annual declarations by material and weight.

Thresholds and exemptions

Most member states apply a zero threshold to distance sellers. The new Packaging Regulation adds design requirements including recyclability performance grades and minimum recycled content by date.

What must appear on the label

Material identification and sorting instructions, mandatory in France and Italy today and becoming harmonised under the new Regulation with a common labelling system. Where packaging contacts food, the food contact indication and the declaration of compliance in the supply chain.

Marketplace fields

Amazon and other marketplaces validate packaging EPR numbers against the national registers and suspend sellers without them. Germany's LUCID and France's UIN are the most systematically checked.

Documentation you must hold

Registration in each national packaging register. Contract with a producer responsibility organisation. Annual declarations of packaging placed on the market by material. For food contact packaging, the declaration of compliance, migration data and good manufacturing practice records covering printing inks and adhesives.

Standards and testing

Migration testing for food contact packaging, including set-off from printing inks on the reverse of the material, and recyclability assessment against the criteria being introduced under the new Regulation.

Language requirements

Sorting instructions in the language of the country concerned, with the harmonised pictograms as they come into force.

When it applies

Registration before the first shipment into each country. The Packaging Regulation applies from 12 August 2026 with staged requirements on recyclability, recycled content and minimisation running to 2030 and beyond.

How long records are kept

Registration and declaration records per national law, generally five to ten years.

What happens if you do not comply

Sales bans in the member state, retroactive fees for undeclared volumes, marketplace suspension and national fines. Germany and France pursue non-registered foreign sellers systematically.

Who enforces it

National packaging registers and environmental agencies, food safety authorities for food contact packaging, and marketplaces as verifiers.

Where the boundary lies

Packaging EPR is national and cannot be covered by any EU-level appointment, which is the same trap as WEEE and batteries. Separately, printed food packaging brings the ink set-off issue, where substances migrate from the printed outer surface to the food contact surface in the reel.

Questions we are asked

Do we need packaging registration if we only ship a few parcels?

In most member states yes, from the first parcel. There is no meaningful threshold for distance sellers.

Does the marketplace register for us?

No. It verifies your number and suspends the listing if you do not have one.