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20 November 2025Shipping products into the European Union might look simple at first glance — pack the item, apply a label, hand it over to your carrier. But sellers entering the EU market for the first time quickly learn that Europe plays by a different rulebook. Packaging and labelling aren’t just operational details here - they’re compliance requirements that directly affect whether your shipment gets accepted at customs, allowed into an EU warehouse, or checked in at an Amazon fulfilment centre.
Why does this matter so much? Because EU regulations go far beyond “make sure the box is sturdy.” They define what materials you can use, how your packaging must be labelled, which recycling symbols must appear on the box, and even what language those labels must be in. And if you’re sending products to Amazon Europe, the list becomes even longer: carton strength tests, barcode placement requirements, and strict rules for liquids, batteries and fragile items.
Many non-EU sellers only learn about these rules after their shipments are rejected, relabelled at a cost, or flagged for non-compliance fees though. This article is here to help you avoid that scenario — by walking you through the essential EU packaging and labelling requirements, previewing the upcoming Packaging and Packaging Waste Regulation (PPWR) changes for 2028, and highlighting the specific standards Amazon expects from every inbound shipment.
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What the EU actually regulates when it comes to packaging
One of the many things that surprises non-EU e-commerce and Amazon store owners when planning to expand into Europe is that in the EU, packaging isn’t treated as “just the box your product arrives in.” No, the packing, filling and labels are treated as a part of the product itself and because of this, all elements of the packaging have rules attached to it. And if your shipment isn't compliant with the regulations, there's a high risk your products might be stuck at the customs for longer than you would have liked it.
So what exactly does the EU look at? Let’s break it down for clarity.
Materials and safety
The first thing the EU cares about is what your packaging is made of. That means:
No harmful substances — anything containing restricted chemicals or heavy metals is a non-starter (that's especially important if you import from Asia!)
Recyclable materials are preferred — paper-based packaging is usually the safest bet.
Less plastic is better — especially using single-use plastic or multi-layer materials that can’t be separated during recycling is frowned upon.
No “over-packaging” — shipping a small item in a huge box with lots of air inside is increasingly a compliance issue, not just a bad customer experience.
If your current packaging relies heavily on plastic wrap or complicated multi-layer constructions, it would be best if you simplified the packaging before starting to ship your products to EU countries.
Labelling: what needs to be visible on the packaging
Labelling rules catch many sellers off guard, mostly because they apply to the outer packaging too — not only the product inside.
At minimum, your packaging should include:
A clear, readable label that won’t fade or smear during transport
Information in the language of the destination country
Details of an EU-based responsible party (if your product category requires it)
Recycling or disposal instructions for the end consumer
Net and gross weight when relevant
Any hazard warnings if your item falls under specific categories (like batteries or chemicals)
For non-EU sellers, the two most common issues are: missing language requirements and missing recycling information on the labels.
Environmental markings
Environmental labelling is a big deal in Europe — and it’s only getting stricter. The goal is simple: help consumers recycle correctly and reduce how much packaging ends up in landfills. Because of that, the EU requires clear, easy-to-understand markings on most types of packaging.
You’ll typically need:
A recycling symbol that follows EU standards
A material identification code (so consumers know how to sort the waste)
Basic disposal guidance
So far, so good. But here’s where things get tricky: some EU countries add their own national rules on top of the EU framework. If you’ve never shipped to Europe before, these extra requirements can feel slightly confusing. For example, France has the Triman logo, which is French environmental symbol that tells consumers: “This product and/or its packaging should be sorted for recycling.”
The Triman logo is mandatory in France for most consumer products and packaging and you cannot replace it with a standard EU recycling symbol. What's more, the symbol must appear directly on the packaging — not just on your website or a leaflet. For many products, France also requires sorting instructions (called “info-tri”) alongside the Triman icon.
Extended Producer Responsibility (EPR) — what non-EU sellers really need to understand
If you’re new to the EU market, EPR is often the first major compliance topic that creates confusion. It sounds pretty complex, it’s handled differently in each country, and most sellers outside Europe have never dealt with anything similar. But once you break it down, it becomes much easier to understand — and much easier to set up.
In simple words, Extended Producer Responsibility is the EU’s system for making businesses responsible for the waste they create - especially packaging waste.
Basically, the EU wants brands and sellers to contribute to:
collecting used packaging from consumers,
recycling it,
reducing overall waste,
and designing packaging that’s easier to recycle in the first place.
To make this happen, they use a straightforward model:
If you put packaging on the market, you pay into the recycling system of that country.
This usually means:
Registering in that country’s EPR system
Reporting how much packaging you ship there
Paying a small recycling fee once a year
Think of it as a recycling “membership” — not a tax, and not a penalty. Just a formal step that proves you’re contributing to the system.
Why EPR applies even if you're not based in the EU
This is where many international sellers get caught off guard: EPR applies based on where your product ends up — not where your company is located. If your goods arrive in any EU country and generate waste there, the EU considers you a “producer” under EPR rules, even if:
your warehouse is outside Europe,
your business is registered outside Europe,
you ship directly to consumers,
or you use Amazon FBA/FBM or a 3PL provider.
So if your products (and thus, everything you used to wrap and pack said product) enters the EU, you must register for EPR.
What registration actually involves (step by step)
Registering for EPR isn’t difficult, but it does involve several moving parts — especially if you’re doing it for the first time, and you’re not familiar with EU systems. So to help you prepare for the registration, let's look at how the registration process typically looks like.
Step 1: Create an account with the national EPR authority
First thing you need to keep in mind is that each EU country runs its own registration portal — there isn’t one single “EU-wide” website for EPR. So you’ll need to register separately in every country where your packaging ends up. For example, Germany uses the LUCID Packaging Register, which is probably the most well-known system among Amazon sellers. France meanwhile requires registering with their Agency for the Transition of Ecology (ADEME) and then with cooperating producer organisations (PROs) such as Citéo, Adelphe and Léko.
Other countries have their own versions, but the idea behind them is always the same: you tell the local authority who you are and confirm that your packaging will enter their market.
During this step, you will usually need to provide:
your business legal name,
address (your real company address outside the EU is accepted),
company registration number,
contact person details.
Step 2: Declare that you are placing packaging on the market
This is where you formally confirm that your products (and their packaging) will enter the waste stream of that country.
Typically, you will be asked to specify:
the type of packaging you use (e.g., cardboard, plastic, paper, composites),
whether you ship directly to consumers, to Amazon FBA, or to distributors,
estimated yearly packaging volume
Don't worry if you can't provide precise volumes at this stage, the system will accept a rough estimation as well.
Step 3: Sign a contract with a “producer responsibility organisation” (PRO)
After registering with the national authority, you must join a licensed recycling scheme in that country. These organisations handle the collection and recycling of packaging waste on your behalf. Typically, you'll have a few different providers to choose from, which differ based on price per kilogram of packaging, contract length or additional services available. Many of them also offer English support and work regularly with Amazon sellers.
Once you sign the contract, the PRO becomes your official recycling partner.
Step 4: Report your estimated packaging volume
Most PROs will ask you to estimate how many kilograms of packaging you expect to place on the market in the coming year. This doesn’t need to be extremely precise — it’s just a forecast.
To make this estimate, sellers typically calculate:
average weight of a single product package (e.g., 84 g),
average weight of the shipping packaging (e.g., 120 g),
expected number of units shipped to that country.
If you’re completely new to the market, you can use very low estimates and adjust them later.
Step 5: Receive your EPR registration number
After completing the first four steps, the national authority will assign you a unique packaging EPR registration number.
This number is important because:
Amazon may ask for it before allowing you to sell,
Some countries require it on invoices or shipping documentation,
It proves you’re legally registered in case of audits.
Keep this number in a safe and easily accessible place, as you'll use it very often.
Step 6: Apply the number where required
Depending on the country, you may need to:
add your EPR number to your Amazon seller account,
include it in your product listings (in certain categories),
show it on invoices or delivery notes,
provide it to 3PL suppliers or customs brokers.
Not every country requires visible display, but Amazon will definitely expect the number in your Seller Central compliance section.
Step 7: Submit an annual (or sometimes quarterly) report
EPR doesn’t end at registration - that’s only the setup. Once you’re in the system, you also need to report how much packaging you actually placed on the market. For many sellers, this is the part that feels confusing at first, because every country handles reporting a little differently.
Most countries ask for a breakdown of:
material type (cardboard, paper, plastic, aluminium, glass, composites),
total weight per material in kilograms,
number of units sold in that specific country,
any changes in packaging that affect recallability (e.g., switching from plastic tape to paper tape),
a confirmation that data is accurate to the best of your knowledge.
What you should keep in mind though is that some countries require even more detail. Germany, for example, will ask you for the exact weights per material category, while France may require combining EPR reporting with the information needed for environmental labelling (Triman + info-tri). You also need to check how often you are expected to send the report:
In some countries, reporting is annual (once per year).
In others, especially slightly stricter markets, reporting may be quarterly.
A few systems require both an initial estimate and a final report.
Your Producer Responsibility Organization (PRO) will usually send reminders ahead of deadlines - but it’s still your job to track this.
How to calculate the packaging amounts
If you’ve never done this before, the simplest method is:
Weigh your product packaging (retail box, inner wrap, paper instructions, etc.).
Weigh your shipping packaging (outer box, label, tape, filler).
Multiply these weights by the number of units sold in that country.
Group the totals by material type.
Example:
If each product uses 80 g of cardboard and you sold 2,000 units to France → you report 160 kg of cardboard.
Sellers usually create a simple spreadsheet to track this month by month so that the annual report takes minutes, not hours.
Once you send your data to the PRO or national authority:
They calculate the exact recycling fee based on material type and weight.
You receive an invoice or online payment request.
You get a confirmation of compliance for that reporting period.
Your EPR registration remains active for the next cycle.
The cost is usually low — cardboard-heavy sellers pay the least. And don't worry in case your initial estimate was too low or too high. All you need to do is to adjust the volume in the annual report and then your PRO will recalculate the fee for you. Then you either pay the difference or receive a credit for the next cycle.
PPWR 2028 – what will change and why sellers must prepare now
If you’ve been reading about EU packaging rules lately, you’ve probably seen the same acronym everywhere: PPWR. It stands for Packaging and Packaging Waste Regulation, and it’s one of the biggest overhauls of packaging legislation Europe has ever introduced.
The important part?
It becomes fully enforceable in 2028, and it will radically reshape what “compliant packaging” means for any seller shipping products into the EU.
And yes - this matters just as much for sellers outside the EU as for European brands.
Let’s break it down in a way that helps you understand what’s coming and how to prepare.
Until now, the EU’s packaging rules were based on a directive, which allowed each country to interpret the rules differently. That’s why Germany has LUCID, France has Triman + info-tri, and Italy has its own labelling system. Which also meant quite a lot of confusion for non-European sellers, that, for example, wanted to start selling to those three countries and learned that they have to register and file reports differently for each country!
PPWR changes that, as it replaces the old directive with a single, directly applicable regulation for all 27 EU countries.
For non-EU sellers, this is actually excellent news because they won't have to create different reporting processes for each country or track the news from each country to learn about the upcoming reporting changes. No matter to how many countries they are selling, they will have a single regulation and process to follow.
But the regulation itself is stricter, and that’s where sellers need to pay attention.
Limits on empty space (goodbye oversized boxes)
One of the biggest shifts in PPWR is the EU’s plan to crack down on excessive packaging — something many e-commerce sellers rely on without thinking. Sending a small item in a big box with lots of filler is no longer just “inefficient”. Under PPWR, it becomes a compliance issue.
Here’s what this means in practice:
The EU will introduce a maximum allowed empty space ratio.
If the inside of your box is mostly air, it won’t be compliant.
“One-size-fits-all” cartons will cause problems unless the fit is reasonable.
Plastic fillers like air pillows, foam, and bubble wrap will be heavily restricted.
Logistics providers (including Amazon) will be expected to measure and monitor empty space ratios during inbound checks.
For sellers outside Europe, this means reviewing the entire packaging workflow:
You may need multiple box sizes, not just one.
You’ll need to design packaging that fits the product more closely.
Any filler you use should be paper-based and minimal.
If you’re repacking in a 3PL, they’ll need updated guidelines too.
If you currently ship 80% of your orders in the same box, PPWR will force you to diversify your packaging sizes.
Mandatory recycling and easier sorting.
PPWR introduces a simple rule that will affect almost every seller:
Packaging must be fully recyclable using standard EU recycling processes.
This is no longer something “nice to have”. It’s a requirement.
And it comes with a big practical impact:
Packaging must be monomaterial wherever possible.
Multi-layer or composite packaging (paper + plastic + foil) will be severely restricted.
Laminated cardboard, plastic windows, metallic coatings, and mixed-material bags will often require a complete redesign.
Packaging must be easy to separate into recyclable fractions — paper with paper, plastic with plastic.
What this means for sellers:
Fancy retail boxes with glossy coating or plastic windows may no longer be compliant.
Plastic-based mailers that are not 100% recyclable will need to be replaced.
Mixed-material protective packaging (e.g., bubble-lined envelopes) will be phased out.
You should plan to move toward cardboard, paper tape, paper filler, and paper labels.
PPWR will also introduce recycling performance classes (A, B, C, D). Low-performing packaging (category C or below) will eventually be removed from the market.
Increasing recycled content requirements
PPWR doesn’t just require packaging to be recyclable but it also requires that part of it comes from recycled materials.
This applies especially to:
plastic packaging,
transport packaging,
shipping materials used in e-commerce.
The EU will set minimum recycled content percentages, which will increase in phases. Suppliers will also need to provide proof that the material includes genuine post-consumer recycled (PCR) content. So if until now you relied on mostly plastic-based solutions, it's a good idea to slowly start moving from those to working with packaging suppliers who already work with PCR materials and can provide necessary documentation or certification.
Stricter labelling for recycling and disposal
Right now, packaging labels across Europe are pretty much a mess. France has Triman. Italy has environmental labelling rules. And Germany has its own system. What this means is that sellers need different labels for different markets.
PPWR changes that by introducing a single, unified EU-wide labelling system.
What we know so far:
All EU countries will use the same set of recycling symbols.
Sorting instructions will be standardized.
The visual design (icons, layout, placement) will be consistent everywhere.
Labels must appear on every part of the packaging that is separable (e.g., box, bottle, cap, label).
This is a huge win for non-EU sellers because instead of creating country-specific packaging, you’ll follow one system for all 27 markets.
However, to prepare:
leave enough space on your packaging for new labels,
avoid busy designs that make labels difficult to place,
expect Amazon to enforce this ahead of schedule.
Restrictions and phase-out of certain packaging types
PPWR identifies several types of packaging that consistently fail recyclability standards and contribute heavily to waste. These types will face restrictions, phase-outs, or outright bans.
Affected packaging includes:
non-recyclable single-use plastics,
multi-material composites that cannot be separated (e.g., paper + foil + plastic),
black plastics that optical sorters can’t detect,
certain foams (like EPS/styrofoam),
plastic-based padded mailers,
heavily lacquered or laminated cardboard.
Examples of packaging that will need replacement:
bubble-mailers with plastic interiors and paper exteriors,
cardboard boxes with PVC windows,
glossy laminated boxes,
heavy-duty multi-material pouches.
If your current packaging uses anything “mixed” or “shiny”, PPWR will likely affect it, so it's best to start replacing the packaging you are using now before the new law becomes enforceable.
New requirements for re-use systems
PPWR strongly encourages the use of reusable packaging — mainly in B2B and logistics environments.
This includes:
reusable transport crates,
reusable pallets and pallet wraps,
reusable packaging loops within EU supply chains.
While many of these obligations fall on EU-based companies, they will indirectly affect non-EU sellers because:
major logistics providers (Amazon, DHL, DPD, GLS) will update their processes,
some fulfilment centres will require reusable transport packaging internally,
Amazon may introduce new standards for inbound shipments.
So even if you’re not required to use reusable packaging for your products, you may need to adjust to new expectations from EU logistics partners.
What sellers should do now (practical steps)
PPWR starts fully in 2028, but waiting until then is one of the most expensive mistakes a seller can make. Packaging redesigns, supplier changes and Amazon compliance updates take months — sometimes longer if you need new materials or certifications.
Here’s a practical, step-by-step plan to help you get ahead.
1. Audit your current packaging (and do it with real measurements)
Start by understanding what you’re actually working with. Most sellers assume they already know their packaging, but once they measure it, they’re shocked by how much empty space or non-recyclable material they’re using.
Break your audit into four parts:
Materials
What is the box made of?
Is the tape plastic or paper?
Are the labels paper-based or plastic film?
Are fillers recyclable (paper) or single-use plastic?
Empty space ratio
Physically measure:
box dimensions,
product dimensions,
filler volume.
If more than ~30–40% of your box is empty space, PPWR will require a change.
Recyclability
Check whether each component is monomaterial.
If something combines paper + plastic (like padded mailers), it’s likely non-compliant.
Visual space for labelling
PPWR will require unified EU-wide recycling icons.
If your packaging design is crowded, you’ll need to reserve space for future labels.
This audit gives you a baseline for redesign.
Move toward monomaterial packaging (the simplest way to future-proof)
Even without knowing every detail of PPWR yet, one thing is certain:
monomaterial packaging will always be the safest option.
For most sellers, this means:
cardboard box (uncoated or lightly coated),
paper tape instead of plastic tape,
paper filler instead of plastic air pillows,
paper labels with eco-friendly adhesive,
no laminated layers, foils or plastic windows.
Why this works:
easier to recycle,
cheaper long-term,
lower EPR fees,
fully compatible with Amazon FBA,
guaranteed compliance with PPWR categories A–B recyclability.
If you’re redesigning packaging, start here — it eliminates most future headaches.
Reduce empty space — before Amazon forces you to
PPWR will officially regulate empty space, but Amazon won’t wait until 2028.
Once PPWR becomes law, Amazon will update FBA packaging requirements (just like they did with battery rules, dangerous goods and EPR).
That means:
inbound shipments with too much empty space may get rejected,
sellers may be charged repackaging fees,
Amazon might introduce new carton-size requirements.
To prepare, start optimizing now:
offer 2–4 carton sizes instead of one,
work with suppliers to create snug-fit packaging,
switch from oversized boxes to right-sized mailers (paper, not plastic),
eliminate void fill unless absolutely necessary.
This single step reduces: shipping costs, dimensional weight, EPR fees and compliance risks.
Choose suppliers who understand PPWR (and can prove it)
Not all packaging suppliers are prepared for PPWR. Some will continue selling materials that look eco-friendly but fail recyclability tests.
When reviewing suppliers, ask these questions:
Can you provide documentation on recyclability?
Do your materials contain certified recycled content?
Can you produce monomaterial alternatives?
Are your adhesives and coatings PPWR-friendly?
Do you follow EU recyclability standards (not just generic “eco claims”)?
Suppliers who can’t answer these questions probably won’t be compliant by 2028.
Working with the right supplier now means no urgent redesigns later.
Prepare for unified EU-wide recycling labels (even if they’re not published yet)
PPWR’s new labelling system isn’t fully released, but the direction is clear:
all packaging must include harmonized recycling icons,
labels must indicate both the material and the correct waste stream,
labels must appear on each separable part of the packaging.
Since the exact designs will arrive later, what can you do now?
Reserve blank space on your packaging for future labels.
Avoid printing designs edge-to-edge.
Keep the bottom or side panel clean for regulatory markings.
Don’t commit to highly stylized or overcrowded layouts.
A little planning now means you won’t need a full packaging redesign later.
Update internal workflows and 3PL instructions
Most non-EU sellers rely on 3PLs or prep centres to pack and ship products.
This means your compliance is only as good as their processes.
You should:
update your packing SOPs,
instruct 3PLs to use only approved materials,
specify allowed fillers (paper) and prohibited fillers (plastic),
require that packaging matches empty-space rules,
ask for monthly packaging reports (weight per material).
If you use Amazon FBA, expect Amazon to adjust its own requirements soon — so your prep centre must be ready.
Follow PPWR updates (because the details are still evolving)
PPWR is a regulation — not a guideline — but the EU is still releasing technical details and timelines. These updates affect:
recyclability performance classes,
minimum recycled content percentages,
formatting of unified labels,
implementation timeline per packaging type.
Check updates quarterly.
A 5-minute review every few months prevents expensive redesigns later.
Summary
If there’s one thing to take away from this guide, it’s this: the EU takes packaging seriously — and if you want to sell here smoothly, you’ll need to take it seriously too.
For non-EU sellers, a lot of the rules feel unfamiliar at first. Recyclable materials, environmental labels, language requirements, EPR registration… it’s a different world from the U.S., China or the Middle East. But once you break everything down into steps, it becomes manageable — and actually pretty logical.
And then there’s PPWR 2028. It’s not just another regulatory update; it’s a full reset of how packaging must be designed and labeled in Europe. Empty-space limits, mandatory recyclability, required recycled content, and one unified set of labels for all 27 countries — all of this is coming, and it will change how sellers pack, ship and source materials.
The good news? You don’t need to wait for the last minute. A simple packaging audit, switching to monomaterial solutions, trimming empty space, choosing suppliers who already understand PPWR and keeping your packaging data organized will already put you miles ahead of most new sellers entering the EU.
In short: the sooner you start preparing, the fewer surprises — and the fewer costs — you’ll face later. Europe rewards sellers who plan ahead.
