Any packaged product placed on the EU market must meet the heavy-metal limit, carry an EPR registration per country and have a declaration of conformity on file. Platforms are already asking for the ERN.
Regulation (EU) 2025/40 entered into force on 2025-02-11 and its first mandatory wave applies from 2026-08-12: sum of lead, cadmium, mercury and hexavalent chromium in any packaging must not exceed 100 mg/kg; food-contact packaging must meet PFAS limits (single non-polymeric PFAS below 25 ppb, targeted sum below 250 ppb, all PFAS including polymers below 50 ppm total fluorine, with a fluorine-source statement required above that); all packaging must be recyclable by design; every packaging producer must hold an EPR registration in each country of sale, with a non-EU business appointing an authorised representative; and a declaration of conformity plus technical documentation must be compiled and kept. Several marketplaces require a valid ERN to be uploaded.
Anyone placing a packaged product on the EU market, regardless of where it is manufactured, including FBA and FBM sellers.
Per-country EPR registration with an EU authorised representative, a material and weight BOM per SKU, heavy-metal and PFAS test reports for food-contact packaging, and a signed DoC per packaging type kept for at least five years.
Source: PPWR compliance timeline · last verified 2026-10-31
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