PPWR uncertainty drives surge in packaging EPR compliance demand, says Lappa
Key takeaways
- Lappa says PPWR is increasing pressure on cross-border companies to clarify packaging EPR responsibilities.
- EPR responsibility can shift between businesses depending on who places packaged goods on a national market, while registration timelines vary across EU countries.
- Lappa reports a 166% rise in packaging EPR deals from Q2 to Q3 2026.
The EU’s Packaging and Packaging Waste Regulation (PPWR) has made packaging compliance an urgent operational focus for cross-border companies, according to Lappa, a tax management solution provider based in the UK.
Lappa’s consultation data reveals that 46% of its clients discovered that their eco-fee obligation was lower than expected, or that the payment obligation they had been preparing for did not apply to them at all.
Additionally, registration timelines differed “enormously” by country, ranging from a few days to multiple months.
Olga Maksimova, founder of Lappa, tells Packaging Insights: “Much of the confusion comes from the EU single market itself. Goods move freely across borders, without customs formalities, so companies naturally assume their eco-fee obligations travel with them. But under EPR rules, the responsibility doesn’t necessarily follow the product all the way to its final destination.”
Understanding obligations
Maksimova notes that one of the most common misconceptions regarding EPR compliance is that companies must pay packaging eco-fees in every EU country where their products are sold, particularly when it comes to primary packaging carrying their own brand.
“There is an important distinction,” she underscores. “If a company sells packaged goods to a business in another EU member state, and that business purchases the goods for resale in its own country, the EPR obligation to pay eco-fees generally falls on that local business when it places the products on its national market. The eco-fee doesn’t disappear. The responsibility simply changes hands.”
“This doesn’t mean the original company is relieved of its obligations regarding packaging quality and compliance with PPWR requirements. What changes is who pays for the management of packaging waste.”
Olga Maksimova, founder of Lappa.Lappa suggests that businesses operating in multiple European countries should focus on identifying which entity is performing the legally relevant role when this packaging is placed on the market. They cannot focus simply on where their products are being sold, stresses the company.
Following registration timelines
Lappa shares that registration systems, representatives, and compliance providers are facing a concentration of demand. It suggests that companies expanding in the EU should not assume that packaging EPR registration can be completed shortly before sales begin.
The company highlights that for markets with longer processing periods, businesses should map their obligations and begin registration well ahead of the commercial launch.
“The good news is that October is not too late,” says Maksimova. “Many of the companies we are registering right now will still be able to obtain their EPR numbers and report for the entire 2026 calendar year. In many countries, businesses can specify their intended registration start date — for example, 1 January 2026 — even if the registration itself is completed several months later.”
“In practice, the current approach is designed to bring businesses into compliance rather than unnecessarily disrupt supply chains. Where customs authorities or marketplaces request evidence that registration is underway, we can provide confirmation of the application.”
“Don’t let the registration timelines scare you. It’s not too late to get compliant — but it’s a good time to get started.”
Surge in demand
Lappa also points out that the number of packaging EPR deals handled by the company grew by approximately 166% from Q2 to Q3 2026.
“That combination of awareness and real commercial pressure is what drove the 166% surge in demand we experienced,” Maksimova explains.
“EU institutions and national authorities were raising awareness about the PPWR. Marketplaces, including Amazon, OTTO, and TikTok, reinforced the message with direct warnings, and some sellers faced account restrictions. Customs authorities in several countries also started requesting evidence of EPR compliance.”
“There was a knock-on effect across supply chains. Large companies began asking their suppliers to demonstrate compliance, passing the message further down the chain. Regulators made it impossible to miss. Marketplaces and supply chains made it impossible to ignore,” she concludes.
