The EU PPWR Regulation has been applied since 12 August 2026 and imposes on Polish online shops selling to consumers in another EU countries registration obligations and the request of a local typical of the EPR on each mark market. any companies halt shipping, due to the fact that fixed costs and formalities eat the margin on tiny sales.
PPWR changes its rules of sale abroad
Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, known as PPWR, entered into force on 11 February 2025 and its essential provisions have been applied since 12 August 2026. The act shall apply straight throughout the Union. It covers the full life cycle of packaging, from plan and utilized materials to reuse, recycling and waste management funding.
Brussels presents the improvement as harmonisation of the marketplace and a way of reducing the mountain of packaging. European Commission indicates, that without fresh activities, packaging waste could increase by 19% by 2030 and plastic packaging waste alone by 46%. The environmental nonsubjective is understandable. The problem starts where the administrative cost does not depend on the sales scale.
For a Polish store that sends respective packages a period to respective EU countries, the problem is not just the kind of cardboard. A distance sale straight to the end-user means that the trader can be considered as a maker of packaging on the marketplace of the country to which the consignment reaches. This triggers the obligations of the extended work of the manufacturer, the EPR.
Registration and typical in each country
Articles 44 and 45 of the PPWR Regulation require legal introduction of packages with maker registration in the country of sale. The company conducting cross-border direct sales is besides to appoint a written typical for the EPR in each associate State where it makes the packaging or packaging available for the first time outside its country of establishment.
In practice, this means separate procedures in subsequent markets. The typical shall act in the country of the consignee and the trader must account for the quantity and types of packages entered in accordance with the applicable national system. The trading platforms are to get information about its registration and a declaration of compliance with the obligations of the EPR in the consumer country before allowing the seller.
There was no 1 EU window in which the Polish company could get the full thing. Any additional state of sale may signify another registry, power of attorney, reporting and fees. A large company spreads this cost to hundreds of thousands of orders. A household store or a tiny handicraft workshop must include it in respective or respective deliveries. The bill's off the hook.
Polish companies retreat deliveries
The diary Gazeta Prawna stated that any tiny and medium-sized Polish stores began to halt global shipping, as adjustment costs increase faster than gross from smaller markets. The Editorial Board besides highlighted the deficiency of ready-made national implementing rules. The entrepreneur was so faced with the worst set: the work is already working, but the legal environment remains incomplete and dispersed.
This hits Polish capital precisely erstwhile the net was expected to let tiny companies to go beyond the home market. Electronic commerce gave Polish SMEs the way to export. PPWR creates a permanent entry barrier that most powerfully affects retailers with low volume.
The consequences will besides be felt by the customer. The smaller number of shops serving the country is weaker competition, poorer offer and higher prices. typical costs, reporting and packaging charges shall not disappear. The company will transfer them to the price of the product or quit the market.
Brussels saw a mistake, but did not fix it
The most powerful evidence of defective construction is the reaction of the European Commission itself. The Commission proposed temporarily suspending the appointment of an EPR typical for producers established in the EU until 1 January 2035. However, draft COM(2025) 982 is inactive in the legislative procedure. He did not change the rules until 12 August 2026.
So we have a classical example of a regulatory rush. First a dense work was passed, then it was considered to require suspension, but entrepreneurs entered the deadline without an effective amendment. This method undermines legal certainty and rewards entities that can afford conformity departments and a network of abroad agents.
The policy itself to reduce packaging waste does not justify building 26 separate administrative thresholds for a company utilizing the common market. The PPWR is besides expected to change the regular rules for packaging, but in cross-border sales there is real access for Polish entrepreneurs to customers in Europe.
What this means for the Polish economy
Poland needs companies that grow by export, build their own brands and keep the margin in the country. If EU regulation makes a tiny store exempt supplies to the Czech Republic, Germany or France, the common marketplace exists for it mainly on paper. large players stay. Mali is returning from the administrative border, although the road is not grounded.
The government should urgently guarantee clear national procedures, free information for entrepreneurs and push for the prompt removal of the work of multiple representation for EU companies. Finally, 1 registration window is needed for cross-border sales and small-scale protection thresholds. Environmental protection must be based on proportionality. Otherwise, green regulation becomes a tool for concentrating the marketplace at the expense of Polish household companies.
Source: Journal of the Legal Gazette, Regulation (EU) 2025/40
