Every EPR rule change that reaches a seller.

From 18 February 2027, Article 11 of Regulation (EU) 2023/1542 requires a portable battery built into a product placed on the EU market to be removable and replaceable by its user, with tools anyone can buy. Article 11(2) names the products whose battery may instead be replaceable only by an independent professional. This delegated regulation, in force since 11 November 2026, rewrites that list: two groups become eight. It does not move the day Article 11 applies.

The new groups: wearables whose safety, durability or water resistance user access would compromise, when they are too small for a safe battery change or rely on a sealed enclosure; electric toys with rechargeable batteries, until 31 July 2030; wireless thermometer probes made for food contact during food preparation; equipment for potentially explosive atmospheres; on-body systems that deliver medicines under the skin; telematics devices mounted on the roof of farm and construction machinery. The washable-appliance group now names wearables too. Every group but the medical one applies only where the exemption is required for the safety of the user and the appliance.

If you sell devices with a built-in battery, check each product against the list before 18 February 2027. Our replaceable batteries guide goes through it group by group.

Today, a seller established in one member state that sells directly to end users in another must appoint an authorised representative for EPR in that country: for packaging (Article 45(3) of Regulation (EU) 2025/40), batteries (Article 56(3) of Regulation (EU) 2023/1542) and WEEE (Article 17(2) of Directive 2012/19/EU).

On 10 December 2025, the Commission proposed to suspend these rules until 1 January 2035: a regulation for packaging and batteries (COM(2025) 982), a directive for WEEE, textiles and single-use plastics (COM(2025) 983). A producer established in the EU could then choose whether to appoint a representative. For producers established outside the EU, the Commission says the rules stay as they are.

On 20 October 2026, the European Parliament voted amendments to both texts: the suspension would cover only small and micro enterprises established in the EU, would end once a broader reform of authorised representatives applies, and would keep the rules for producers established outside the EU. The texts now go to negotiations between the Parliament and the Council.

Nothing changes yet. Until a text is adopted and published in the Official Journal, the obligation to appoint a representative applies as written, and our authorised representative page describes the law in force.

This directive, in force since 16 October 2025, amends the Waste Framework Directive. Every member state must bring it into national law by 17 June 2027, and have an EPR scheme for textiles and footwear in place by 17 April 2028: clothing and clothing accessories, hats, household linen such as bed and table linen, curtains, and footwear, listed by customs code in its Annex IVc.

A seller that sells these products at a distance directly to end users in a member state where it is not established counts as a producer there. It must register in each member state where it first makes them available, entrust a producer responsibility organisation with its obligations there and, if it is established in another member state, appoint an authorised representative. A member state may also require one from a producer established outside the EU. Before letting you sell to consumers, a marketplace must obtain your registration number in the consumer's member state.

A directive binds the member states: your obligations come from each country's law once it takes the directive in. Our textile stream page lists the countries where we document a textile route today.

Regulation (EU) 2023/1542 requires an economic operator that places batteries on the market to run a due diligence policy on the cobalt, natural graphite, lithium and nickel they contain, verified by a notified body. It was due to apply from 18 August 2025. This regulation postpones it by two years, to 18 August 2027, and gives the Commission until 26 July 2026 for its guidelines on it.

It does not apply to an operator with a net turnover below EUR 40 million in the financial year before last, unless it belongs to a group above that figure (Article 47).

The packaging and packaging waste regulation (PPWR) applies from 12 August 2026. A regulation applies in every member state on the same day and in the same words, with nothing to transpose first. National registers and schemes still take your registration and your declarations, country by country.

Selling across a border. A producer that makes packaging or packaged goods available directly to end users in a member state where it is not established must appoint an authorised representative for EPR there, by written mandate (Article 45(3)). A member state may also require one from a producer established outside the EU.

Selling on a marketplace. Before letting you sell to consumers in the EU, an online marketplace must obtain your registration number in the consumer's member state and your self-certification that you meet your EPR obligations there (Article 45(4)). You give the same information to a fulfilment service provider when you sign with it (Article 45(7)).

From 18 August 2025, Chapter VIII of the batteries regulation, on the management of waste batteries and extended producer responsibility, applies, and Directive 2006/66/EC is repealed, apart from a few provisions kept for a transition.

A producer registers in each member state where it first makes batteries available, including batteries built into appliances and vehicles, and may only sell there once registered (Article 55).

A seller that sells batteries, or products that contain them, at a distance directly to end users in a member state where it is not established counts as a producer there, and must appoint an authorised representative for EPR in each member state where it sells (Article 56(3)).