The EPR compliance calendar 2025-2028: batteries, packaging, textiles, DPP

EPR obligations do not arrive as one law; they arrive as a drumbeat of dated events, each adding registers, streams or duties. This calendar lists the events that matter to marketplaces, fulfilment providers and their sellers, from the batteries regime already in force to the textile registers landing through 2028. Dates below are the verified ones; where an act is late or a decision pending, we say so.

Already in force

13 December 2024: GPSR raises the platform baseline

The General Product Safety Regulation applies, with marketplace registration in the Safety Gate portal, an EU responsible person required for every product, and explicit marketplace duties under its Article 22, per the US ITA's GPSR briefing and KPMG Law's analysis. Not an EPR law, but it consolidated the verify-before-onboarding operating model, and the budget line, that EPR verification now slots into.

18 August 2025: batteries EPR goes national everywhere

Under Regulation (EU) 2023/1542, producer registration for batteries applies per member state from 18 August 2025, and distance sellers count as producers, per Herbert Smith Freehills Kramer's briefing. Marketplaces began checking battery EPR numbers, and Amazon announced deactivation of non-compliant battery offers in Germany, the Netherlands, Poland and Sweden from that date. Batteries are the template: a new stream arrives, registers multiply, platforms enforce.

16 October 2025: the textile EPR clock starts

The revised Waste Framework Directive, Directive (EU) 2025/1892, entered into force on 16 October 2025. Member states have 20 months to transpose (to around June 2027) and 30 months to establish textile and footwear EPR schemes (to around April 2028), with an extra year's grace for micro-enterprises, per ERP's summary of the new textile rules. Two member states are ahead of the wave: the Netherlands has operated textile EPR since 1 July 2023, and France has a long-standing textiles filiere within its IDU system.

30 March 2026: the Commission's PPWR guidance

The Commission published its PPWR guidance document and FAQ (press release IP/26/664). The documents clarify but do not amend the regulation, and the FAQ is updated on a rolling basis. Worth bookmarking as the canonical interpretation aid ahead of August.

The main event

12 August 2026: the PPWR applies, and Germany switches laws the same day

Regulation (EU) 2025/40 applies generally from 12 August 2026. For platforms and fulfilment providers this is the date the obtain-and-assess duties in Article 45(4)-(6) and 45(7)-(8) bite EU-wide. The same day, Germany's Packaging Law Implementation Act (VerpackDG) is scheduled to enter into force, replacing the VerpackG; LUCID remains, with a duty to adapt to the EU register format within 18 months of the pending implementing decision, per Gleiss Lutz's analysis.

Around 1 October 2026: the authorised-representative decision

A deregulatory item to watch: the Commission proposed suspending the authorised-representative obligation for EU-established companies until 2035 across several waste streams; Parliament's draft report (2025/0395(COD)) would limit the relief to micro and small enterprises, with a decision scheduled for 1 October 2026, per ecosistant's continuously updated PPWR tracker. Registration duties and platform verification are untouched either way.

The long tail: 2027 and 2028

2027: registers everywhere, formats in motion

EPR registration and reporting under PPWR Articles 44-45 phase in during 2027, with national producer registers to be available in each member state by 2027. The implementing act defining the registration format was due by 12 February 2026 and, per Reverse Logistics Group's analysis, had still not been adopted as of late March 2026, so national adaptation (including LUCID's 18-month runway) stretches deep into 2027. Practically: register interfaces and data formats keep changing for at least another year after the PPWR applies.

Around April 2028: textile EPR schemes in every member state

The 30-month WFD deadline lands, and every member state must have a textile and footwear EPR scheme running, per ERP's timeline. For platforms selling fashion, that is a new stream, and a new register, in every country at once.

2027-2028+: the Digital Product Passport approaches

The DPP delegated act for textiles is expected in 2027 with application from around 2028 onward, per Carbonfact's DPP tracker, with delegated acts carrying an 18-month minimum lead time, per Renoon's explainer. Further out, one law firm, Greenberg Traurig, expects national packaging databases such as LUCID to be superseded by an EU-level registry by 2029; that is a forward-looking reading, not settled law, but it signals the direction: more machine-readable, more centralised, more checkable.

For completeness, the PPWR's own later waves, all set out in EUROPEN's compilation of obligations:

• Harmonised labelling from around August 2028.
• Deposit-return systems by 2029.
• Recyclability classes and recycled-content minima from 2030.
• The 50 percent empty-space cap for e-commerce packaging from 2030.

What the calendar means operationally

Every entry above ends the same way: another register to check, another stream to map, another date after which "we did not know" stops working. Platforms that built packaging verification for August 2026 will rebuild it for textiles by 2028 unless the verification layer is built to absorb new registers as they land. That is the design brief EPR Clear is built against: one API, every stream, every register, as they land, with the live coverage matrix showing exactly what is wired today.

Stay ahead of the calendar: get a free exposure scan to see where your seller file stands against the registers in force today, or explore the EU register map to see what is coming next.

Run the verification workflow as a service

Registration checks per seller, stream and member state, continuous revocation monitoring, and a timestamped evidence log that is your best-efforts record.