PPWR Article 45 explained: what marketplaces must verify from 12 August 2026

If you run an online marketplace that lets third-party sellers reach EU consumers, Article 45 of the Packaging and Packaging Waste Regulation gives you a dated, checkable duty: obtain each seller's producer-register registration before you activate them, and assess whether what they gave you is complete and reliable. This page sets out exactly what the article says, who is in scope, what best efforts means in practice, and how the new duty stacks on top of the national verification laws many platforms are already subject to.

When the PPWR applies

The PPWR is Regulation (EU) 2025/40. It was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025, and applies generally from 12 August 2026 after an 18-month transition. As a regulation it applies directly in every member state, with no national transposition needed, replacing the 1994 Packaging Directive.

Article 45(4): what you must obtain before activating a seller

Under Article 45(4), providers of online platforms that allow consumers to conclude distance contracts with producers must obtain, prior to allowing a producer to use their services, two things, as itemised in EUROPEN's compilation of PPWR obligations:

1. Proof of registration, with the number

Information about the producer's registration in the Article 44 producer register of the member state where the consumer is located, together with the registration number or numbers. Registration is per member state, so a seller shipping to consumers in five countries needs to evidence registration in five national registers, and packaging is only one stream among several. The EU producer register map sets out which register answers for which country and stream.

2. A self-certification of EPR compliance

A self-certification by the producer that it only offers packaging for which the extended producer responsibility requirements of Article 45(1) and 45(3) are complied with. The self-certification does not replace the registration evidence; it sits alongside it.

The best-efforts assessment, and a note on paragraph numbering

Obtaining the data is only half the duty. Upon receiving it, and before activating the seller, the platform must make best efforts to assess whether the information is complete and reliable. One drafting wrinkle is worth knowing: DIHK's PPWR guidance note cites this assessment duty as Article 45(6), while EUROPEN presents it as the paragraph immediately following 45(4). Until you are quoting the Official Journal text verbatim, the safe citation is Article 45(4)-(6) PPWR. What is not in doubt is the substance: obtain first, assess before activation.

Best efforts is not defined in a vacuum. The formula mirrors the trader-traceability logic of Article 30 of the Digital Services Act, which normalised verify-before-onboarding as a platform discipline, as the US International Trade Administration's briefing notes in the adjacent product-safety context. And Article 44(13) requires every national producer register to be publicly accessible, free of charge and machine readable. Put those two together and the practical standard of care writes itself: check the official register, and keep evidence that you did, with a timestamp.

Who is in scope

The duty attaches to providers of online platforms within the scope of Section 4 of Chapter III of the DSA (Regulation (EU) 2022/2065) that let consumers conclude distance contracts with producers. In plain terms: if your platform hosts third-party sellers and EU consumers buy from them through you, plan on being in scope. Fulfilment service providers carry a parallel obtain-assess-suspend duty under Article 45(7)-(8), which we cover in a dedicated explainer for fulfilment providers. Distributors, too, must verify that producers are registered before making packaging available.

This is a floor being raised, not a new idea

Several member states already impose marketplace verification duties, so August 2026 is less a starting gun than a harmonisation of duties that already exist:

• Germany has prohibited distributing packaged goods from unregistered producers since 1 July 2022, with marketplaces required to verify LUCID registration, per GvW's analysis, and a valid WEEE number since 1 January 2023. Our guide to checking a LUCID number walks the German check step by step.
• France has made marketplaces liable for third-party sellers' EPR since 2022 under the AGEC law, with a per-filiere unique identifier (IDU) to record for every seller. See the French IDU explained.
• Austria has required marketplace operators to check sellers' EPR compliance and exclude non-compliant sellers since 2023.
• For batteries, Regulation (EU) 2023/1542 applies EPR registration per member state from 18 August 2025, and Amazon announced deactivation of non-compliant battery offers in Germany, the Netherlands, Poland and Sweden.

Enforcement and what non-compliance costs

The PPWR leaves enforcement national: member states must set effective, proportionate and dissuasive measures, which in practice means the existing national packaging and waste regimes, including delistings and market restrictions. The reference points are severe: fines up to EUR 200,000 per case plus sales bans in Germany, and up to EUR 15,000,000 or 10 years' imprisonment on indictment in Ireland. The full picture is in EPR penalties by country.

Where the fine print still moves

Two open items are worth a compliance lead's attention. First, the implementing act on the format of producer-register registration and reporting was due by 12 February 2026 and, per Reverse Logistics Group's analysis, had still not been adopted as of late March 2026, so register formats will keep shifting into 2027. Second, the European Commission published a PPWR guidance document and FAQ on 30 March 2026 (press release IP/26/664); the guidance clarifies but does not amend the regulation. Article 45 itself is not in flux: the obtain-and-assess duty applies from 12 August 2026. The dated view is in the EPR compliance calendar.

FAQ

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.