New EU Packaging Rules: What Amazon and Shopify Sellers Actually Need to Do

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Yo, European ecommerce sellers. Brussels has cooked up another compliance dish, and this one’s all about the boxes, jars, labels, and packaging you use to ship your beautiful products.

Meet the EU Declaration of Conformity for Packaging under the Packaging and Packaging Waste Regulation, better known as PPWR.

Sounds complicated? Sure does.

But before you start imagining expensive laboratories, mountains of certificates, and another consultant charging you for every single SKU, let’s break this bad boy down.

Because the actual requirements are more manageable than some sellers think.

First Things First: What Is This Declaration?

The EU Declaration of Conformity is a formal document in which the manufacturer declares that its packaging meets the applicable EU requirements.

It’s not a government-issued license.

It’s not automatically a certificate from some fancy testing laboratory.

It’s your documented statement that you’ve assessed the packaging and have the evidence to support its compliance.

The bigger change is that packaging compliance now comes with a more structured documentation process.

You need to identify the requirements, assess whether your packaging meets them, maintain supporting technical documentation, and issue the declaration.

Basically, Brussels wants the paperwork to prove you’ve done your homework.

Does This Apply Only to Foreign Sellers?

Nope, homie.

The requirements concern packaging placed on the EU market, regardless of whether the responsible business is based inside or outside the European Union.

That means European manufacturers and businesses importing packaged products can also have obligations.

Some businesses established outside particular EU countries may additionally need an authorised representative under national packaging rules.

But that’s a separate requirement.

Having an authorised representative doesn’t automatically replace the need for a Declaration of Conformity.

And neither does an existing packaging EPR registration.

Different obligations. Different paperwork.

Do You Need to Send Every Box to a Laboratory?

Here’s some good news.

The PPWR doesn’t automatically require every packaging item to undergo third-party laboratory testing.

For most packaging, conformity assessment follows an internal production control procedure.

That means the responsible manufacturer can assess conformity using appropriate technical evidence.

For example, if your packaging supplier provides reliable information about materials, composition, weight, chemical content, and technical properties, that information can support your assessment.

You still need sufficient evidence for the relevant requirements.

But you don’t automatically need to become a chemical engineer overnight.

Can You Just Trust Your Packaging Supplier?

Well, yes and no.

You can rely on appropriate supplier information, but you can’t blindly accept whatever somebody sends you.

Suppose your supplier claims a cardboard box meets the relevant standards.

Cool.

But you still need enough information to establish what the packaging contains, how it’s made, and which requirements apply.

Useful supplier documentation can include material specifications, weight, composition, relevant chemical information, test reports, and existing declarations.

The important thing is that the documentation actually matches the packaging you’re using.

If your supplier sends a certificate for one material while shipping you something different, that paperwork might not help much.

Wait, Are Heavy Metal Restrictions New?

No, player. They’ve been around for decades.

European packaging rules have restricted certain heavy metals since the 1990s.

The combined concentration limit for lead, cadmium, mercury, and hexavalent chromium is generally 100 mg/kg.

PPWR continues this longstanding restriction.

So sellers shouldn’t confuse the new documentation framework with the idea that every chemical restriction suddenly appeared in 2026.

What’s changing is the formal process for demonstrating and declaring compliance.

Do You Need One Declaration for Every SKU?

Now we’re getting to the money-saving part.

Imagine you sell 100 different products.

Do you need 100 separate declarations?

Not necessarily.

The relevant distinction is the packaging specification, not simply the number of products in your catalog.

Let’s say you sell seven varieties of honey, all packed in exactly the same 900-gram glass jar with the same metal lid and paper label.

Those products may be covered by one declaration identifying the common packaging specification, provided the applicable requirements and assessment support that approach.

So seven products don’t automatically mean seven declarations.

And 100 SKUs don’t automatically mean 100 paperwork headaches.

Nice, right?

But Don’t Get Too Excited

There’s an important catch.

You can’t necessarily combine every packaging component or variation into one giant declaration.

Consider a product that uses a glass jar, metal lid, printed label, protective wrapping, and an outer shipping box.

Different components can serve different packaging functions and carry different compliance considerations.

Primary packaging, secondary packaging, transport packaging, and ecommerce shipping packaging may need to be assessed separately depending on their characteristics and applicable rules.

Likewise, two packaging variants made from different materials might not share the same assessment.

The declaration needs to identify the packaging it covers clearly.

So don’t simply declare your entire packaging catalog compliant on one sheet of paper and call it a day.

What Exactly Is a Packaging Specification?

Think of it as the identity card for your packaging.

It describes the packaging in enough detail that somebody examining the declaration can understand exactly what’s covered.

That might include the packaging type, material composition, dimensions, components, or other relevant identifiers.

But PPWR doesn’t establish one universal rule saying every packaging variation must always have its own separate declaration.

Several packaging items can potentially be grouped when their characteristics and applicable requirements permit a common assessment.

The key is traceability.

Authorities need to understand which packaging the declaration refers to.

Do You Attach All Your Supplier Documents?

No.

And this is another distinction worth understanding.

The Declaration of Conformity is a relatively short, formal document based on the requirements in Annex VIII of PPWR.

The supporting technical documentation is a separate collection of records described in Annex VII.

That supporting file can contain specifications, supplier information, relevant test reports, and conformity assessments.

You generally keep those records available rather than attaching every document to the declaration itself.

Think of the declaration as the official statement and the technical documentation as the evidence behind it.

What If You Change Packaging Suppliers?

Let’s say you’ve used the same box for three years.

Then a new supplier offers the same packaging at a better price.

Do you need to rebuild all your documentation?

Not automatically.

The important question is whether the new packaging has the same relevant characteristics and whether the evidence still supports your existing conformity assessment.

If the new supplier provides equivalent packaging and appropriate documentation, you may be able to maintain the existing assessment after reviewing the new evidence.

But if the material, construction, chemical properties, or applicable requirements change, you’ll need to revisit the assessment.

Same principle applies whenever you redesign your packaging.

Changing a supplier isn’t necessarily a compliance disaster.

Ignoring the effect of that change could be.

How Long Do You Need to Keep These Documents?

Here’s where your filing system earns its salary.

PPWR provides different retention periods depending on the packaging category.

Single-use packaging: 5 years.
Reusable packaging: 10 years.

These periods apply to both the declaration and the supporting technical documentation.

So don’t create the document, email it to somebody, and then lose the file.

You may need to provide evidence years after the packaging entered the market.

A proper document management system suddenly sounds pretty attractive.

What About LUCID Registration in Germany?

Here’s another classic ecommerce compliance confusion.

LUCID registration and the EU Declaration of Conformity are not the same thing.

LUCID is Germany’s packaging register, and registration obligations arise under German packaging legislation.

The PPWR Declaration of Conformity serves a different purpose: documenting that packaging meets the applicable EU requirements.

One doesn’t automatically replace the other.

And contrary to some information circulating online, Germany’s LUCID registration number isn’t generally required to be printed on packaging simply because of Section 9 of the German Packaging Act.

That provision concerns registration, not a blanket obligation to print the registration number on every product box.

Packaging labeling requirements are a separate topic and need their own assessment.

So What Should Ecommerce Sellers Do Right Now?

Here’s the practical game plan.

Identify your packaging specifications. Start by identifying the packaging specifications used across your product catalog.
Contact your suppliers. Request the relevant technical information for each packaging specification.
Review compliance requirements. Assess the materials, chemical requirements, construction, and applicable obligations.
Organize your documentation. Prepare the supporting technical documentation and determine which packaging specifications can appropriately share a conformity assessment.
Prepare the declaration. Once the assessment is complete, prepare the Declaration of Conformity in the required format.
Keep everything up to date. Store the declaration and supporting documentation securely, and update them whenever relevant packaging characteristics or legal requirements change.

That process is much easier to manage if you standardize packaging across multiple products.

Fewer distinct packaging specifications can mean fewer separate assessments to maintain.

Need Some Help With the Paperwork?

Our partners at Packaging Compliance have developed a PPWR Declaration of Conformity generator designed to help businesses prepare the required document.

The tool guides users through the declaration fields and provides a live preview.

The company also works with Amazon sellers and online retailers dealing with European packaging compliance, including German LUCID and EPR requirements.

Its founder, Nadezda Walz, previously operated an Amazon FBA business herself, so she knows the seller side of these compliance headaches.

You can check out their Declaration of Conformity Generator and the supporting guidance.