EU packaging rules for online stores: what to register when you ship abroad

On 12 August 2026 the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, often called PPWR) started to apply. It replaces the old packaging directive, and because it is a regulation, the same text applies directly in every EU country.

Most of the regulation is about how packaging is designed. One part hits small online stores straight away: when you sell to consumers in another EU country, you can count as the producer of the packaging you send there. That includes the product’s own packaging and the shipping box, tape and filling.

What changed for online stores

• Registration is per country. Each EU country keeps its own register of packaging producers. There is no single EU-wide register (Article 44).
• Register first, sell second. A producer may not make packaging available in a country for the first time until it, or its authorised representative, is registered there (Article 44(4)).
• A local representative. A producer that sells into a country where it has no establishment must appoint an authorised representative for producer responsibility there (Article 45(3)).
• Reporting. Registered producers report the packaging they put on that market every year, by material.

Are you a packaging producer?

You are very likely affected if all three are true:

1. you sell to consumers, not only to businesses,
2. you ship to at least one EU country other than the one where your company is registered,
3. the parcel carries packaging: product packaging, a shipping box, a mailer bag, tape or filling.

Selling only in your own country? Then nothing new happens at the border, but your home country’s packaging rules still apply. In Lithuania that means the GPAIS register (see below).

The authorised representative rule is still in motion

This is the part that worries small sellers most, and the part that may still change:

• In December 2025 the European Commission proposed to pause the representative requirement for producers established in the EU until 1 January 2035 (COM(2025) 982).
• The pause has not been adopted. EU governments left these provisions out of their June 2026 negotiating position, and the European Parliament was still voting on its own position in October 2026.
• Until a change is published in the EU’s Official Journal, the rule applies as written. Sellers based outside the EU were never covered by the proposed pause.

So the safe reading today: an EU store that ships to consumers in another EU country needs a representative there, and should keep an eye on whether the pause is adopted.

What to do, step by step

1. List the countries you really ship to. In Shopify admin, open Markets in the main menu and Settings → Shipping and delivery to see every country you sell and deliver to. Then check your orders: export them from Orders → Export and count orders by the Shipping Country column.
2. Decide country by country. For a country with a handful of orders a year, compare the cost of registration and a representative with what you earn there. Stopping delivery to that country until you are ready is a legitimate choice. You can remove it from the shipping zone or deactivate its market.
3. Register in each country you keep. Each country has its own register and its own rules. Germany, for example, already required foreign online stores to register in LUCID and has no minimum quantity: one parcel to a German consumer is enough.
4. Appoint an authorised representative where you have no company. Packaging compliance schemes and specialised firms offer this as a service, usually as a yearly fee per country.
5. Join a packaging scheme and report. Usually you also have to join a producer responsibility organisation, or a take-back system, and report the packaging you sent, by material and weight.

Keep packaging data in Shopify

Every report asks how much packaging, of which material, went to each country. Shopify doesn’t track packaging for you, but you can make the yearly report a calculation instead of a guess:

• Write down each packaging type you use (box sizes, mailer bags, product boxes) with its material and weight in grams.
• Store each product’s packaging in product metafields, for example material and grams. Create them under Settings → Metafields and metaobjects → Products.
• Export orders by country once a year. Units per product multiplied by packaging grams give the weight per material and country.

Selling from Lithuania: GPAIS

In Lithuania, producers and importers register in the producer and importer list of GPAIS, the national product, packaging and waste accounting system, and keep packaging records there. According to the GPAIS FAQ:

• A company that is not required to be VAT-registered in Lithuania is exempt from registering and keeping packaging records in GPAIS. This doesn’t apply to sellers of deposit-return packaging.
• Companies that put up to 0.5 tonnes of packaging on the market a year don’t pay packaging fees, but still have to register.
• A new packaging item must be entered within 5 working days of supplying it to the Lithuanian market.

For sellers from other countries shipping into Lithuania: in a notice on 2 September 2026, GPAIS said the system can’t yet register a foreign producer through an authorised representative. The changes are in progress, and the procedure will be published on the GPAIS website.

What comes later

The registration rules apply now. The packaging design rules arrive in stages: harmonised sorting labels on packaging from 2028 at the earliest, and from 2030 limits on empty space in shipping and e-commerce packaging, plus recyclability requirements. If you are ordering a large stock of boxes now, it’s worth asking your supplier how they fit the 2030 rules.

Common mistakes

• Thinking the shipping box doesn’t count. A shipping box sent to a consumer is packaging that ends up as household waste, and it counts.
• Assuming one registration covers the EU. It doesn’t: every country keeps its own register.
• Waiting for the pause. It may still come, but until it is published, the representative rule applies.
• Forgetting small markets. One order a month to Latvia or Estonia still makes you a producer there.
• Assuming Shopify handles it. Shopify, your carrier and your payment provider don’t register your packaging for you.