- PPWR applies EU-wide from 12 August 2026
- Battery capacity must be marked from 18 August 2026
- France: business packaging now in scope, Triman ends in 2028
- Luxembourg and Belgium: show the disposal fee openly
- Switzerland follows from 2027
A box with three self-printed light modules heads to France. Bubble wrap, one carton, one label. Sounds like an ordinary shipment. That is the exact moment you become a producer under French packaging law, possibly under battery law too, and in 2026 several of the rules that then apply to you are changing at once.
I have written elsewhere about the German side of extended producer responsibility. Anyone who wants electrical equipment, batteries and packaging sorted out for Germany will find it in the article on the deadlines and pitfalls of 2026. This piece is about what happens at the border. Because that is where a lot of hobbyists, modellers and photo sellers get caught off guard: the obligation does not end at the German customs post. It starts all over again in the destination country.
Why the border simplifies nothing
Extended producer responsibility, EPR for short, comes down to this: whoever first places a product on a national market helps pay for its later disposal. That holds for packaging, for batteries and for electrical equipment, and it holds country by country. You can be cleanly registered in Germany and still be an unregistered producer in France, Poland or Luxembourg the moment your parcel lands at a customer there.
For a small run of self-printed parts, a handful of decals or a used lens, that sounds like bureaucratic madness. In practice much of it only bites above thresholds or through professional marketplaces. But those very thresholds are falling in 2026, country after country. So it pays to know where the journey leads before the first fine arrives.
What shifts EU-wide in 2026
Two dates set the rhythm. On 12 August 2026 the core provisions of the new EU Packaging Regulation take effect, the PPWR, Regulation (EU) 2025/40. It replaces the old 1994 packaging directive and harmonises much of what each country used to handle on its own. Shortly after, on 18 August 2026, the next stage of the EU Battery Regulation (EU) 2023/1542 kicks in, among other things the duty to mark the capacity visibly, legibly and indelibly on every battery.
The crossed-out wheelie bin marks electrical equipment and batteries across the EU. Source: European Union, Wikimedia Commons, public domain.
Three movements run through almost every country:
Thresholds are falling. Many countries used to exempt small quantities, Ireland for example below ten tonnes of packaging and one million euros in turnover. Under the PPWR these de minimis limits disappear piece by piece. In Norway the one-tonne packaging threshold already fell on 1 July 2025, and since then foreign senders have to register there too.
Reporting categories are being harmonised. In future everyone reports under the same scheme from Annex II of the PPWR. The catch: most countries will only adopt these adjustments from 2027, because annual reports are mostly affected. 2026 is the transition year, with old and new law running side by side.
Marketplaces become the enforcement layer. France, the Netherlands and Italy already require platforms to check whether a seller is registered. Sell without a number, and you get flagged faster than before.
France: the biggest chunk
If one country means work in 2026, it is France. Three things change at once.
First, business packaging enters scope for the first time. Until now only household packaging had to be reported. There is now a dedicated filière for emballages professionnels, registration is possible from summer 2026, and the relevant specification, the cahier des charges, has already been published in draft. It applies to anyone selling to commercial end users in France. The reporting categories are expected to follow around June 2026. For anyone selling B2B into France, that means a household-packaging registration alone may soon no longer be enough.
Second, the Triman marking is being phased out. The little sorting logo with the stick figure stays mandatory until 11 August 2028. From 12 August 2028 the harmonised European marking applies and replaces the Triman, with the delegated act on it due on 12 August 2026. Stock carrying the old marking may be sold off until 12 August 2031. Anyone printing packaging or instructions for the French market should have the switch on their radar now, not only in 2028.
The Triman logo tells French consumers that packaging belongs in separate collection. Source: Ministère de l’Écologie (France), Wikimedia Commons, CC0.
Third, batteries: anyone shipping battery-containing products to France, so power packs, chargers or mini compressors with a built-in cell, has to register there once shipments start. New is the duty to name an authorised representative in the country. The deadline for naming one runs until autumn 2026, and without a representative the registration is closed. Italy, Portugal, Greece and Spain already have this duty, and France is now following.
Pitfall: spare parts. France grades disposal fees on devices by whether batteries are removable and whether spare parts are made available. Anyone selling spare parts for devices, say for carriers or small machines, lands in that assessment faster than they think.
Luxembourg and Belgium: the visible fee
Article 74 of the EU Battery Regulation introduces the so-called visible fee, the disposal cost shown openly. The idea: at the point of sale the end customer should see what the later disposal of the battery costs. Exactly how is regulated a little differently in each country, and that is precisely what makes it error-prone.
In Luxembourg the advance disposal costs have to be shown separately when a new battery is sold, plus a note on the sales invoice. Anyone running a physical shop in the country also has to put up posters. For pure online sellers without a sales floor the poster duty falls away, the separate disclosure remains.
In France the costs must be shown at the point of sale, to consumers and distributors alike, but not on the invoice there.
In Belgium inspections are strict. Anyone who fails to show the fee on a B2B invoice risks a 150 euro penalty per case, and a blanket line such as “all disposal fees included” is expressly not enough. The figure has to be specific.
Netherlands and Belgium: declaration of conformity and new packaging
On packaging both countries are introducing a declaration of conformity. In the Netherlands it is meant to cover all packaging, including stock already on the shelf: the producer issues it, importers and retailers have to check that it exists. In Belgium it arrives from August 2026, though responsibility and the submission route are not yet finally settled.
On top of that, scope is growing. In the Netherlands coffee pods and tea bags count as packaging from 12 August 2026, coffee capsules from 1 January 2027. Belgium follows on coffee pods, tea bags and capsules from 12 August 2026 and adds fruit and vegetable labels from 2028, with a ban on non-compostable labels. The Dutch 50-tonne threshold still applies in 2026, and once it falls under the PPWR a simplified report is planned for smaller producers below 10,000 kilos. For most hobby senders this stays below the threshold for now, but the direction is clear.
Poland: shipping, but no number yet
Poland is a growth market, and that is exactly where the typical gap opens up: goods go out before the registration is complete. The country is also planning a state-run packaging take-back system, with details expected for 2026. Anyone selling into Poland should finish the registration for packaging and batteries before the new system reshapes the frame. Shipping without a completed registration is no condition to sleep soundly on for long.
Denmark: batteries for outsiders too
Since Denmark transposed the EU Battery Regulation into national law, non-Danish companies are registrable too once they sell to end users. It used to apply only to Danish firms. On packaging the EPR has been in force since 2025, with an eight-tonne threshold and an eco-modulation on a traffic-light system. For the German small sender Denmark is no longer a blind spot, but a country to keep an eye on the moment cells or batteries travel in the parcel.
Switzerland: not in the EU, still in scope from 2027
Switzerland is not in the EU, so the PPWR does not apply there. Even so the country is following: the Swiss packaging ordinance is set to enter force in stages from 1 January 2027, starting with single-use packaging from 2028. Anyone selling regularly into Switzerland should track the federal timetable. There is still lead time here, but the direction is set.
Three terms worth knowing
Eco-modulation. The disposal fee no longer follows mere quantity, but material and recyclability. Easy to recycle gets cheaper, hard to recycle more expensive. In the Netherlands the bonus for good design can reach almost half the eco-fee, but only against proof. For small quantities the detailed report often only kicks in above thresholds, in France for example only above 500,000 sales units a year for household packaging.
Authorised representative. Anyone not established in a country increasingly needs an official representative there to handle the registration and the correspondence with the authorities. For batteries this is already mandatory in several countries, and France joins in 2026.
Visible fee. The disposal cost shown openly, described above. Not a new cost block, but a transparency duty that, depending on the country, has to appear on the invoice, at the point of sale, or both.
Deadline overview
| Date | What applies | Where |
|---|---|---|
| 1 Jul 2025 | Packaging de minimis threshold dropped | Norway |
| 12 Aug 2026 | Core PPWR provisions in force | EU-wide |
| 12 Aug 2026 | Coffee pods and tea bags as packaging | Netherlands, Belgium |
| 12 Aug 2026 | Delegated act on marking expected | EU / France |
| 18 Aug 2026 | Battery capacity marking mandatory | EU-wide |
| Summer 2026 | Registration for business packaging possible | France |
| Autumn 2026 | Deadline for battery authorised representative | France |
| 1 Jan 2027 | Coffee capsules as packaging | Netherlands |
| 1 Jan 2027 | Packaging EPR enters force in stages | Switzerland |
| 11 Aug 2028 | Last day of Triman duty | France |
| 12 Aug 2028 | Harmonised EU marking replaces Triman | France |
| Apr 2028 | Textile EPR systems must be in place | EU-wide |
Quick check: the remaining countries
| Country | Situation in 2026 |
|---|---|
| Germany | Systems stable, no new breaks (details in the earlier article) |
| Austria | Three streams established, voluntary opt-out available |
| Czechia | All three streams registrable, well bedded in |
| Slovenia | Electrical and packaging possible, batteries not yet |
| Spain | Packaging registration much simpler, NIF in days not weeks |
| Italy | Packaging registration required when selling via marketplaces |
| Ireland | Threshold removed for packaging, small producers now in |
| United Kingdom | Own rules, third-party registration for UK distributors no longer possible |
Reading the picture
On balance 2026 brings less a change of course internationally than a tightening. The big lines have stood for years, and now the exemptions that used to shield small senders are falling away. Three questions stay open and are worth watching: how hard the individual countries actually enforce, whether the marketplaces handle their new checking duty strictly or loosely, and how much of the promised harmonisation really ends up looking the same everywhere. By summer 2026 many details should sharpen, especially around French business packaging and the national registers.
In practice, for anyone selling across the border, it comes down to this: first check where you ship, then clarify the thresholds in the destination country, and when in doubt register before the parcel goes out. Anyone shipping the odd single item usually stays below the radar. Anyone shipping regularly and in volume into several countries should work through the list above.
Legal status as of 31 May 2026, not legal advice. The exact obligations depend on the product, the destination country and the quantity sold.
If you want to dig deeper
I took apart the German side, with the ElektroG, the BattDG and the packaging register, in the article “Extended Producer Responsibility: Deadlines and Pitfalls 2026”. The international changes gathered here come from a specialist workshop in spring 2026, cross-checked against the original texts of the PPWR (EU 2025/40) and the Battery Regulation (EU 2023/1542) as well as the publications of the national bodies. Anyone who needs the exact wording will find the legal acts on EUR-Lex under the CELEX numbers cited above.
