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PPWR-EPR  ›  Checklists  ›  Direct-to-Consumer
Interactive EU27 work engine

Selling directly to the EU end user? Build the route before you ship.

Determine whether the sale is truly direct-to-consumer, identify the packaging EPR Producer country by country, resolve registration and EPR representation, connect the national system, prepare packaging data, handle regulatory funding and retain the evidence that proves the work was done.

EU27 country-awarePPWR applies · 12 Aug 2026Own webshop ≠ marketplaceBrowser-local workspace
01 · Confirm the route

Direct sale first. EPR analysis second.

This checklist is for a business supplying packaged goods directly to an EU end user through its own webshop or another direct-sales channel. If an independent importer/reseller opens the EU commercial chain, or a marketplace intermediates the transaction, use the appropriate market-entry or marketplace workflow instead.

Selling entity & transaction

Record the legal entity actually making the direct offer or supply.

Use legal establishment, not a VAT number or fulfilment warehouse.
A warehouse can matter operationally, but it does not replace the Producer analysis.
Direct-sales channel
For a cross-border direct end-user sale, Article 3(15)(c)–(d) can make the foreign seller the Producer. Record the actual conclusion rather than assuming it from the factory or brand.
Resolve Producer status ↗Open EU Market Entry ↗

Fulfilment service provider test

PPWR Article 45(7)–(8) creates a separate information/verification route where a qualifying fulfilment service provider is used. A parcel carrier alone is not automatically an FSP.

FSP resultSelect the services above. The legal definition normally requires at least two listed services, no ownership of the goods, and excludes postal/parcel/freight transport-only services.
Own webshop rule. Article 45(4)–(6) duties imposed on providers of online platforms are not automatically imposed on a seller merely because it operates its own webshop. If you use a qualifying fulfilment service provider, Article 45(7)–(8) can still apply separately.
Local-first workspace. Non-secret factual data is stored in this browser. It is not an authority filing, PRO submission or secure statutory archive. Never enter passwords, API keys, private keys, 2FA recovery codes, card-authentication data, bank-login credentials or portal secrets.
02 · Destination countries

Direct selling is analysed at the destination.

Select every Member State where the end user is located. Each destination loads its reviewed national register, system/PRO, reporting route and EPR-representation summary. The EU cross-border Producer rule is then applied to your transaction facts instead of treating all foreign sales alike.

0 destinations selected
DTC legal baselineA seller established in another Member State or a third country that makes packaged products available for the first time directly to end users in a destination Member State can fall within PPWR Article 3(15)(c)–(d). For an EU-established cross-border Producer, Article 45(3) currently requires a destination-country EPR authorised representative. For a third-country Producer, the Member State's national rule must also be applied.
Select at least one destination country to build the DTC country matrix.
03 · Work list

Follow the direct-sales chain in order.

The engine keeps route qualification, Producer status, EPR AR, registration, system/PRO participation, packaging data, fulfilment-provider evidence, reporting/funding/payment and the final DTC evidence file as separate work records. One registration number never closes the rest.

Phase
DTC work readinessNo active items
Confirm the route and select a destination country to generate the work list.
04 · Verify & evidence

Done means the action happened and the proof exists.

Open each work item, read the controlling EU and country rule, record what actually happened and retain the strongest evidence reference normally available. Drafts, quotes and unchecked assertions do not automatically prove registration, system participation, representation, filing or payment.

Choose an item in the work list to open its verification record.

Retain the DTC evidence file

Reference the Audit Evidence workspace rather than turning this page into an uncontrolled file repository.

Audit evidence ↗
05 · DTC readiness

Know what blocks the first direct shipment.

A destination becomes READY FOR DTC ACTIVATION only when every blocking item is VERIFIED COMPLETE or validly NOT APPLICABLE. This is operational work readiness. It is not a declaration of legal compliance.

No destination scope yet

Confirm the DTC route and select one or more Member States.

Local workspace

Reuse compatible non-secret Company Data, Packaging Data and Audit Evidence facts stored in this browser. Local data is not authority submission or statutory archival.

No compatibility scan run yet.

Export / handoff

Export factual scope, work states, national-rule references and evidence references for internal handoff or audit preparation.

Download notice. This is a checklist preparation / evidence file. Download does not mean submitted, accepted, approved, registered, verified by an authority or PRO, or legally compliant.
06 · Legal & country sources

EU rule first. National operating route second.

The source registry separates the PPWR Producer/AR/FSP baseline from the destination-country register, EPR system and reporting sources. An own webshop is not treated as an online-platform provider merely because it sells online.

Select a destination country to load the source registry.
Current-law note · 29 August 2026. PPWR applies from 12 August 2026. Article 45(3) remains in force. COM(2025) 982 / 2025/0395(COD), which proposes suspending part of that rule until 2035, is still an ongoing legislative procedure and is not treated as adopted law.