Anyone selling online in Europe today has two acronyms on the desk, EPR and GPSR, and the temptation is to hand them to the legal team or to whichever consultant is around. I think that is a mistake. EPR and GPSR are not paperwork to clear once a year: they are the new entry ticket to the European market, and the person checking the ticket will more and more often be the marketplace. Those who treat these rules as product data, managed by operations alongside prices and stock, will keep selling without interruption. Those who treat them as documents to file away will sooner or later see their listings disappear at the worst possible moment.
What EPR and GPSR are, explained for sellers
GPSR is the European General Product Safety Regulation 2023/988, and it has applied since 13 December 2024 to almost every non-food product sold to consumers. It asks for two things that directly affect online sellers. The first is that every product has a responsible economic operator established in the Union, a person or a company an authority can knock on the door of. The second is that the online listing clearly shows who the manufacturer is, who the responsible person in the Union is, how the product is identified and which safety warnings come with it.
EPR, extended producer responsibility, starts from a different idea: whoever first places a product or its packaging on a country's market helps pay for and organise its end of life. It has existed for years for packaging, electrical and electronic equipment, batteries and other categories, and each Member State has applied it in its own way, with different registers, schemes and registration numbers. For packaging, the new European Regulation 2025/40, known as PPWR, has applied since 12 August 2026 and brings common rules where there used to be twenty-seven national versions.
There is one point many business owners discover late. Both rules look at the country where the product arrives, not the country where the company is based. A business shipping from Italy to customers in Germany, France and Spain is, for each of those markets, the producer of the packaging it leaves at the customer's door. Every country switched on with one click on a marketplace brings one more EPR registration, and therefore one more cost.
GPSR and marketplaces: why enforcement has already started
To see where GPSR is heading, look at the latest sweep of online marketplaces carried out by the European Commission and national market surveillance authorities between May and July 2026, with results presented on 7 September. Almost 1,700 listings of childcare and gym products were checked across 35 marketplaces. Only 58% showed the manufacturer's details, the responsible person in the Union and the product identification together. Authorities sent marketplaces 560 orders about non-compliant listings.
The figure that interests me most, though, is another one. 91% of the marketplaces checked were registered on the Safety Gate portal with a point of contact for authorities, up from 53% the year before. In twelve months the platforms have equipped themselves to receive notices and orders in an orderly way. When an authority asks for action on a listing, the marketplace now knows who must respond and how quickly.
In Italy the picture became stricter with Legislative Decree 78 of 2026, in force since 16 May, which aligned the Consumer Code with GPSR and extended sanctions beyond manufacturers and distributors to online marketplace providers. A platform that carries its own risk does one thing: it passes the risk on to the seller. It requires mandatory fields, blocks incomplete listings and suspends without much discussion. For sellers, the real danger is not so much the fine as the listing that disappears in November, in the middle of peak season.
EPR and packaging: what changes with the PPWR regulation
With PPWR, EPR on packaging becomes a European obligation with a common logic. A business selling at a distance into a Member State where it has no establishment must appoint, by written mandate, an authorised representative for EPR in that country. For a small company selling into ten countries that means ten mandates, ten contracts and ten fixed costs, even where volumes in some markets are tiny.
On this point the timetable is moving. In December 2025 the Commission proposed suspending the representative obligation until 2035. The European Parliament voted its position in October with 616 votes in favour, but limited the suspension to micro and small enterprises based in the Union, meaning fewer than 50 employees and under 10 million euro in turnover or balance sheet. Non-EU companies remain excluded, and every other EPR obligation, starting with registration and fees, stays in place. It is now up to the Council to adopt its own position, and only then can the final negotiation start. In the meantime the Commission has asked Member States to apply the rules pragmatically and to avoid sanctions.
The Commission also points out that businesses placing less than 10 tonnes of packaging a year on the market already enjoy exemptions and simplifications, and it encourages Member States and producer responsibility schemes to cut costs and red tape for small players. The underlying direction does not change, though. Once national registers are harmonised, and Member States will have 18 months to do so after the new common rules, marketplaces will have to ask for the EPR registration number before allowing a business to sell. It is the same pattern as GPSR: the platform becomes the checkpoint, and whoever lacks the right data does not get in.
The most common mistake with EPR and GPSR: treating them as legal paperwork
What I often see in companies that sell online is a siloed approach. The consultant prepares a dossier, someone signs a mandate with a representative, the PDF ends up in a shared folder and the topic is considered closed. Then a new country is opened, a product line is added, the box supplier changes, and nobody updates anything.
In my view EPR and GPSR should be treated for what they are, which is product data. Every catalogue item should carry the manufacturer, the responsible person in the Union, a unique identifier, the warnings in the languages of the countries where it is sold, the packaging materials and weights, and for each country the EPR registration number that covers it. If this data lives in the management system or in whatever feeds the sales channels, opening one more marketplace or country becomes a configuration. If it lives in a document, it becomes a project every time.
There is also a margin question, which has always mattered to me. EPR fees, the cost of the representative and the time spent keeping the data up to date are costs per country and per channel. They belong in the calculation before deciding to open a market, not after. A country worth a handful of orders a month can turn loss-making once these fixed costs are added up, and it may be better to serve it differently or not at all.
How to organise for selling online in Europe with EPR and GPSR in order
The first step is an honest map of the countries you actually sell into, looking at where the parcels arrive rather than where you think you are present. A marketplace often switches on sales in countries the company never consciously chose, and each of those countries brings EPR obligations and one more language for GPSR warnings.
The second step is closing the gaps country by country: EPR registration where it is missing, a representative where one is needed, and a responsible person in the Union for every product, which for an Italian company is often the company itself but for a non-EU brand distributed in Europe is not. It is also worth asking packaging suppliers for their conformity documentation, because PPWR requires it to be available and allows resellers to check it.
The third step is bringing everything into the catalogue, as structured fields rather than side notes, so that listings feed themselves on every channel. The fourth is giving someone in the company responsibility for this data, with time and budget, as you would for prices or stock. You do not need a department, you need a name.
Where I stand
EPR and GPSR are one of the best things that could happen to those who sell seriously in Europe. They raise the bar for everyone, including the sellers who until yesterday came in from outside without a responsible person, without registrations and without end-of-life costs, and who for exactly that reason could set prices nobody could match. The cost of complying is real, especially for small businesses, and European policy is right to reduce it. But whoever organises their data today will have a structural advantage when marketplaces start asking for the EPR number the way they ask for a VAT number today.
The question I would ask any business owner selling online is simple: who in your company is accountable today for the "responsible person in the Union" field of every product on sale? If the answer is "nobody" or "the consultant", that is where the work starts.
Francesco Luigi Ziccheddu, CEO & Co-Founder, BusinessLabs
CEO & Co-Founder of BusinessLabs. I have attended major international trade shows since 2015 and share here experiences and insights for online sellers.
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