What is EPR? Why EU packaging rules matter when you shop small

You find a handmade bag from a small designer in Amsterdam. You live in Denmark. You add it to your cart and, suddenly, Denmark isn't available at checkout.

Why?

The answer might have nothing to do with shipping costs or the brand not wanting international customers.

It could be EPR.

Extended Producer Responsibility is one of those regulations most consumers will probably never hear about. But behind the scenes, it is changing the way businesses deal with packaging and waste across Europe—and for very small brands, the consequences can be surprisingly significant.

Here's what it actually means, without the legal language.

first: what is EPR?

EPR stands for Extended Producer Responsibility.

The basic idea is actually quite reasonable: if a company puts products and packaging onto the market, it should contribute towards the cost of dealing with that waste afterwards.

Imagine you order a dress online.

It might arrive inside a cardboard box, wrapped in tissue paper, with a shipping label and perhaps some protective packaging.

Eventually, all of that becomes waste.

Under EPR systems, businesses can be required to help finance the collection, sorting and recycling of the packaging they introduce into a country's market.

In other words, the responsibility for packaging doesn't necessarily end when your parcel reaches your doorstep.

why is the EU doing this?

Europe has a packaging problem.

Packaging represents around 36% of municipal solid waste in the EU, while approximately half of the paper and 40% of the plastics used in Europe are destined for packaging.

The EU's new Packaging and Packaging Waste Regulation (PPWR), which began applying on 12 August 2026, aims to reduce unnecessary packaging, encourage reuse and recycling, and make producers more responsible for what happens to packaging after use.

The principle is simple:

if you put packaging into the system, you should contribute to dealing with it.

The complicated part is how that works when a business sells across borders.

what happens when you order from a small brand in another country?

This is where things get interesting.

Imagine a tiny fashion brand in the Netherlands sells 50 pieces per year.

Most go to Dutch customers, but then someone in Germany discovers the brand on Instagram and orders a top.

The brand has now introduced packaging into the German market.

Depending on the applicable national EPR rules, selling into another European country can bring registration, reporting and financial responsibilities with it.

So while you see one parcel, the brand may see an entirely new compliance process.

And that's particularly significant for independent designers selling very small quantities.

and then there's the authorised representative

This is the part of the regulation that has caused particular concern for small European businesses.

Under the PPWR framework, a producer established in one EU country and selling packaged products directly to consumers in another Member State can be required to appoint an authorised representative for EPR in that country.

Think of an authorised representative as a local compliance contact acting on behalf of the brand.

For a large company selling thousands of products across Europe, this is another administrative process.

For an independent designer selling three dresses to that country in an entire year, it's a very different equation.

The European Commission itself has recognised that authorised-representative requirements can create significant complexity and barriers within the EU single market. It has proposed suspending the mandatory requirement for EU-based packaging producers until 1 January 2035, while it works towards less burdensome alternatives. As of August 2026, however, that proposal is still going through the EU legislative process, so the suspension should not yet be treated as final law.

why should customers care?

Because regulation eventually affects what appears in your shopping cart.

Imagine a designer makes €5,000 in annual sales.

They would love to ship throughout Europe. But if entering additional markets means researching separate EPR systems, registering with authorities, submitting reports, potentially joining recycling schemes and dealing with representation requirements, there comes a point where selling one €80 product into a country simply isn't economically viable.

The easiest solution?

Stop shipping there.

And that's where a regulation about packaging can unexpectedly become a question about access to independent fashion.

Large retailers can spread compliance costs across thousands or millions of orders.

A micro-brand can't.

does this mean EPR is bad?

Not at all.

The idea behind EPR is important.

Companies should take responsibility for the waste they create, and businesses that use enormous quantities of packaging should contribute to managing its environmental impact.

The problem is proportionality.

A multinational shipping millions of parcels and an independent designer shipping 30 shouldn't necessarily experience the administrative burden in the same way.

Good environmental regulation needs to make sustainable behaviour easier—not accidentally make it harder for the smallest businesses to participate in the European market.

And the EU appears to recognise at least part of this problem: its proposal to suspend certain authorised-representative requirements specifically describes reducing administrative burdens and unintended barriers in the internal market as part of its rationale.

so what could this mean when you shop independent?

The next time you discover a small European brand and notice that it doesn't ship to your country, there may be much more happening behind that decision than you realise.

It isn't always about expensive postage.

It isn't always because the brand doesn't want international customers.

Sometimes, a business with one designer, a sewing machine and a few dozen annual orders is navigating the same increasingly complex regulatory landscape as companies operating across the entire continent.

EPR is designed to make businesses more responsible for the waste they create.

That's a goal worth supporting.

But as Europe builds a more circular fashion economy, there's another question worth asking too:

How do we protect the planet without making it impossible for the smallest businesses to participate?

At Closet.eco, we believe those two goals shouldn't have to compete.