Knowledge
Product compliance in the EU — and the software that carries it
Product compliance means: a product meets every requirement EU law places on it before it is placed on the market in a Member State. Which requirements those are depends on the product — the same coffee grinder can be subject to packaging law, electrical equipment law, substance restrictions, product safety and battery law at the same time. This page explains what those obligations are in detail, whom they affect and what information a company has to gather for them.
What is product compliance?
EU product compliance is not a single law but the sum of the requirements several legal acts place on the same product. They apply alongside one another, not one after the other: an article can be packaging, electrical equipment, a carrier of restricted substances and a consumer product at the same time.
It applies before placing on the market
The order is prescribed: first meet the requirements and complete the registrations, then sell. The law generally does not provide for putting this right afterwards.
It applies per target country
EU regulations apply directly in all Member States. What is implemented nationally — registers, competent bodies, thresholds — differs from country to country.
It applies per product, not per company
Two products of the same company can be subject to entirely different sets of obligations. The classification decides, not the industry.
Who does it apply to?
The obligations follow from the role a company has in relation to the product — and the same company can have different roles for different products.
| Role | When it arises | What follows from it |
|---|---|---|
| Manufacturer | Whoever manufactures a product or places it on the market under their own name or trade mark. | The full set of obligations: conformity assessment, technical documentation, declaration, labelling, registration. |
| Importer | Whoever places a product from a third country on the market in the EU. | Checks before placing on the market, own details on the product, retention of the documentation. |
| Reseller | Whoever makes a product available without being the manufacturer or the importer. | Duties of care: check whether labelling and documents are present, and do not pass the product on if they are missing. |
| Fulfilment service provider | Whoever stores, packs, addresses or dispatches without owning the goods. | Own obligations, among others under the market surveillance regulation; in some cases they move into the manufacturer role. |
| Authorised representative / responsible person | Appointed by a company without an establishment in that country or in the Union. | Representation before an authority or register; the role is appointed, not assumed automatically. |
Supplying a marketplace does not make you a distributor in the legal sense — the marketplace has its own obligations and in practice increasingly asks its sellers for evidence.
Which requirements apply?
Ten legal acts share the same information about the same components. That is why it pays to keep them together rather than apart.
| Regulation | Legal act | What matters |
|---|---|---|
| PPWR | Regulation (EU) 2025/40 | Recycled content under Art. 7, recyclability under Art. 6, labelling under Art. 12, declaration of conformity under Art. 39 and technical documentation under Annex VII. |
| EPR | national, per Member State | Registration in the national register, regular quantity reporting and fees to a scheme. |
| DPP / ESPR | Regulation (EU) 2024/1781 | A machine-readable data set accessible through a data carrier. What a passport must contain per product group is only set by delegated acts. |
| Batteries | Regulation (EU) 2023/1542 | Passport obligation for batteries for light means of transport, electric vehicles and industrial batteries above 2 kWh from 18/02/2027. |
| WEEE | Directive 2012/19/EU | Under Art. 16 a separate national producer register in every Member State. |
| RoHS | Directive 2011/65/EU | Limit values per homogeneous material, not per component. |
| REACH | Regulation (EC) 1907/2006 | Above 0.1 % by mass of a candidate-list substance, information and SCIP notification duties apply. |
| GPSR | Regulation (EU) 2023/988 | Responsible person in the Union under Art. 16, traceability; harmonised law displaces it only in part. |
| EUDR | Regulation (EU) 2023/1115 | Geolocation of the production areas, risk assessment, due diligence statement. Core obligations from 30/12/2026 and 30/06/2027 respectively. |
| EmpCo | Directive (EU) 2024/825 | Environmental claims and sustainability labels. Twelve new per-se prohibitions in Annex I of Directive 2005/29/EC; applies from 27/09/2026 — see page. |
| Textiles | Regulation (EU) 1007/2011 | Fibre composition in the official language of every Member State in which the product is made available. |
How the checks, evidence and approvals behind this are technically secured and kept traceable is described under Data security and enterprise security.
What does the company have to gather?
Almost every requirement comes down to the same five kinds of data. Keep them properly once and you serve several regulations at the same time.
1. Product master data
Item number, name, category. The category decides which sets of rules come into question at all.
2. Components and materials
A component consists of homogeneous materials. RoHS measures at the material, REACH at the article, the PPWR at the packaging component — one and the same survey serves all three.
3. Supplier information
Recycled content, material details, declarations, test reports. They originate at the supplier and have to be requested there.
4. Evidence
Documents with version, date of issue, expiry date and review note. Evidence without a version and an expiry date is of little use in an inspection.
5. Registrations per target country
Which register is required in which country and what its status is — separately for packaging, electrical equipment and batteries.
And: the basis of every statement
Every assessment comes with the article reference it rests on and the point in time. Without that it is no longer possible to explain later why something counted as fulfilled.
The process in five steps
Three examples
Bluetooth-Lautsprecher
Electrical equipment with a built-in battery in a carton: PPWR for the packaging, WEEE for the device, RoHS for the materials, battery law for the cell, REACH for the substances, GPSR for safety. Five registers in five countries is nothing unusual.
Coffee in a pouch
Coffee is a commodity under Annex I of the EUDR: geolocation of the production area and a due diligence statement from 30/12/2026 — on top of the PPWR for the pouch and food law for the contents.
T-Shirt
Textile labelling under Regulation (EU) 1007/2011 in the official language of every target country, GPSR for product safety, PPWR for the outer packaging — and REACH if a candidate-list substance is above the threshold.
How PPWR-Ready helps with this
You create your products once — with category, components and substances. From that the platform derives which of the ten regulations apply, what is fulfilled and what information is missing; every statement carries the article reference it rests on.
One data basis instead of ten spreadsheets
One product, one supplier, one piece of evidence — shared by all regulations.
Requests instead of chasing by phone
Missing details go out as a request to the supplier. They answer through a link without creating an account.
Per target country, not across the board
The EU compliance map shows, per target country, which registration is required there and what its status is.
Unchecked means unchecked
What has not been checked for a country is reported as unchecked — not as unobjectionable.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)
- Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements (ESPR)
- Regulation (EU) 2023/1542 concerning batteries and waste batteries
- Directive 2012/19/EU on waste electrical and electronic equipment (WEEE)
- Directive 2011/65/EU on the restriction of the use of certain hazardous substances (RoHS)
- Regulation (EC) 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
- Regulation (EU) 2023/988 on general product safety (GPSR)
- Regulation (EU) 2023/1115 on deforestation-free supply chains (EUDR), Art. 38 as amended by Regulation (EU) 2025/2650
- Regulation (EU) 1007/2011 on textile fibre names
- The German Packaging Act (VerpackG) and the LUCID register of the Zentrale Stelle Verpackungsregister foundation
Technical status: 2026-09-20 · Responsible for the technical information: Gabriel Hahnel, Hahnels Amsterdam (operator of PPWR-Ready). This page is not legal advice.
Frequently asked questions about EU product compliance
What is EU product compliance?
EU product compliance means a product meets every requirement EU law places on it before it is placed on the market in a member state. Which ones apply depends on the product — the same coffee grinder can be covered at once by packaging law (PPWR), electrical equipment law (WEEE), substance restrictions (RoHS, REACH), product safety (GPSR) and battery law. These separate rules often ask for the same details about the same components.
What is EPR — extended producer responsibility?
Extended producer responsibility means whoever places a product on the market stays co-responsible for its disposal — financially and organisationally. In practice: registration in a national register, regular volume reporting and fees paid to a scheme. In Germany the Zentrale Stelle Verpackungsregister foundation runs the LUCID register for packaging; in the Netherlands Verpact fills that role. Electrical equipment and batteries have their own registers in each member state.
Do I need software, an authorised representative, or both?
These are two different things. PPWR-Ready is software for EU product compliance: it keeps your products, suppliers, evidence and target markets, and shows which requirements apply and what is missing. An authorised representative, by contrast, is a named person or company that represents you before an authority in an EU country. Roles such as the “responsible person” under Art. 16 GPSR or an authorised representative are kept and documented in the platform — but PPWR-Ready does not sell that representation. The software tells you where such a role is required; whom you appoint is your decision.
What happens if I do not register?
The consequences differ from Member State to Member State, because penalties are governed nationally. Two points are documented. First, registration is expressly a precondition for placing on the market in several legal acts — under Art. 16 of the WEEE Directive, for instance, every Member State must keep a producer register, and in Germany the Packaging Act prohibits distribution without a LUCID registration. Second, marketplaces increasingly check their sellers’ registration themselves and block listings without proof. We do not quote specific fine amounts here — they differ by country and procedure.
How does PPWR-Ready actually help?
You enter your items once — with category, components and substances. From that the platform derives which of the ten sets of rules apply, what is met and which detail is missing; every statement carries the legal reference it rests on. Missing details go out as a request to the supplier, who answers through a link. The EU compliance map shows, per target country, which registration is required there. Whatever has not been checked for a country is shown as unchecked — not as cleared.
Read on
PPWR guide
The packaging regulation in detail: rates, discounts, the reporting process and eighteen dates with article references.
Digital product passport
What the Ecodesign Regulation prepares and which part of it already has a binding date today.
Services
What the platform does per product, per supplier and per target country.
Conformity declaration
What an EU declaration of conformity must contain, who issues it and which documents support it — explained across legal acts (page in German).
Regulations covered
Compliance is expanding. Your data does not have to.
New frameworks build on the same core of products, components, suppliers and evidence. No separate tool per regulation, no second data entry.
PPWR — packaging
Regulation (EU) 2025/40. Recycled content under Art. 7, recyclability under Art. 6, labelling under Art. 12, declaration of conformity under Art. 39.
EPR — extended producer responsibility
Registration in the national register, regular quantity reporting and fees to a scheme. LUCID in Germany, Verpact in the Netherlands.
The LUCID register explained (in German) · Markets & registrations
DPP — digital product passport
Ecodesign Regulation (EU) 2024/1781 (ESPR). So far only the battery passport is bindingly dated, to 18/02/2027. PPWR-Ready prepares the passport.
Batteries
Regulation (EU) 2023/1542. The passport obligation covers batteries for light means of transport, electric vehicles and industrial batteries above 2 kWh.
WEEE — electrical and electronic equipment
Directive 2012/19/EU. Under Art. 16 every Member State requires its own national producer register. A LUCID registration does not cover that.
RoHS — substance restrictions
Directive 2011/65/EU. The limit values apply per homogeneous material, not per component — which is why the platform keeps materials below component level.
REACH
Regulation (EC) 1907/2006. Above 0.1 % by mass of a candidate-list substance, information and SCIP notification duties apply.
GPSR — product safety
Regulation (EU) 2023/988. Responsible person in the Union under Art. 16, traceability. Art. 2(1): harmonised law displaces the GPSR only in part.
EUDR — deforestation-free supply chains
Regulation (EU) 2023/1115. Seven commodities, geolocation of the production areas, due diligence statement. Core obligations from 30/12/2026 and 30/06/2027 respectively.
Textile labelling
Regulation (EU) 1007/2011. Fibre composition in the official language of every Member State in which the product is made available.
EmpCo — environmental claims
Directive (EU) 2024/825. Environmental claims on products and packaging need evidence. Applies from 27 September 2026.
Product compliance
One product. Every requirement that applies.
You create your products once — with category, components and substances. From that the platform derives which of the ten regulations apply, what is fulfilled and what information is missing; every statement carries the article reference it rests on.
Example product: Bluetooth speaker, category electrical equipment
| Regulation | Applies? | Why | State |
|---|---|---|---|
| PPWR | ja | sales carton, padding, film bag | complete |
| WEEE | ja | electrical equipment under 50 cm edge length | registration open per target country |
| RoHS | ja | electrical and electronic equipment | material information for 2 components missing |
| Batteries | ja | built-in lithium-ion battery | supplier information requested |
| REACH | ja | article containing plastic and solder | candidate list not yet checked |
| GPSR | ja | consumer product, partly harmonised | responsible person appointed |
| EUDR | no | no Annex I commodity in the product | — |
| Textiles | no | not a textile product | — |
| DPP | preparatory | battery passport expected from 18/02/2027 | preparation under way |
| EPR | ja | packaging, electrical equipment and battery, per target country | 3 registrations open |
Components and substances hang off the product
Not in a second list. A material recorded for RoHS is also available for REACH and for the product passport.
Every statement carries its evidence
Every assessment carries its article reference, its timestamp and its evidence with it. What has not been checked for a country is reported as unchecked — not as unobjectionable.
One status instead of ten spreadsheets
The same items are now covered by packaging, substance, equipment, textile, battery and supply chain rules at the same time. Handle them separately and you maintain the same data several times over — and never see the whole picture.
Supplier compliance
Collect missing information from suppliers
Most missing information does not sit in your own house but with the supplier: materials, recycled content, declarations, test reports. PPWR-Ready requests it where it originates — and keeps the answer as evidence on the product.
Expiry date with reminder
A piece of evidence expires and nobody notices in time — that is exactly what the deadline tracking on the document prevents.
Weekly sanctions list screening
Your suppliers’ names are automatically screened against the EU sanctions lists.
EU compliance map
See per target country what is required there
EU regulations such as PPWR, GPSR or EUDR apply directly in every member state. Whatever is shaped nationally — registers, authorities, thresholds — differs by country and is kept per country in the platform.
Your EU compliance — sample account
Registered office: Germany · Target markets: France, Belgium, Netherlands, Austria
The figures come from a sample account with invented data. They show the processing status in the software, not the legal position of any particular company.
| Country | PPWR | EPR register | WEEE | REACH | GPSR | Open supplier information |
|---|---|---|---|---|---|---|
| Germany | met | registered in LUCID | met | met | met | 0 |
| France | met | registration open | open | open | met | 2 |
| Belgium | met | registered | met | open | met | 1 |
| Netherlands | met | registered with Verpact | met | met | met | 0 |
| Austria | evidence missing | registration open | not affected | open | met | 3 |
Clicking a country opens, inside the product, the list of requirements that apply there, the status of the registration and the products affected.
Product and market
What changes if I sell there?
Before market entry, the platform shows what an additional country means for your existing range: which products are affected, which requirements are added, which registration is required and which supplier information is missing for it.
One product across three target markets
| Market | State | What is missing |
|---|---|---|
| Germany | ready for sale | — |
| France | open | WEEE registration, recycled content of the outer packaging |
| Netherlands | ready for sale | — |
Add a market: Spain
Impact on the existing range:
- 128 products affected
- 4 additional regulations with their own national requirements
- 2 registrations before first placing on the market
- 11 missing supplier information
- 6 pieces of evidence that need a Spanish language version
Supply chain
Keep supply chain and regulatory origin apart
The transport route of goods says nothing about where they were produced. For the EUDR what counts is the production area, not the port the goods came through — which is why the platform keeps the two separate.
Goods route
Regulatory origin under the EUDR
Illustrative view without real coordinates. Production areas of real accounts are never shown publicly.
Deadlines
Which PPWR deadlines apply when
The PPWR has applied directly since 12/08/2026, but its individual obligations take effect in stages. The platform keeps eighteen dates with an article reference and checks, for each packaging item, which of them apply to it.
- 12.08.2026 — PFAS ban for food-contact packaging (Art. 5(5))
- 12.08.2026 — Declaration of conformity required (Art. 38, 39, Annex VIII)
- 12.02.2027 — EPR symbol digital only (Art. 12(9))
- 12.08.2027 — The 50,000 kg threshold falls away (PPWR producer register); Verpact names this date at the earliest
- 12.02.2028 — Empty space limit for sales packaging (Art. 24(4))
- 12.08.2028 — Labelling obligation (Art. 12 PPWR) & product passport (ESPR)
- 01.01.2030 — Minimum recycled content & market ban for non-recyclable packaging (Art. 6(3), Art. 7(1))
- 01.01.2038 — Only grade A or B may be placed on the market (Art. 6(3) subpara. 3)
All eighteen dates with article reference and consequence in the PPWR guide
Market Germany
Germany: LUCID and the Packaging Act
Anyone placing packaged goods on the German market must be listed in the LUCID register of the Zentrale Stelle Verpackungsregister foundation before the first placing, and hold a contract with a dual system. The PPWR applies alongside; electrical equipment and batteries have their own registers. PPWR-Ready tracks what each target country requires.
The German Packaging Act and the PPWR apply side by side
The PPWR (Regulation (EU) 2025/40) applies directly in all Member States. It does not replace the German Packaging Act at once but takes its place in stages; until then both sets of obligations exist side by side.
Separate registers for equipment and batteries
For electrical and electronic equipment Germany keeps its own producer register under the Electrical and Electronic Equipment Act, and another one for batteries. A LUCID registration does not cover these.
Registration before first placing on the market
The order is prescribed: first the registration, then the sale. The platform keeps the status per register and target country.