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Unlike VAT, GST or tariffs, there is no fee that gets paid before a package gets delivered.

The new PPWR is an environmental regulation, not a customs regulation. But it's consequences are significant.

The stated purpose of the regulation is to reduce packaging pollution and minimize raw material use by maximizing the use of recyclable materials.

The PPWR regulation covers:
1. how the package must be marked identifying the materials the package and the packing materials within are made from.
2. whether or not the packing materials are recyclable .
3. how certifying documents must be completed and filed by the shipper and to whom.
4. that the shipper must register with member states' environmental authorities .
5. that the shipper must record the weight of packing materials and submit a report to each receiving EU country annually .
6. that the shipper must pay an annual fee to each receiving country's environmental authority in order to help pay a portion of the recycling costs in that country.

The way the regulation reads, at least how I understand it, is that the documents, reporting and annual fees have to be done by an agent in the EU whom I am to hire. The filings have to be made annually in each EU country we ship to. I, as the shipper, must account for the weight of each packing material and report that information to the agent who in turn makes the appropriate filings with each EU country.

This is very different from how VAT, GST, tariffs or customs declarations are handled.

What is known is that a US vendor sending non-compliant packaging to the European Union faces immediate border blocks, product sales bans, and future financial penalties enforced by member states. Non-compliant boxes or materials cannot legally enter the EU market. Border agents can refuse entry to shipments missing proper environmental documentation or product tracking files.

Online sales platforms like Amazon or eBay can remove our product listings if I fail to submit valid compliance proofs or local waste registration numbers.

What's not clear at this point is exactly how the PPWR gets enforced and what actually happens if I try to ship a non-compliant package (package marked improperly) to an EU country.

The PPWR directs each country to determine their own actions in response to a non-compliant package. Some reports indicate that most countries are likely to issue a warning for the first offense. Other reports indicate that most countries are likely to reject the package and return it to the vendor at the vendor's expense. Yet other reports indicate that a country may seize and destroy the package.

We also don't know anything about agents in the EU, who they are, and what their costs might be.

At this point, I have yet to see anything authoritative about enforcement from any authoritative source.

In any event, we are not at all resourced to be able to hire an agent(s), capture package material weights per package per country, file annual reports or pay annual environmental fees to EU member countries.

More to follow as we learn more.