EPR and PPWR on marketplaces: where listing blocks are really coming

Three levels of marketplace readiness

September 2026 shows three distinct levels of maturity among the major platforms. Knowing which group a marketplace belongs to tells you how urgently you need to act.

• Level 1 — active enforcement: Amazon, TikTok Shop and, in selected areas, Zalando. Missing data can already cost you sales.
• Level 2 — infrastructure and rollout: Kaufland, eBay, bol.com and Zalando for further markets. Platforms are collecting data, building validation or officially announcing consequences.
• Level 3 — preparation: Allegro, eMAG and many other marketplaces. Automated checks are limited mostly by the state of national registries, but the verification process is already being built.

Amazon — the most advanced enforcement

Amazon has been developing its EPR mechanisms for years, so PPWR did not require building the process from scratch. Sellers can submit EPR/ERN numbers in the Regulatory Compliance section of Seller Central. Importantly, the option to submit a number is not yet available for every country — Amazon confirms it appears for markets where compliance verification has been launched.

For Poland, Amazon's communication is much more direct: the platform informed sellers about the need to obtain an ERN number for packaging and indicated that failing to start registration before 12 August could result in listings being removed in Poland.

The practical conclusion: do not wait for a warning in Account Health. If you are an EPR-obligated producer in a given country, registration should be in place regardless of whether the submission field is already active.

TikTok Shop — a missing number can deactivate your listing

TikTok Shop has published one of the most concrete instructions on EPR Packaging and PPWR. A packaging producer should obtain a valid EPR number on every required market, appoint an authorised representative where required, join a PRO and submit the number through Seller Center.

The key part is the consequence of non-compliance: TikTok Shop states that a non-compliant listing can be deactivated and, once a valid number is submitted and approved, reactivated.

This is the shift from educating sellers to a real mechanism: number → verification → permission to sell.

Zalando — a concrete blocking date: 1 January 2027

Zalando Partner is currently among the most transparent marketplaces regarding its EPR schedule. Numbers and other EPR data are submitted through zDirect. For packaging, data submission was previously available for Germany, France and Spain, and since 12 August 2026 the rollout has covered further markets, including Poland, Belgium, Denmark, Finland, Hungary, Lithuania, Slovakia and Sweden.

The most important date is 1 January 2027: Zalando officially informs that if a partner does not submit the required EPR data, their assortment will be blocked.

This is especially relevant for the fashion industry, where — beyond packaging EPR — obligations for batteries, textiles and other streams can also apply. Zalando already has experience with actually blocking products in the battery area: platform rules state that battery products remain deactivated until compliance is verified against the national register or by Zalando itself.

eBay — infrastructure ready, listings can be hidden

eBay already supports adding Packaging EPR registration numbers at account level: the seller selects a country, chooses the Packaging category, enters the number and confirms the packaging complies with the relevant requirements.

The key information concerns the consequence: eBay officially states that listings may be hidden from buyers in countries where the packaging registration number is missing or invalid.

However, in September 2026 we cannot yet confirm mass blocking of PPWR-related listings across all EU countries. Treat eBay as a platform with an enforcement mechanism in place — not as proof that mass blocks are already happening everywhere.

Kaufland — EPR is already part of the Seller Portal

Kaufland Global Marketplace has implemented a dedicated EPR Compliance section in its Seller Portal. The seller selects a country and EPR category, enters the registration number and submits it for review. In addition, compliance with the obligations arising from Article 45 PPWR is confirmed in the legal texts.

The level of implementation still depends on the market. Kaufland currently requires packaging EPR numbers for markets including Germany, Poland, France and Spain, while for countries such as Czechia, Slovakia, Austria, Italy or the Netherlands the number is not always yet required to keep selling on the platform.

That leads to an important distinction: the absence of a required field in the Kaufland panel does not mean the absence of a legal EPR obligation in that country.

bol.com, Allegro and eMAG — preparing, not blocking (yet)

bol.com officially admits it is not yet running active, mass verification of PPWR registrations, because the relevant verification system is not yet available. At the same time, in August 2026 the platform informed partners that it will check compliance in the future and that non-compliance may affect the ability to sell products. Its general EPR rules already state that products covered by producer responsibility can only be sold when the relevant requirements are met — and that non-compliant assortments can be removed.

Allegro confirms that a missing EPR number currently does not block sales — for a technical reason: EU countries are still adapting their registries to PPWR. But the target model is already clear. Allegro announces that once the registries are ready, it will check the EPR number for every country the seller ships to, before enabling sales. In September 2026 Allegro also started a cooperation with Interzero to handle EPR formalities for exporting sellers.

eMAG has published detailed PPWR information: producer registration, EPR fulfilment, an authorised representative where required, and submitting compliance data to the platform. The platform openly admits that full verification is not yet possible because public producer registers and official interfaces are not fully operational — so today the basic requirement is self-certification, with verification to be extended as registries come online.

Temu, AliExpress and others — don't assume blocks without proof

For OTTO, compliance requirements have existed for a long time: participation in a packaging system under the German VerpackG, ZSVR registration and WEEE information are all part of partner requirements. However, there is no sufficiently strong official confirmation that OTTO has launched a new, mass listing-blocking mechanism based solely on PPWR — so it should not be placed in the same category as Amazon, TikTok Shop or Zalando.

For Temu and AliExpress, the honest status is: monitoring and existing compliance requirements. Treat claims like "Temu already blocks offers" with caution until an official announcement or sufficiently credible confirmation of such a process appears.

Article 45: why mass verification is coming

This is probably the most important part of the whole picture. PPWR does not leave verification solely in the hands of the platforms. Article 45 creates a framework in which marketplaces must collect information about producers and their EPR compliance, while the EU is working on a harmonised format for producer registries.

In current Commission implementing documents, the systems are expected to enable automated processes and mass verification of producer registration numbers and EPR certificates.

This explains why some marketplaces are not yet blocking offers. The problem is not always a lack of will on the platform's side — the complete infrastructure on the side of individual countries is still missing. Once the registries become interoperable and numbers can be checked automatically, enforcement can accelerate dramatically.

What a cross-border seller should do now

The biggest mistake today would be to assume: "the marketplace hasn't blocked me yet, so I don't have to do anything." Legal obligation and marketplace enforcement are two different levels. The duty may already exist even though the marketplace cannot technically check it yet.

A cross-border seller should build a map: country × marketplace × EPR stream. For every market, establish:

• Is the company a producer in the meaning of EPR/PPWR?
• Is packaging EPR registration required?
• Is an authorised representative required?
• Does the product additionally fall under WEEE, batteries, textiles or another EPR stream?
• Which numbers have been obtained, and where do they need to be submitted?
• Is the marketplace already verifying the number?
• Which packaging must be reported — product, grouped and shipping packaging?
• Do we have material and weight data plus PPWR documentation?

Who owns the shipping packaging under marketplace fulfilment?

The last question in the map is particularly important. For example, Zalando states that with ZFS it takes responsibility for the shipping packaging it adds, while responsibility for the product packaging remains with the relevant EPR producer. bol.com describes a similar split of responsibility for Logistics via bol.

In practice, this means your packaging data model must separate product packaging from fulfilment packaging — and you must know exactly which party reports which component in which country.

The takeaway: don't ask "is the marketplace blocking?" — ask "when will it start?"

EPR is ceasing to be an obligation that marketplaces merely inform sellers about. Increasingly, it is becoming a technical condition of access to a given market: no valid registration number means no visibility for your offers.

For cross-border sellers this means EPR registrations, authorised representatives, reporting and packaging data should be part of the expansion process before launching a new country — not an action taken after receiving a warning from a marketplace.

How EPRPilot helps

EPRPilot gives you exactly that map in one place: registrations and deadlines for every EU market, packaging data at component level linked to each SKU and country, and reporting per market — so when a marketplace asks for your EPR number, you have it verified, submitted and tracked instead of scrambling through spreadsheets.