EPR documentation and verification is becoming increasingly critical in light of the new European Packaging Regulation. With the entry into force of Regulation (EU) 2025/40 and its direct application starting August 2026, companies across Europe will be faced with stricter documentation and control obligations.

EPR documentation is becoming a reliable and, above all, essential management tool for audits by marketplaces and other entities within the supply chain. Anyone planning to place packaging on the market must in future keep their data in a structured, verifiable and complete manner.

What is the regulatory basis for EPR verification?

With the new Packaging & Packaging Waste Regulation (PPWR), the EU is replacing the previous directive with a directly applicable regulation for organized and environmentally friendly waste management. In this context, EPR documentation is becoming a central component that should contribute to a Europe-wide standardization of requirements.

In February 2026, a standardized data set was introduced for all EU member states, whose processes must now align with it. This structure will form the foundation of EPR documentation in the future and defines exactly which data fields are to be reported. For companies, this means that for future EPR documentation, specific data requirements must be observed – and it is no longer just about the EPR registration number. Data models, master data, responsibilities and audit trails will also change in the further course. For you, this means – react quickly and proceed in a structured manner.

This makes documentation technically more precise and at the same time more susceptible to formal errors. Therefore, a clean organization and a structured approach are needed in this sensitive transition phase. As a service provider, we are happy to help you with this.

Which control authorities ensure EPR documentation?

One of the biggest changes concerns the control function of platforms and logistics service providers. EPR documentation is becoming a central topic for marketplaces such as eBay, Amazon or even Temu and connects directly to the increased control obligation of online marketplaces.

In marketplace audits, EPR documentation must be carefully recorded and regularly checked so that targeted measures can be taken in the event of violations, such as blocking an account or certain offers. The necessary data here includes registration confirmations, system participation, numbers per country and much more. All these factors can be checked by marketplaces, for example through seller compliance portals and other digital solutions. The only important thing here is that a fundamental check takes place.

Fulfillment service providers are also obliged to monitor their clients’ EPR documentation through measures such as SOPs, checklists, responsible persons, etc. If no relevant information is available here, these service providers may take appropriate measures and reject orders.

What is meant by audit-proof data requirements?

The data requirements for EPR documentation go far beyond simple quantity reports. In addition to quantitative information, consistency, traceability and documentation quality are moving to the fore. The specific data must be prepared in such a way that it can withstand audits at any time and, above all, meets the requirements of laws such as the Packaging Act.

The comprehensive data requirements affect both EU-based companies and third-country traders who deliver directly to end consumers in the EU. Especially for international distribution models, centrally managed EPR documentation is therefore essential to avoid double reporting or gaps. In this way, EPR for textiles, EPR for mattresses and many other areas are to be secured across the board.

Authorized representatives and cross-border responsibility

One of the most profound changes affects so-called remote sellers – i.e. companies without a physical location on site or within the EU. Companies that place packaging on the market in an EU state without being established there require an authorized representative in the destination country. In the further process, this representative takes over important tasks such as EPR documentation and thus ensures compliance.

With this step, EPR documentation is expanded in a targeted manner and requires a differentiated consideration of each individual target market. This primarily prevents the uncontrolled export of goods from distant foreign countries.

How do you prepare for EPR documentation 2026?

Companies should use the coming years to systematically review their EPR documentation. In addition to technical adjustments, close coordination between compliance, IT, logistics and accounting is required. This is the only way to develop a structured and seamless process in the long term that meets the requirements of the new 2026 regulations.

EPR documentation is thus evolving from an administrative obligation to a strategic compliance factor. Companies that switch and adapt their data structures early reduce risks and create transparency along the entire supply chain.