The new wave: from legal texts to the product
For years, e-commerce compliance was a matter of documents: contracts, policies, disclosures. The 2024–2026 wave has moved the bar to the product and to operations: the product must have a responsible party in the EU, the store an accessible interface, and the packaging a registered producer. What the three regimes have in common is that compliance is verifiable from the outside — and that enforcement has been delegated to the marketplaces.
Practical guidance
A single supplier-contract clause lightens the documentation side of all three burdens: the manufacturer should undertake to provide the GPSR information, product safety documents, and packaging data.
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GPSR/PPWR representative structures, an accessibility baseline, and packaging registrations — in a single project, before the August 2026 wave.
GPSR: the product’s address in the EU (13.12.2024)
Every consumer product sold from outside the EU requires a responsible person established in the EU; the name, address, and e-mail details must appear with the product and in the listing. Traceability and recall processes have also been updated. Details are in our GPSR record.
Accessibility: the store itself (28.06.2025)
With the EAA/BFSG, B2C web stores — wherever they are established — have come under an accessibility obligation: an interface built on EN 301 549, an accessibility statement and compliance across the entire ordering flow. Exception: microenterprises providing services (fewer than 10 persons and an annual turnover or balance-sheet total not exceeding €2 million) are exempt from the accessibility requirements (Art. 4(5) EAA; § 3(3) BFSG). Crossing the threshold ends the exemption. In Germany, a violation means fines of up to €100,000 and a new wave of Abmahnung (cease-and-desist) letters. For a scope test, see the EAA/BFSG record.
Packaging: LUCID today, PPWR tomorrow (12.08.2026)
For shipments to Germany, LUCID registration and participation in a dual system (licensing) are mandatory today, and the register is public. Breach of the registration duty carries a fine of up to €100,000, and breach of the system-participation duty up to €200,000 (§ 36 VerpackG). The PPWR applies from 12 August 2026. Producers established in the EU must appoint an authorised representative for each Member State in which they are not established; for producers established in third countries such as Türkiye, whether to impose that requirement is left to each Member State (Art. 45(3)). Because the producer registers are to be set up within 18 months of the entry into force of the Commission implementing act, the timetable must be followed country by country. The roadmap is in our packaging record.
A single plan for the seller
Efficient management of the three workstreams comes together in a single project: (1) an inventory of the product range and target countries; (2) setting up representative/responsible-person structures under a single roof; (3) adding the mandatory blocks to listing templates; (4) writing information-and-documentation commitments into supplier contracts; (5) bringing the store interface up to the accessibility baseline. This plan is the product-compliance module of our e-commerce focus area; for the supply side, our supplier contract architecture is in place.
Conclusion
In e-commerce, the EU has moved to a regime of “the seller may be far away, but responsibility will be close by.” A seller who starts preparing today for the August 2026 wave gains both uninterrupted selling capability and a supply chain that is strong at the negotiating table.
