Where the EU rules stand in September 2026: GPSR, EPR and LUCID, VAT OSS, the withdrawal button and the new customs charge, with the dates that apply in Germany, France and Poland.
Author: Borys Terlecki · marketplace sales and implementations at Commercraft · updated: September 2026
In short
GPSR has applied since 13 December 2024: every product needs a responsible economic operator in the EU, and platforms take down offers without safety information.
Sales to consumers in other EU countries run on a single €10,000 threshold and the OSS procedure, Poland's KSeF e-invoicing starts on 1 February and 1 April 2026, and from 1 July 2026 parcels from outside the Union pay €3 in duty for each tariff line.
In Germany three registrations decide whether your offers stay live: LUCID (packaging), stiftung ear (WEEE) and BattDG (batteries), and from 12 August 2026 the PPWR applies across the Union.
On a European marketplace, whether your offers stay live now rests on a complete set of registration numbers and product-page information, alongside the product itself. One missing EPR number can block an account, and a wrongly stated promotional price can end in an intervention by a consumer authority.
This guide collects the rules that actually reach the seller in 2026, with the date each one starts and a note on what has moved in recent months. Several dates still circulating in trade articles are out of date.
Legal position: September 2026. This is a guide for sellers. It does not replace legal or tax advice and we are not a law firm. In regulated areas such as VAT, EPR and product compliance we take clients through the process step by step and work with law firms and tax advisers. Before a decision that costs money, confirm the detail with a lawyer or an adviser.
The GPSR regulation (EU) 2023/988 on general product safety has applied since 13 December 2024. In practice it means that:
Commission guidance published on 19 November 2025 settled the two points sellers asked about most. The responsible operator’s “electronic address” is an email address or a contact form, not the seller profile on the platform. An accident goes to the Safety Business Gateway when the product has caused death or serious injury. The guidance also comes with a template for technical documentation.
The marketplace carries its own duties under article 22: it shows buyers the seller details and takes down offers where safety information is missing. Platforms therefore enforce a complete data set earlier and harder than any authority does, with the national market surveillance bodies behind them.
Sources: regulation (EU) 2023/988; European Commission guidance C(2025)7699 of 19 November 2025, with commentaries by Noerr and Taylor Wessing, November 2025.
The Digital Services Act (DSA, EU regulation 2022/2065) has applied in full since 17 February 2024. Article 30 sets the know your business customer rule. Before it lets you sell, a marketplace has to collect and verify your company data. That runs from the commercial register entry and address through to the bank account and a self-certification, and part of it goes on public display to consumers. Sellers who leave the file incomplete get suspended.
Keep one folder with all of it: registration details, tax number, address, contact and bank account. Onboarding then takes days instead of weeks.
Platforms take this seriously because they answer for weak checks themselves. In May 2026 the European Commission fined Temu €200 million for DSA breaches. The Digital Fairness Act, aimed at dark patterns and purchase pressure, had no published text as of September 2026, and the Commission talks about a proposal by the end of 2026.
Sources: regulation (EU) 2022/2065, article 30; European Commission decision on Temu of 28 May 2026; Commission statements on the Digital Fairness Act, position as of 15 May 2026.
When you sell to consumers in other EU countries, a single threshold of €10,000 a year applies across the whole Union:
The ViDA reform, adopted in March 2025, spreads the changes over several years. OSS corrections start in January 2027. A single VAT registration for sales across the Union follows in mid-2028. A mandatory deemed supplier model for some platforms arrives in January 2030, and intra-EU B2B e-invoicing with digital reporting comes in July 2030.
Poland has moved earlier on e-invoicing. Its national system, KSeF, is mandatory from 1 February 2026 for the largest taxpayers and from 1 April 2026 for everyone else. If you sell through a Polish entity, your invoices have to pass through that system, and your integrator or ERP has to support it.
We do not register VAT or OSS ourselves. We map the process and show where a registration will be needed before stock moves into a warehouse abroad.
Sources: the OSS procedure, European Commission; the ViDA package adopted in March 2025; KSeF deadlines of 1 February and 1 April 2026 under the Polish e-invoicing act.
The Union is removing the duty exemption for consignments worth up to €150. From 1 July 2026 until 1 July 2028 a temporary customs duty of €3 applies to each tariff line in a consignment worth up to €150 arriving from outside the Union. Product identifiers in customs declarations become mandatory on 1 November 2026, and from 1 July 2028 these consignments move to normal duty rates handled through the EU Customs Data Hub.
If you import in small batches or ship directly to customers from outside the Union, the charge lands straight on unit margin. On low-value baskets it can decide whether a category works at all, so it belongs in the model before the season starts.
Source: EU customs reform, European Commission (taxation-customs.ec.europa.eu), announcements of 13 November 2025 and 8 June 2026.
Extended producer responsibility is the most common reason offers vanish from German platforms. Three registrations decide whether you start at all:
At EU level, regulation (EU) 2023/1542 sets the battery timeline. CE marking has applied since 18 August 2024, and supply chain due diligence was pushed back in 2025 to 18 August 2027. A carbon footprint declaration for industrial batteries follows on 18 February 2026. On 18 February 2027 the battery passport arrives for industrial batteries above 2 kWh, EV batteries and batteries for light means of transport, and portable batteries must become replaceable.
LUCID has no volume threshold and bites from the first shipment. The application takes a few minutes, and the registration number arrives right after you submit it. Amazon blocks offers without an EPR number in Germany, the Netherlands, Poland and Sweden, so this gets closed before sales start rather than after the first block.
Sources: VerpackG and the LUCID register (verpackungsregister.org); ElektroG and stiftung ear; BattDG in force since 7 October 2025 (Umweltbundesamt, Händlerbund); regulation (EU) 2023/1542 and the amending regulation (EU) 2025/1561; Amazon EPR requirements, position as of September 2026.
Regulation (EU) 2025/40 entered into force on 11 February 2025 and applies from 12 August 2026. Three things matter from that date: designing packaging for recycling, the ban on double walls and false bottoms that inflate volume, and substance limits covering lead, cadmium, mercury and PFAS in food packaging. The producer also has to appear in the national packaging register.
Two dates get mixed up and are worth separating. The 50% empty space limit for e-commerce parcels only starts on 1 January 2030 rather than in August 2026. Harmonised packaging labels arrive in 2028, and recycled content and reuse targets in 2030.
Sellers established outside the Union have to appoint an EPR authorised representative in every EU country they sell into from 12 August 2026.
Source: regulation (EU) 2025/40 and European Commission material (environment.ec.europa.eu), read on 11 August 2026.
The Omnibus Directive (EU 2019/2161) has applied across the Union since 28 May 2022. With every price reduction you state the lowest price from the 30 days before the promotion. The Consumer Rights Directive (2011/83/EU) gives the buyer 14 days to withdraw from the contract without giving a reason, and failing to inform them of that right extends the period by 12 months.
The newest change is about how withdrawal happens. From 19 June 2026, under directive 2023/2673, a shop has to provide a digital withdrawal button or form and confirm receipt to the consumer. On a marketplace the platform usually handles this, while in your own shop the duty sits with you.
The right to repair runs on a separate track. Directive (EU) 2024/1799 was due to be transposed by 31 July 2026. Poland is late with it. At the start of September 2026 the draft act had still not reached parliament there, so the duties towards buyers will arrive later and probably with a short lead time.
Sources: directives (EU) 2019/2161, 2011/83/EU, 2023/2673 and (EU) 2024/1799; status of the right to repair transposition in Poland as of 2 September 2026.
The Empowering Consumers directive (EU 2024/825) applies from 27 September 2026. Generic phrases such as “environmentally friendly” or “climate neutral” come off offers unless evidence stands behind them, and so do eco labels that no independent body has verified.
This covers everything the buyer sees: the offer title, the bullet points, the description, the images on the product page and advertising banners. Reviewing the catalogue in one pass is worth the time, because platforms are starting to pick these phrases up automatically.
The wider Green Claims Directive never came into force. The European Commission announced its withdrawal on 20 June 2025 and the negotiations were halted. Where you read that Green Claims bans something, the information is out of date.
Sources: directive (EU) 2024/825; European Commission announcement withdrawing the Green Claims proposal, 20 June 2025.
Products covered by EU harmonisation law need CE marking and a declaration of conformity, and mandatory information, warnings and instructions have to be in the official language of the country of sale. For Germany and Austria that means German, which is why translating product pages counts as compliance work rather than cosmetics.
If you sell furniture, wood products or paper, the deforestation regulation (EUDR) comes on top. The dates moved again in December 2025. It applies to large and medium companies from 30 December 2026 and to micro and small companies from 30 June 2027. Printed products are out of scope. In practice it means due diligence statements and geolocation data for where the raw material came from, which is work on the supplier side as much as yours.
Sources: EU harmonisation law and language requirements on the German and Austrian markets; the EUDR regulation and the Council of the EU decision of 18 December 2025 postponing the dates.
France is the market where platforms ask for EPR numbers most often after Germany. Kaufland Global Marketplace currently requires EPR registrations in three countries: Germany, Poland and France. If French sales are in the plan, schedule the packaging and electronics registrations alongside the platform launch, because the offer will not go live without them and the registration runs in weeks rather than days.
Poland works on an entry in the BDO register before the first sale, an annual report by 15 March and a product fee calculated on the weight of packaging placed on the market. The new extended producer responsibility model expected on 1 January 2026 did not arrive. The ministry postponed it, so the existing rules still apply, and single-use plastic charges have been in place since 2024.
Sources: BDO and the Polish packaging rules; the Ministry of Climate statement postponing the new EPR model (PAP, 18 December 2025); Kaufland Global Marketplace EPR requirements, September 2026.
Several deadlines still circulating in trade articles have already moved. The corrections that matter in September 2026:
The dates to keep in the calendar:
| Date | What starts | Who it reaches |
|---|---|---|
| 1 February 2026 | KSeF, mandatory e-invoicing | the largest taxpayers in Poland |
| 1 April 2026 | KSeF, mandatory e-invoicing | all other taxpayers in Poland |
| 19 June 2026 | digital withdrawal button (2023/2673) | own shops across the EU |
| 1 July 2026 | €3 duty per tariff line in consignments up to €150 | imports from outside the EU, until 1 July 2028 |
| 31 July 2026 | transposition deadline for the right to repair (2024/1799) | member states, Poland late |
| 12 August 2026 | PPWR: design, ban on false bottoms, substance limits | anyone placing packaging on the market |
| 27 September 2026 | EmpCo: end of unproven green claims | offer and advertising copy |
| 1 November 2026 | mandatory product identifiers in customs declarations | imports from outside the EU |
| 30 December 2026 | EUDR: due diligence and geolocation | large and medium companies, wood, furniture, paper |
| January 2027 | ViDA: OSS corrections | cross-border B2C sales |
| 18 February 2027 | battery passport, replaceable portable batteries | industrial batteries above 2 kWh, EV and light means of transport batteries, portable batteries |
| 30 June 2027 | EUDR: due diligence and geolocation | micro and small companies |
Further out, harmonised packaging labels arrive in 2028 and a single VAT registration under ViDA in mid-2028. The deemed supplier model for some platforms starts in January 2030, together with intra-EU B2B e-invoicing in July 2030 and the empty space limit on 1 January 2030.
Sources: the legal acts named in the sections above; the table reflects the position on 18 September 2026.
We are not a law firm and we do not issue legal opinions. We work in the space between the rule and the product page. We check which registrations the market you are entering asks for. We assemble the files for LUCID, stiftung ear or a national register. The responsible operator details and safety information go onto the offers, and VAT questions we handle together with your tax adviser.
Before you start on a new market you get a list of what has to be ready, and in which order. Packaging registrations are often the longest part of an entry, so they come first, before the feed runs.
For the German-speaking markets the operational side sits in our guides to selling on Amazon.de and to cross-border logistics.
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Borys Terlecki – marketplace sales and implementations at Commercraft. He previously worked on the operator side of marketplace platforms (Mirakl, Munich) and today onboards brands on marketplaces in Poland and the DACH region and runs their accounts.
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