EPR is not the only EU sustainability regulation affecting e-commerce brands. It operates alongside the Single-Use Plastics Directive, the EUDR deforestation regulation, and the CSRD — all of which have packaging, supply chain, or reporting implications. Understanding how they interact prevents compliance gaps and prevents double-handling of overlapping data requirements.
| Regulation | Acronym | Key packaging/product impact | Primary deadline |
|-----------|---------|----------------------------|-----------------|
| Packaging and Packaging Waste Regulation | PPWR | Recyclability, recycled content, DoC, re-use | August 2026 (ongoing) |
| Single-Use Plastics Directive | SUPD | Restrictions on specific plastic items | 2021–2025 (partially live) |
| EU Deforestation Regulation | EUDR | Due diligence for paper/board/soy/palm sourcing | Dec 2025+ |
| Corporate Sustainability Reporting Directive | CSRD | Sustainability disclosure for qualifying brands | 2025–2028 (phased) |
| Ecodesign for Sustainable Products Regulation | ESPR | Digital Product Passports for products | 2027+ |
| EU Green Claims Directive | EGCD | Substantiation of sustainability claims | 2026+ |
Each operates independently but shares data with the others. A brand's packaging sustainability programme ideally generates data that satisfies multiple reporting frameworks.
The EU's Single-Use Plastics Directive (EU 2019/904) was implemented progressively from 2021. Its key provisions:
The following single-use plastic items are prohibited from being placed on the EU market:
For e-commerce brands: If you sell any of these items, you cannot sell them in plastic form into the EU market. This is a product ban, not a packaging rule — it affects the items themselves, not just their packaging.
The SUPD also created EPR-like obligations for specific product categories:
Cigarette filters and fishing gear — EPR obligations (not directly relevant to most DTC brands).
Single-use plastic bottles — mandatory deposit return system requirements (PPWR Article 50 picks this up and extends it). Some member states (Germany, Netherlands) already have bottle DRS; others are implementing.
Packaging covered by SUPD Article 8: For single-use plastic food containers, cups, wet wipes, sanitary products, and tobacco products with plastic components, brands must:
This is separate from PPWR EPR but in most markets handled through the same PRO systems.
Interaction with PPWR: PPWR largely supersedes and harmonises SUPD's EPR provisions for packaging. Where SUPD applies to product categories (not just packaging), it remains independent.
SUPD's prohibition on oxo-degradable plastics catches brands that have marketed packaging with "oxo-degradable" or "oxy-degradable" additives — these are plastics with pro-oxidant additives that cause the plastic to fragment into microplastics. The EU determined this fragmentation is worse than conventional plastic. If any of your packaging uses oxo-degradable additives, it is non-compliant in the EU and must be immediately replaced.
Regulation (EU) 2023/1115, the EUDR, entered into force in June 2023, with application dates of December 2024 (large operators) and June 2025 (SMEs) — though implementation has been delayed in practice to December 2025 for most operators.
The EUDR requires that the following commodities and derived products placed on the EU market are not sourced from deforested land (deforestation after December 2020):
For e-commerce packaging brands: The "wood" category is directly relevant. Paper and cardboard are derived products from wood and fall within EUDR scope.
If you're a brand placing paper/cardboard packaging on the EU market (which every DTC brand is, given corrugated boxes), you technically fall within EUDR scope as an operator or trader.
Operator obligations under EUDR:
In practice for DTC brands: the due diligence obligation sits primarily with your packaging supplier (who is closer in the supply chain to the raw material). However, as an importer of products using paper/cardboard, you may have trader obligations.
The practical approach for most DTC brands:
FSC and PEFC as a proxy: Forest certification schemes (FSC — Forest Stewardship Council; PEFC — Programme for the Endorsement of Forest Certification) provide chain-of-custody traceability for sustainably sourced wood. The EU Commission has issued guidance that FSC/PEFC certification can support EUDR due diligence, though it's not a complete automatic compliance pathway.
The EUDR-EPR interaction: FSC-certified corrugated cardboard is also likely to achieve eco-modulation bonuses under national EPR systems (recycled content and sustainable sourcing credentials). One data request to your supplier (FSC certification and recycled content declaration) serves both frameworks.
CSRD (EU 2022/2464) requires qualifying companies to publish detailed sustainability information in their annual reports, following the European Sustainability Reporting Standards (ESRS).
CSRD is phased by company size:
ESRS E5 (Resource use and circular economy) is the most directly relevant standard. It requires disclosure of:
These are exactly the metrics that a well-run EPR compliance programme generates. If you're accurately reporting packaging volumes to PROs and tracking eco-modulation factors, you have the raw data for CSRD E5 disclosures.
ESRS E2 (Pollution) also requires information on hazardous substance use — which overlaps with PPWR's prohibited substances (PFAS) documentation.
Even brands not directly subject to CSRD will receive data requests from CSRD-reporting customers (retailers, distributors). A UK supplement brand selling to a French supermarket chain that's CSRD-reporting will receive questionnaires asking about:
Brands that have their EPR data organised and their PPWR technical documentation complete can answer these requests with minimal incremental effort. Brands that haven't organised their packaging sustainability data will find these requests time-consuming and potentially deal-threatening.
The EU Green Claims Directive (proposed October 2023, expected to be adopted and effective from 2026) regulates environmental claims made to consumers. It prohibits:
For EPR and packaging claims:
The practical implication: the same technical documentation that supports your PPWR DoC also substantiates your green claims. Maintain the documentation and you're in a defensible position.
The most efficient approach: design your data infrastructure to serve all frameworks simultaneously rather than maintaining separate data pools for each regulation.
Core data set (serves PPWR, EPR, CSRD, EUDR, EGCD, ESPR):
| Data point | EPR use | PPWR use | CSRD use | EUDR use | EGCD use |
|-----------|---------|---------|---------|---------|---------|
| Material type and weight per component | ✓ | ✓ | ✓ | — | — |
| Recycled content % | — | ✓ | ✓ | — | ✓ |
| Supplier identity | — | ✓ | ✓ | ✓ | — |
| Wood origin / FSC certification | — | — | ✓ | ✓ | — |
| Substance declarations | — | ✓ | ✓ | — | ✓ |
| Recyclability assessment | ✓ | ✓ | ✓ | — | ✓ |
| Annual kg by market | ✓ | — | ✓ | — | — |
A single supplier onboarding process that collects material composition, recycled content, substance declarations, and wood origin documentation generates data that populates EPR reporting, PPWR technical files, CSRD disclosures, EUDR due diligence, and green claims substantiation.
Brands that invest in this data infrastructure in 2025–2026 create a scalable compliance operation. Brands that treat each regulation as a separate silo will multiply their administrative burden with each new requirement.
For a DTC brand selling into EU markets, the compliance stack by 2030 includes:
Each of these has data requirements. The brands that will navigate this stack efficiently are those that invest now in the underlying supplier data relationships, product and packaging data management systems, and compliance documentation infrastructure — treating it as a platform, not a series of one-off projects.
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EPRDesk is building tools to help DTC brands navigate this regulatory stack systematically. Start with EPR compliance and see how our platform connects all 27 EU markets.