EU product compliance tracker: what your catalog needs, when

One row per obligation that changes what a catalog must hold or show. Filter by regulation, category or role, or sort by deadline. Where a row says "Date depends on an act not yet adopted", the legal text sets a floor date or ties the start to a future act. Several start dates float this way: the battery label, the PPWR sorting label, the online-offer duties for each construction product family, every ESPR product passport, and the French place-of-manufacture rule for textiles^{3,5,24,25,26,27}.

A seller that sells under its own name or trade mark is treated as the manufacturer under the GPSR⁷, and an importer or distributor that sells under its own brand becomes the manufacturer under the Cyber Resilience Act²³.

Dated changes from the research, including votes on proposals. Filter by year or regulation, or sort by date. Upcoming dates that matter most for a catalog: the EUDR on 30 December 2026^1,2, battery QR codes and passports on 18 February 2027³, the Cyber Resilience Act on 11 December 2027²³ and the PPWR sorting label no earlier than 12 August 2028^4,5.

Read this table from the catalog side: each row is a field or field group, the laws that make it necessary, and where it is used. Search for a field name to see every law behind it.

The General Product Safety Regulation (GPSR) has applied since 13 December 2024⁷. It covers consumer products that are new, used, repaired or reconditioned, and acts as a safety net where no specific EU safety rule applies⁷. Food, medicines, living plants and animals, and antiques are excluded⁷.

For online sellers the key article is Article 19. Every distance-sales offer must show four groups of data⁷:

• the manufacturer's name, registered trade name or trade mark, with a postal and an electronic address⁷;
• for a manufacturer outside the EU, the name, postal and electronic address of the EU responsible person⁷;
• information that identifies the product, including a picture, its type and any other identifier⁷;
• warnings and safety information in a language set by the Member State of sale: German in Germany¹⁰², Dutch in the Netherlands⁹⁷ and Italian in Italy⁹⁸.

The listing duties also apply to CE-marked products that fall under other EU safety laws⁸. Commission guidance says an electronic address means an email address or a dedicated contact section; a website alone is not enough⁸. Behind the listing, every economic operator keeps supplier and business-customer identity for 6 years, and risk, complaint and corrective-measure information for 10 years⁷.

Marketplaces and the Digital Services Act

Marketplaces must let traders enter the same data and show it on the listing⁷, act on authority orders within 2 working days⁷ and process product safety notices within 3 working days⁷. The Commission says the listing-interface duty applies to medium and large marketplaces, and to micro or small ones only if designated as very large platforms⁸. Under the Digital Services Act, marketplaces have collected trader identity data and a compliance self-certification since 17 February 2024²⁸.

Enforcement against platforms is rising. The Commission fined Temu EUR 200 million under the DSA on 28 May 2026 for an inadequate risk assessment of illegal products²⁰. On 20 July 2026 it fined AliExpress EUR 550 million for failing to diligently assess and mitigate the risk of illegal, unsafe or counterfeit products²¹.

In a 2026 sweep run from May to July, national authorities screened nearly 1,700 offers of childcare and gym products on 35 marketplaces and issued 560 orders. 58% of listings showed manufacturer details, an EU responsible person and product identification together. These figures come from a secondary source reporting Commission data; the Commission release itself could not be checked, so treat them with caution⁶.

National penalties

Enforcement is national, and the amounts differ widely. Germany fines Article 19 listing breaches up to EUR 10,000¹⁰³. Poland fines them up to PLN 500,000 and fines marketplaces up to PLN 1,000,000⁸⁵. The Netherlands uses fixed fines of EUR 525 or EUR 1,050 per violation depending on company size, or a turnover-based fine capped at EUR 1,100,000^104,105. Spain and Austria had no GPSR-specific act in their official gazettes on 17 October 2026, so older product-safety and consumer laws still set the fines^106,107. The table also covers penalties under the other laws on this page.

The EU Deforestation Regulation (EUDR) covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood²⁹. Its Annex I lists the products made from them, such as chocolate, coffee, palm oil and many palm derivatives, new tyres, wooden furniture and paper^29,30. A product may be sold only if it is deforestation-free (no deforestation after 31 December 2020), legally produced, and covered by a due diligence statement (DDS) or a simplified declaration^1,29.

Dates

Regulation (EU) 2025/2650 moved the start to 30 December 2026 for most companies, and to 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024¹. Micro and small operators placing timber products covered by the old EU Timber Regulation still start on 30 December 2026². The Commission's May 2026 review proposed no further legal changes².

Scope changes

Printed products left the scope in December 2025¹. Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, removed leather and hides, conveyor belts, other vulcanised rubber articles, and retreaded and used tyres³⁰. From 30 December 2027 it adds soluble coffee, frozen cattle tongues and palm-based soap³⁰. A catalog that maps CN codes to EUDR scope therefore changes twice, on 30 December 2026 and on 30 December 2027³⁰.

Operators and traders

The operator, meaning whoever first places a product on the EU market or exports it, carries out due diligence and files the DDS¹. The operator collects the product description and trade name, quantity, country of production, plot geolocation, and supplier and customer details, and keeps them for 5 years²⁹. Geolocation uses latitude and longitude with at least 6 decimal digits²⁹.

An online retailer is an operator if it imports, and a trader if it sells a product someone else already placed on the EU market⁹. Online and distance sales are in scope, both B2B and B2C⁹. Traders do no due diligence and cannot file a DDS⁹. They keep, for 5 years, the name, postal address, email and web address of each supplier and business customer, plus DDS reference numbers received from operators¹. Retailers need no data on consumers², and the EUDR has no consumer label or listing field⁹. Traders that are not SMEs must register in the EUDR Information System¹. A marketplace that only intermediates has no EUDR duties⁹.

Risk and national penalties

Four countries are high risk (Belarus, North Korea, Myanmar and Russia); all EU Member States and about 113 other countries are low risk¹¹⁴. Member States set penalties, with a maximum of at least 4% of EU turnover for companies¹. National implementation is uneven, as the table shows.

The Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025 and has applied since 12 August 2026^4,33. Packaging placed on the market before 12 August 2026 can stay on sale³¹. Already in force:

• a type, batch or serial identifier on the packaging, plus the manufacturer's name and postal address^4,31;
• the importer's name and postal address on packaging from outside the EU⁴;
• technical documentation and an EU declaration of conformity, kept for 5 years (single-use) or 10 years (reusable)⁴;
• PFAS limits for food-contact packaging, such as 25 ppb for any single PFAS, and a 100 mg/kg cap on heavy metals⁴;
• distributors, including online sellers, must check EPR registration, labelling and manufacturer and importer details before selling⁴.

EPR registration and the authorised representative

The producer is whoever first makes packaging available in a Member State, and an online offer to an end user counts as making it available in the end user's country³³. Producers register in each such country⁴ and report weights by 1 June each year: by packaging category at 10 tonnes or more, by material below that⁴. Distance sellers must appoint an EPR authorised representative in each Member State other than their own⁴.

A Commission proposal would suspend that duty until 1 January 2035, which relieves EU-based producers while Member States could still require one from producers outside the EU, and the Commission has asked Member States not to sanction operators while it is examined^32,89. Parliament's environment committee voted on 5 October 2026 and the plenary vote is scheduled for 20 October 2026⁸⁸. Parliament's draft report would limit the relief to micro and small enterprises selling across borders inside the EU, so producers established outside the EU would keep the duty¹²⁶. In the Council, COREPER discontinued examination of both suspension proposals¹²⁷. Until an amending act is published in the Official Journal, the duty applies⁴.

What comes next

The harmonised sorting label applies from 12 August 2028 or 24 months after its implementing act, whichever is later⁴. That act missed its 12 August 2026 deadline; the Commission plans adoption in Q4 2026⁵. Once labels apply, the label information must also be available online before purchase⁴. From 12 February 2027, EPR participation may only be marked digitally⁴. From 1 January 2030, at the earliest, e-commerce packaging may have at most 50% empty space, and filling material counts as empty space⁴. That duty sits with whoever fills the packaging, such as a webshop packing orders³¹.

Twelve annulment actions against the PPWR are pending at the EU General Court: nine against the whole regulation and three against its deposit-return rules. Pending actions do not suspend the regulation¹²⁸.

The digital product passport (in German, digitaler Produktpass) comes from several laws, not one. Under the Ecodesign for Sustainable Products Regulation (ESPR), in force since 18 July 2024, a DPP becomes mandatory only when a product-specific delegated act requires it¹⁰. As a rule, each act applies at least 18 months after it enters into force; the regulation allows exceptions in duly justified cases¹⁰. As of 17 October 2026 no product act has been adopted; the first, for iron and steel, is planned for Q4 2026²⁶. The Commission's 2025 working plan puts textiles, tyres and aluminium in 2027, furniture in 2028 and mattresses in 2029¹²⁹.

The infrastructure exists already. The EU DPP registry went live on 20 July 2026⁸⁷, and six harmonised DPP standards were cited in the Official Journal on 15 July 2026¹³⁰. Product laws with their own passport dates:

• Batteries: a passport for LMT, industrial above 2 kWh and EV batteries from 18 February 2027³.
• Detergents: a mandatory DPP under Regulation (EU) 2026/405, which applies from 23 September 2029¹¹.
• Toys: a DPP for every toy model from 1 August 2030¹².
• Construction products: 18 months after a delegated act that has not been adopted²⁵.

For online sellers, the pattern repeats across these laws. The supplier must give the seller a digital copy of the data carrier or identifier, or a web link, free of charge within 5 working days of a request^10,11,12,25. Under the ESPR, the seller must make the passport easily accessible before purchase, including in distance selling¹⁰.

The ESPR also has rules that apply now. Since 19 July 2026, large companies may not destroy unsold apparel, clothing accessories and footwear, and the ban reaches medium-sized companies on 19 July 2030¹⁰. Unsold goods include consumer returns within the withdrawal period¹⁰. A standard format for disclosing discarded unsold goods applies from 2 March 2027¹⁰⁰.

The European Accessibility Act (EAA) has applied since 28 June 2025 to e-commerce services offered to consumers¹³. Shops that sell only to businesses fall outside, because the definition requires a consumer contract¹³. Ordinary goods sold online, such as clothing or furniture, are not EAA products; the shop that sells them is the regulated service¹³. What an online shop must do:

• show the accessibility information for products it sells, when the responsible economic operator provides it¹³;
• offer text alternatives for non-text content, such as product images and video¹³;
• make identification, security and payment functions accessible¹³;
• publish how the service meets the requirements, in its terms and conditions or a similar document¹³.

Under the directive, microenterprises (fewer than 10 persons, and turnover or balance sheet of EUR 2 million or less) are exempt from the service requirements, but microenterprises that deal in in-scope products, such as smartphones or e-readers, are not exempt from the product requirements¹³. Belgium's law of 5 November 2023, which covers e-commerce and consumer banking services, excludes microenterprises from its whole scope until 28 June 2030³⁴.

Germany transposed the EAA as the Barrierefreiheitsstärkungsgesetz (BFSG) and its implementing regulation, the BFSGV^131,132. German shops must also name the competent market surveillance authority in their accessibility information¹³¹. The enforcer is the MLBF in Magdeburg¹³³, and fines reach EUR 100,000¹³¹.

The Dutch regulator ACM names WCAG 2.1 AA as the current benchmark and expects WCAG 2.2 AA during 2026¹³⁴. In a check published on 24 March 2026, it found 61% of about 100 of the largest Dutch online stores were not digitally accessible¹⁴. EN 301 549 V4.1.1, aligned with WCAG 2.2, was adopted on 24 August 2026, but it gives a presumption of conformity only once cited in the Official Journal^135,136.

French disability associations are enforcing e-commerce accessibility in court. On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour France to make carrefour.fr and its app fully accessible within 6 months, backed by a daily penalty, and rejected the argument that meeting 71% of the criteria was enough. The ruling is reported by a secondary source¹³⁷.

The Batteries Regulation has applied since 18 February 2024, with CE marking and economic-operator duties since 18 August 2024³. Since 18 August 2025, all batteries carry the separate collection symbol, and the EPR rules apply: producers register in each Member State where they first sell, distance sellers appoint an authorised representative, and marketplaces collect registration numbers and a self-certification³. Online sellers offer free take-back, explain it when the customer orders, and show waste and collection information³.

From 18 February 2027, every battery needs a QR code, LMT, industrial above 2 kWh and EV batteries need a passport, and portable batteries in products must be removable by the end user³. Due diligence starts on 18 August 2027 for operators with net turnover of EUR 40 million or more^3,96.

For catalog data, the battery category drives most duties: portable (sealed, up to 5 kg), LMT (up to 25 kg, for e-bikes and e-scooters), EV, industrial and SLI³. In Germany, distributors and fulfilment providers may not handle batteries of unregistered producers, with fines up to EUR 100,000¹⁰¹.

Common charger

Since 28 December 2024, phones, tablets, digital cameras, headphones, headsets, handheld consoles, portable speakers, e-readers, keyboards, mice, navigation systems and earbuds that charge by wire need a USB Type-C receptacle; laptops followed on 28 April 2026²². Devices that charge above 15 W must support USB Power Delivery²². The rules cover only radio equipment, so a wired keyboard with no radio falls outside⁶².

Three duties reach the webshop directly. Any seller that offers a device with a charger must also offer it without one²². In distance selling, the "charger included" or "not included" pictogram must be shown close to the price²². The charging label, with the minimum and maximum charging power in watts and "USB PD" where supported, must also be shown close to the price²². Commission guidance says to use the "included" pictogram whenever any charger is in the box, even an incompatible one⁶².

Radio equipment cybersecurity

Since 1 August 2025, internet-connected radio equipment, childcare radio equipment, radio toys and wearables must meet network-protection, data-protection and, where payments are possible, fraud-protection requirements^59,60. This is a conformity matter for the manufacturer, not a listing field. The delegated act is repealed from 11 December 2027, when the CRA takes over⁶¹.

Cyber Resilience Act

The CRA entered into force on 10 December 2024 and applies in full from 11 December 2027^23,148. Its reporting duties have applied since 11 September 2026, including for products already on the market: an early warning on an actively exploited vulnerability within 24 hours and a notification within 72 hours²³. From 11 December 2027, the catalog needs these fields for every product with digital elements:

• the end date of the support period, at least month and year, given clearly at the time of purchase; the support period is at least 5 years unless the product's expected use time is shorter²³;
• a type, batch or serial number, and the manufacturer's name, postal address and email or other digital contact²³;
• a single point of contact for vulnerability reports²³;
• the Annex II user information, kept online for at least 10 years or the support period, whichever is longer²³;
• the EU declaration of conformity, or a simplified one with the internet address of the full text, and the CE marking²³.

Distributors, online retailers included, must check the CE marking, documents and support end date before selling, while a marketplace that only intermediates is not an economic operator under the CRA²³. Units placed on the market before 11 December 2027 do not need to comply unless they are substantially modified^23,149. Smartwatches, fitness trackers, smart speakers with a voice assistant, smart locks, baby monitors and home security cameras are Class I important products, which need a harmonised standard or third-party conformity assessment^23,58.

Under Regulation (EU) 2017/1369, online sellers must display the energy label and make the product information sheet available, including in online distance selling³⁷. Suppliers register each model in the EPREL database before placing it on the market, deliver labels within 5 working days of a request³⁷ and pass the EPREL registration number to dealers³⁸.

The label goes near the price. A nested arrow showing the class letter in the same font size as the price may open the full label on a click, roll-over or tap, and the link to the sheet must read "Product information sheet"³⁹. Commission guidance of May 2026 reads "near the price" as every page, including list pages and the basket⁹⁹. Visual ads must show the class and the range of classes³⁷.

Smartphones and slate tablets have carried a label since 20 June 2025, showing energy class, battery endurance, a repairability class from A to E, a drop class and the IP rating³⁹. Tumble dryers moved to the A to G scale on 1 July 2025 and add a repairability class from 1 January 2027^40,94.

Tyres follow Regulation (EU) 2020/740, in force since 1 May 2021. The label (fuel efficiency A to E, wet grip A to E, noise class and decibels, snow and ice grip, QR code) is shown close to the price online^42,43. Marketplaces hosting tyre sales must enable that display⁴². Proposal COM(2026) 565 would name product pages, search results and the basket explicitly; it is not law¹⁵⁰.

Two regimes overlap. Until 31 July 2030 the Toy Safety Directive applies: warnings that affect the purchase decision, such as age limits, must be visible before purchase, including online⁴⁴, on top of the GPSR listing fields⁷. The new Toy Safety Regulation was published on 12 December 2025 and applies from 1 August 2030¹².

From 2030, every toy model needs a digital product passport with 14 mandatory items, and its data carrier must be visible before purchase, including in distance sales¹². Marketplaces must let sellers show the CE marking, warnings and the passport link¹². Warning text on labels needs a minimum x-height of 1.2 mm¹². The 2030 rules also ban intentionally added PFAS and 10 named bisphenols, and require 65 fragrance allergens to be named when present above 10 mg/kg¹². Toys placed on the market under the Directive before 1 August 2030 may keep being sold, with no end date¹².

Directive (EU) 2024/825 (ECGT) has applied since 27 September 2026¹⁵. It bans generic environmental claims such as "eco-friendly" or "green" unless the trader shows recognised excellent environmental performance, or the claim is specified clearly on the same medium^15,16. Product names and brand names count as claims, and sustainability labels must rest on a certification scheme or be set by public authorities¹⁵. Old stock gets no transition period¹⁶, though authorities may phase enforcement¹⁵¹. New information for online sellers¹⁵:

• the harmonised notice on the legal guarantee (mandatory, at shop level)¹⁵;
• the GARAN label, when the producer offers a free durability guarantee of more than 2 years for the whole good, shown on the product page and directly before ordering^15,152;
• the minimum software-update period, when the producer supplies it¹⁵;
• the EU reparability score (today only for smartphones and tablets) or, failing that, spare-part and repair information¹⁵.

Implementing Regulation (EU) 2025/1960 fixes the designs of the notice and the label⁴⁵. The Commission says sellers need not search for producer information¹⁶; the Dutch regulator ACM says sellers should ask for it¹⁵³.

The Right to Repair Directive has applied since 31 July 2026⁴⁶. Manufacturers must offer repair for 11 product groups, including washing machines, phones, tablets, goods with LMT batteries and, since a 2026 amendment, local space heaters^46,47. When repair is the remedy under the legal guarantee, the seller's liability is extended once by 12 months, and the seller must tell the consumer⁴⁶. National rules lag behind: on 25 September 2026 the Commission sent letters of formal notice to 18 Member States for not notifying full transposition of the directive, according to a secondary source¹⁵⁴. Check the national law in each market before relying on it.

Price reductions

Every announced price reduction must show the prior price, meaning the trader's lowest price in at least the 30 days before the reduction; the rule has applied since 28 May 2022⁷¹. Percentage badges such as "-20%" must be calculated from that prior price, as the EU Court of Justice confirmed in 2024^72,73. Where prices differ by sales channel, the prior price is the lowest in that channel, so a catalog selling on several marketplaces needs price history per channel⁷². Selling price and unit price, both including VAT, have been required since 2000⁷⁴.

Footwear

Shoes sold to consumers carry a label that states the material of the upper, the lining and sock, and the outer sole, using four classes: leather, coated leather, textile and other⁶³. If no material reaches 80%, the two main materials are given⁶³. The label sits on at least one shoe per pair, the directive sets no online display duty, and the retailer must make sure the label is there⁶³.

WEEE

Electrical and electronic equipment carries the crossed-out wheeled bin and a mark showing it was placed on the market after 13 August 2005⁶⁴. A seller that ships directly to users in another Member State counts as the producer there and must register, through an authorised representative where required⁶⁵. Germany adds three rules: the WEEE registration number in every offer and on invoices, a ban on marketplaces and fulfilment providers serving unregistered producers, and take-back information that online sellers must publish where customers can easily find it^66,67.

REACH

Any supplier of an article, retailers included, must tell a consumer on request whether it contains a Candidate List substance of very high concern above 0.1% by weight, giving at least the substance name, free of charge within 45 days⁶⁸. The threshold applies to each component of a complex product such as a shoe or a laptop, so the data has to be held per component⁶⁹. The AskREACH request channel stops taking requests on 1 November 2026, but the legal duty stays⁹².

Machinery

The Machinery Regulation applies from 20 January 2027^70,95. Instructions may be digital, but must stay online for at least 10 years, and a user who asks at the time of purchase gets a free paper copy within one month⁷⁰. Machinery that non-professionals may use, such as garden and power tools, must come with paper safety information⁷⁰. Online retailers, as distributors, check the CE marking, declaration of conformity and instructions in the destination language before selling⁷⁰.

France adds its own product-page display rules on top of EU law. The durability index replaced the repairability index for TVs on 8 January 2025 and for washing machines on 8 April 2025⁷⁵. Sellers show the score as a pictogram near the price, in a character size equivalent to the price, on every page that allows purchase or add-to-cart, with the scoring detail one action away⁷⁵. Laptops, lawnmowers, vacuum cleaners, dishwashers and high-pressure cleaners keep the repairability index under the same display rule, and smartphones left the French index in June 2025⁷⁶.

For textiles, the anti-fast-fashion law of 8 July 2026 requires the place of manufacture near the price for textiles sold online, but names neither the responsible party nor a start date^27,81. Its per-product eco-penalties started on 1 September 2026 at EUR 0.25 to EUR 12 and rise to EUR 2 to EUR 20 from 2030²⁷. None of its three implementing decrees had been published by 20 July 2026¹⁵⁵.

Producers and importers above EUR 10 million turnover and 10,000 units a year publish a machine-readable environmental product sheet per model; retailers are not obliged unless they sell their own brands⁷⁷. Terms such as "biodégradable" and "respectueux de l'environnement" are banned on products and packaging⁷⁷. The Triman logo and sorting instruction belong on the product, packaging or supplied documents, not on the web page^78,79, and fines reach EUR 15,000 per product for companies¹¹³. The textile environmental cost score remains voluntary; a brand that shows it must follow the official method and declare it^82,83.

The Textile Labelling Regulation (EU) No 1007/2011 has applied since 8 May 2012⁴⁸. Fibre composition must be clearly visible before purchase, including online, using Annex I fibre names and percentages in descending order, per component for multi-component products, and in the official language of the country of sale⁴⁸. No revision has been proposed yet¹⁵⁶.

Directive (EU) 2025/1892 introduces textile EPR and entered into force on 16 October 2025¹⁵⁷. Member States transpose it by 17 June 2027 and set up EPR schemes by 17 April 2028⁴⁹. The scope covers apparel, household linen, curtains, hats and footwear⁴⁹. Distance sellers count as producers and need an authorised representative in each Member State they sell into, and marketplaces must collect their registration number and a self-certification⁴⁹.

National rules already require registration numbers in many places. Germany's VerpackDG replaced the Verpackungsgesetz on 12 August 2026¹⁵⁸. France requires a unique EPR identifier (IDU) in terms of sale⁸⁰.

Marketplaces turn these laws into fields and blocking rules, each on its own timetable. bol asks for GPSR manufacturer data per article for new listings from 5 March 2026 and for the EU responsible operator from 1 April 2026, and takes existing listings without manufacturer data offline in phases¹⁷. Zalando collects EPR numbers per country across 23 countries and will block assortment without packaging EPR numbers from 1 January 2027^19,167. Kaufland's seller API holds back offers with reasons such as gpsr_info_needed, epr_number_needed, weee_number_needed and idu_number_needed¹⁸. Amazon enrols sellers without a valid EPR number in a paid Pay on Behalf service¹⁶⁸.

Proposals, open acts and court actions that could change the rules above. Several votes fall in the weeks after this page was verified, so check the status before planning around a proposal.

The research recorded 111 conflicts between sources. These are the ones that change what a seller should do. Where a lane's claim conflicted with the primary legal text, the primary text was used.

1. GPSR and legacy stock. Products placed on the market before 13 December 2024 under the old directive may still be sold, and the new on-product rules do not apply to them. Whether Article 19 listing data is needed for such units is unsettled; eBay's reading is more relaxed than the Commission's. The cautious choice is to show it on every offer^8,189.
2. Which marketplaces must build GPSR listing fields. Article 22(9) names all marketplaces; the Commission guidance limits it to medium and large providers^7,8.
3. Who gets the EUDR June 2027 date. The text defers the date for micro and small operators. The Commission FAQ speaks of company size, which suggests size alone decides, while Commission guidance ties the deferral to the operator; on that reading, a small retailer buying from a large importer follows the 30 December 2026 date^1,9,204. Many summaries, including a French government page before the verifier's correction, also leave out the 31 December 2024 cut-off and the timber exception^1,120.
4. PPWR marketplace checks. Article 45(4) requires platforms to collect EPR numbers from 12 August 2026; the Commission's small-business page says platforms are not required to ask until harmonised registers exist^4,32.
5. PPWR authorised representative. The duty is law since 12 August 2026. A proposal would suspend it until 2035 for EU-based producers, while Parliament's draft report would limit the relief to EU micro and small enterprises. In the Council, COREPER discontinued examination of the proposal, yet several Member States have since asked to reopen a narrower relief for small producers. The Dutch scheme Verpact says the duty may be scrapped^{4,89,126,127,163,190}.
6. Battery label date. Many secondary sources give 18 August 2026 as fixed. The text uses the later of that date or 18 months after an implementing act that is still not adopted^3,24.
7. CRA support end date online. The CRA asks for the end date "at the time of purchase" but does not name online shops, and the Commission guidance adds nothing on this. The charger rules, by contrast, say "close to the price" for distance selling. Showing the CRA date on the product page is a reasonable reading, not an explicit rule^22,23,205.
8. Must sellers ask producers for guarantee and repair data? The Commission says no; the Dutch ACM says yes^16,153.
9. Energy label pages. The delegated acts say "near the price"; Commission guidance reads this as every page, including list pages and the basket^39,99.

The research merged 17 research lanes: GPSR and DSA, EUDR, PPWR, accessibility, batteries, ESPR and DPP, energy and tyre labels, toys, green transition and repair, textiles and national EPR, regulated categories, an amendments cross-check, and five gap lanes (electronics; footwear, WEEE, REACH, machinery and price reductions; French display rules; national GPSR and EUDR penalties; marketplace field mapping). Each lane was checked by an independent verifier that re-fetched every source.

EU legal texts were read from the EU Publications Office, which serves the Official Journal text. National texts came from official gazettes and databases. Legifrance could not be reached, so French rules rest on ministry pages and Senate texts.

Primary-first rule

Official Journal and gazette texts, court judgments and official legislative documents take priority over Commission and national guidance, which take priority over law-firm, industry or press sources. Marketplace help pages and API documents are a separate class: they show how a platform applies the law, not what the law says. Of 1,011 facts, 756 rest on primary sources, 203 on official guidance, 42 on platform documentation and 10 on secondary sources. Secondary sources are labelled where they support a statement on this page.

Verification

All rows were verified on 17 October 2026. 866 rows were confirmed as written and 145 were corrected by the verifier and then confirmed; no row was marked unverifiable. 58 rows restate a fact held by another lane, which leaves 953 unique facts. A freshness sweep on 17 October 2026 added 11 rows with news up to that date: 3 on primary sources, 5 on official guidance and 3 on secondary sources.

Limits

National coverage is partial: GPSR penalties cover eight Member States, EUDR implementation covers eight Member States, and other Member States were not checked. The French GPSR penalty rests on a secondary source. Some marketplace requirements sit behind seller logins. Whether all Member States have named a PPWR enforcement authority was not checked. The research logged 168 open gaps.

Refresh

This page is reviewed monthly, and updated when a watched act is adopted or a vote happens. Known triggers include the votes on the EPR authorised-representative suspensions, the CLP Omnibus VI vote, the PPWR label act, the first ESPR delegated act, the battery labelling act, and national EUDR penalty laws.