PPWR and online retail: Is limiting EU deliveries discriminatory?

As PPWR compliance costs increase, many online retailers are reconsidering cross-border sales. However, limiting deliveries to certain countries does not automatically constitute discrimination against customers in other EU countries.

Under the EU Geoblocking Regulation, retailers are not required to ship products to every EU member state. They may restrict their delivery area to selected countries to avoid the additional administrative and EPR obligations associated with international sales.

What matters is access to the online shop; retailers may breach geoblocking rules if they block foreign customers, restrict access based on IP addresses, or automatically redirect visitors to other country-specific websites. A retailer can legally allow customers from across the EU to place orders while offering delivery only to a few selected countries. For this reason, billing and delivery addresses should be handled separately during checkout.

Cross-border self-collection is a different matter, though. If a customer collects goods, for example, in Germany and arranges transport themselves, the shipment is generally not considered a distance sale by the retailer.

PPWR relief measures under discussion

Growing compliance costs are a major reason why some retailers are reducing EU-wide shipping. To ease the burden of these extra duties, Germany has proposed exemptions for businesses using less than 10 tonnes of packaging per year in a single EU country from appointing an authorised representative. A central EU register is also proposed to replace national registration systems, with a transition period running until mid-2028.

As criticism of the PPWR continues, the European Commission is discussing simplification measures and temporary penalty relief. Therefore, in Germany, fines for breaches of new PPWR requirements are not expected before 12 February 2027.

VERE e.V. is in contact with all relevant stakeholders and keeps its members informed of further developments via the “VERE Insider”.

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Christoph Brellinger
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Christoph Brellinger
Executive secretary

Phone: 040 750687 – 200

info@vereev.de

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