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What do I need to keep in mind when packing and shipping my thank-you gifts? PPWR → EU Regulation

The EU Packaging Regulation (PPWR) has been in effect since August 12, 2026. Here’s what you need to know about shipping boxes, registration, and—most importantly—shipping to other EU countries—and why you should decide which countries to ship to before your campaign launches.

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September 7, 2026
As of August 19, 2026. The legal situation is currently changing frequently. This article is not a substitute for legal advice.

The EU Packaging Regulation (PPWR) has been in effect since August 12, 2026. If you send physical thank-you gifts, this regulation applies to you.

Decide which countries you'll ship to before you list your thank-you gifts online. Shipping to other EU countries incurs fixed costs in the three-digit range per country—regardless of how many packages you send.

The Basic Rule

Shipping within the country where you're based is easy. Shipping to any other EU country is more complicated.

It doesn't matter where Startnext is located. What matters is where your package arrives—that's where your packaging becomes waste. For a project based in Graz, Germany is a foreign country; for a project based in Leipzig, it's Austria.

So the first question isn't "Where am I shipping to?", but "Where am I located?"

Does this apply to me?

Yes, if you send physical thank-you gifts. There are no exceptions for small quantities or small businesses; the requirement applies starting with the very first package.

No, for purely digital thank-you gifts, services, or in-person pickups without outer packaging: downloads, streams, workshop spots, acknowledgments, tickets, and in-person pickups.

If you provide a bag or box when handing over the goods, that counts as service packaging. Ask your supplier about pre-licensed service packaging; that way, you won't be subject to any obligations.

How can I avoid packaging requirements right from the planning stage?

The easiest thing to do is to avoid creating packaging in the first place. So check your thank-you note before you post it:

  1. Offer them digitally or as a service: Downloads, access, workshops, and similar thank-you gifts don't require packaging.
  2. Agree on packaging-free production: Ask manufacturers and printers to avoid using plastic bags, shrink wrap, hang tags, and additional decorative packaging.
  3. Buy suitable shipping packaging: Use a new, plain cardboard box with a built-in closure from a supplier in your own country.
  4. Do not add anything: Tape, packing material, tissue paper, or your own logo may result in additional obligations. A standard shipping label is fine.
  5. Plan Your Pickup Correctly: When picking up items on-site, there is no packaging requirement if no additional packaging is used. If you need a bag or box, be sure to order pre-licensed service packaging.
  6. Define your delivery area in advance: Limit shipping to your own country or a few carefully selected destination countries whenever possible. Offer a digital option or in-store pickup for customers outside your delivery area.
These measures can reduce or eliminate certain obligations. Once packaging is actually placed on the market, the regulations of the respective destination country must be reviewed.

What do I need to do when shipping within my own country?

Three steps—the same everywhere, just in different places:

  1. Register with the National Packaging Registry
  2. Licensing, that is, participating in a waste disposal system
  3. Report, usually annually

This primarily affects your product's retail packaging: plastic bags, hang tags, inserts, and sticker backing paper.

In Germany: Register with LUCID (https://lucid.verpackungsregister.org/), then join a dual system (https://www.verpackungsregister.org/systembeteiligung-und-datenmeldung/uebersicht-systembetreiber). The ZSVR is responsible for this.

In other EU countries: Each country has its own registry and its own systems. There is not yet a unified EU registry. Overview of requirements by country: https://www.wko.at/abfall/ppwr-laenderuebersicht

What about the shipping box?

If you purchase a plain, ready-made cardboard box with an integrated self-adhesive strip from a supplier in your own country, that supplier has already licensed it. In that case, you have no obligations of your own regarding shipping packaging.

The supplier must establish the supply chain in the country where the packaging becomes waste. A German cardboard box shipped to Austria is not licensed for use in Austria.

You are not eligible for the tax relief if you:

  • add something — tape, bubble wrap, paper padding, tissue paper
  • If you buy a cardboard box without a closure—that's just material, not ready-made packaging
  • have your logo on it
  • uses a used cardboard box — it is practically impossible to provide proof of prior licensing

A standard shipping label is no problem.

Recommendation: Use two to three graduated cardboard box sizes to eliminate the need for packing material. This will be mandatory starting in 2030 anyway. Details: https://www.verpackungsregister.org/themen/versand-und-onlinehandel

What's different when shipping to another EU country?

You are considered a manufacturer there and must register, participate in a waste disposal system, report quantities, and appoint a local authorized representative. This applies to each country.

No de minimis threshold—one package is enough. Cost: several hundred euros per country per year, regardless of volume. For 50 packages sent to five countries, that amounts to 30 to 60 euros per international package.

At the EU level, measures to ease the burden on small businesses are currently being negotiated. Until any changes are made, the rule remains in effect as is. Details: https://www.it-recht-kanzlei.de/bevollmaechtigter-verpackungen-eu-ausland.html

How can I set shipping regions for thank-you gifts?

That's not possible on Startnext at the moment.

Shipping costs have so far been included as a flat rate in the thank-you gifts and do not take shipping regions into account—in part to avoid introducing complexity for rare EU shipments, which could create unnecessary work if the project is not successful.

We've realized that we need to make some technical improvements here to provide more security for campaign creators. Until the update is released, you can only specify your shipping region in the thank-you message and will need to check yourself whether contributions from other countries can be processed.

In practice, you can accept virtually any contribution and then license a shipping region before shipping if it’s worth it. If it’s not worth it, you can negotiate an alternative arrangement with the backers or cancel the contribution.

Can I exclude supporters from other countries?

No. The EU Geoblocking Regulation prohibits excluding customers from making purchases based on their place of residence or nationality.

You may limit your delivery area. You may not prevent the purchase.

A supporter from another EU or EEA country provides her own address as the billing address and an address within your delivery area as the shipping address. Or she can pick up the order, if you offer that option.

The easiest solution: Offer supporters outside your delivery area an equivalent digital or pickup option. Learn more: https://www.haendlerbund.de/de/ratgeber/recht/3968-geoblocking

What if I'm located outside the EU?

Within your own country, your national rules apply. For each EU destination country, you need to register and, as a rule, appoint an authorized representative. There is a separate article for projects in Switzerland.

What options do I have for my campaign?

Shipping is available only within the country. Offer a digital version or pickup option for supporters abroad.

Shipping to non-EU countries. Switzerland, the United Kingdom, Norway: no PPWR requirements, but national regulations and customs clearance apply. https://ohn.haendlerbund.de/recht/rechtsfragen/ppwr-ausnahmen-eu-laender

Shipping to other EU countries with costs included in the price. Limit this to one or two destination countries, as fees are charged per country. Schedule all international shipments within a single calendar year—the fees are calculated annually. Service providers such as Lizenzero, Landbell, or Deutsche Recycling bundle multiple countries under a single account.

What else do I need to keep in mind?

  • Textiles: Specific Registration Requirements in France and the Netherlands
  • Electronics and Batteries: WEEE and the Battery Regulation
  • All Products Exported to the EU: Responsible Person Under the General Product Safety Regulation (GPSR)

Overview: https://www.ecosistant.eu/epr-bevollmaechtigter-guide

The narrower your "thank you" structure is, the fewer of them you'll have to check individually.

Checklist

  • Is the thank-you a physical gift? No → Done
  • Is it only for your own country? No → Explore EU options
  • Did you buy a box with an integrated adhesive strip?
  • No tape, no packing material used?
  • No custom logo on the box?
  • A new box from a supplier in your country?
  • Is the product's retail packaging licensed?
  • Are you registered in your country's registry?
  • Are there alternatives for supporters outside your delivery area?

Where can I get help?

We cannot provide legal advice or information about other countries' registries. For specific questions, please contact your Chamber of Commerce, IHK, or a specialized law firm. If you have questions about Startnext itself, please write to us.


This post is not a substitute for legal advice. The legal situation is currently changing frequently.

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