UK musicians selling merchandise to EU fans will need to comply with new packaging rules including regulations on labelling, recyclability, and reusability.
The EU Packaging and Packaging Waste Regulation (PPWR) came into force on 12 August 2026, requiring musicians selling physical products from the UK to customers in the EU to review their packaging arrangements and ensure products comply with the new rules.
Non-compliance could result in merch being rejected at EU borders
The new regulations state that:
- Packaging must be recyclable, minimally wasteful, and clearly labelled
- Plastic packaging will be subject to recycled-content targets by 2030 and 2040
- Reuseable or refillable options must be offered for certain products
- Unnecessary packaging and harmful substances must be avoided.
According to the Business Innovation, Science and Trade (BIST), non-compliance could result in items not reaching their destination.
BIST states that “UK exporters will need to comply with PPWR when selling any packaged goods to the EU. Non-compliance could result in goods being rejected at EU borders. PPWR covers all aspects of packaging, including labelling, recyclability, and reusability.
“It is important that UK exporters review PPWR requirements and ensure that they are compliant prior to 12 August 2026. This includes a packaging audit to identify any excessive packaging or non-recyclable materials for example.”
BIST has issued further guidance on the new regulations.
Government confirms responsibilities for producers
The MU contacted the government for details on how the regulations apply to musicians selling vinyl, CDs, and other merchandise to the EU.
In response, officials highlighted the requirement for producers to appoint an authorised Extended Producer Responsibility (EPR) representative. This is a representative appointed by a producer that is not established in the EU member state where packaging is placed on the market, whose duty it is to fulfil the producer’s packaging EPR obligations in that country.
The government confirmed that this requirement applies from 12 August 2026.
Officials also stated that “there is no general exemption for micro-enterprises from EPR obligations in the PPWR”, meaning that musicians selling merchandise will still be required to meet the new packaging regulations, including appointing an authorised EPR representative where required.
However, the regulation is intended to reduce the administrative burden on smaller producers, as businesses placing less than 10 tonnes of packaging on an EU member state’s market per year are subject to fewer reporting requirements.
The government also confirmed that member states and producer responsibility organisations (PROs) must ensure that smaller producers are not subject to disproportionate compliance burdens. Commercial third-party compliance schemes are available and may be used to help meet these obligations.
Further guidance and next steps
More information, including a comprehensive set of FAQs can be found in the European Commission’s guidance on the PPWR. Pages 59-60 contain further information on the issues outlined above.
Whilst producers are required to register by 12 August 2026, they are not required to report to the national EPR registers before 1 June 2030.
The MU has sought further clarification on how these requirements will apply in practice to musicians, and will provide further updates as soon as new information becomes available.