EU Regulatory
Changes 2026

What it is

• Directive (EU) 2024/825 rewrites EU consumer law on green and ethical claims.
• Covers everything a shopper sees: product copy, titles, images, badges, emails, social, packaging, landing pages.
• Applies to anyone selling to EU consumers, wherever they are based. Fines can reach at least 4% of turnover in the member states concerned for widespread breaches.

What is banned from 27 September

• Generic claims ("eco-friendly", "sustainable", "green", "natural") unless the specific basis sits on the same page.
• Sustainability badges not backed by an independent certification scheme.
• Whole-range claims ("all our merch is sustainable") where only one aspect qualifies.
• Neutrality claims ("carbon neutral", "climate neutral") based on offsetting.
• Future promises ("a tree for every order", "net zero by 2030") without a public, dated, verified plan.

Still fine: "100% GOTS-certified organic cotton", "pressed on 100% recycled PET", "FSC-certified board", with the certificate on file.

Who carries the risk

• BSI, wherever it is merchant of record. Where a client runs its own store, the claims and the risk are the client's.
• UK stores too: the CMA applies the same tests and can fine up to 10% of global turnover (DMCC Act, since April 2025).
• Artist-run social and email are caught in the same way; the risk sits with whoever publishes the claim.

What BSI is doing

• Auditing every live store and updating wording where needed.
• Building an evidence file of certificates and supplier data behind every specific claim that stays live.

Key dates

Words that now need evidence

Do not use without a specific, evidenced statement alongside: eco-friendly · sustainable · green · natural · environmentally friendly · planet-friendly · climate neutral · carbon neutral · net zero · biodegradable · compostable · recyclable · ethically made · ethically sourced

EPR is a different rule

Easily confused, deliberately separate. This directive polices what a store says; EPR polices what a seller ships, with registration and fees in every country of sale so products and packaging are paid for at end of life. A store can be word-perfect and still unregistered, or fully registered and still fined for one stray "eco-friendly". BSI runs both. Where we are registered is in section 02.

What it is

• Extended Producer Responsibility (EPR): register in each country, report packaging weights by material, pay fees to a national scheme.
• EU PPWR applies from 12 August 2026 and harmonises the rules; registration and fees stay national. The UK runs its own scheme (pEPR).

Who is responsible

What BSI is doing

• UK: registered with the regulator via the Report Packaging Data system and reporting packaging data.
• Germany: Backstreet International Merchandise Limited and BSI Merch GmbH each hold their own LUCID registration, with dual system contracts in place. LUCID registration numbers are available on request.
• Further EU markets: registrations for the next 13 markets are being submitted to the national registers through a specialist EPR compliance partner and implemented as each register processes them, with textile EPR where national schemes already run. Remaining markets are phased through 2027, driven by sales volumes and necessity.
• Fulfilment clients: despatch packaging data by material and market on request; registration numbers verified where the law requires.

If you are a fulfilment client

• Register in each country you sell into or appoint an authorised representative there.
• Send BSI your registration numbers. Without a LUCID number BSI cannot legally fulfil German orders for you.
• Ask BSI Operations for despatch packaging data to support your reporting.

Where BSI is registered

EPR registrations held or in delivery by BSI as merchant of record:

*Next 13 markets: France, Spain, Belgium, Netherlands, Poland, Sweden, Austria, Denmark, Portugal, Finland, Greece, Czech Republic, Hungary.

Applications for the 13 markets are being filed with the national registers through BSI's specialist EPR compliance partner, and each market moves to Registered as its register issues the number; this briefing is updated as they complete. Netherlands packaging sits under the national registration threshold, so textiles is the applicable stream there.

Key dates

NOT TO BE CONFUSED WITH: Green claims (section 01) are a separate rule. Textile EPR (France, the Netherlands, Hungary and Latvia now, EU-wide by 2028) is not covered by a packaging registration.

What is changing

• €3 flat duty per item, since 1 July 2026. On every consignment up to €150, whatever the product or origin. BSI pays it under IOSS DDP; not refunded on returns. Runs to 1 July 2028.
• Three product identifiers per item, 1 November 2026. BSI SKU (existing, must now flow into the customs data), the manufacturer's own product reference (new data for most merch), and EAN/GTIN where one exists. Missing data means held, rejected or surcharged parcels.
• EU handling fee per parcel, 1 November 2026. About €2, set by Commission delegated act, paid by whoever pays the duty.
• EUDR, 30 December 2026. Due diligence for imported leather, natural rubber, wood and paper products. Printed matter and packaging are out of scope.
• IOSS right to use, January 2027. The IOSS number on a declaration must belong to the seller of the goods; anyone else's is rejected.
• Data Hub and four-band tariff, 1 July 2028. Flat duty ends; the seller becomes importer of record; low-value parcels pay one of four duty bands (proposed 5, 8, 12, 17%). Apparel sits in the top band and recorded music, now duty-free, becomes dutiable, unless full classification is chosen instead. Final text to confirm.

What it means for BSI

• Cost: €3 per item plus about €2 per parcel inside the DDP price, unrecoverable on returns. 2028 needs re-modelling for apparel and music.
• Data: SKU and origin already held. Work is mapping SKU and barcode into the carrier feed and sourcing manufacturer references, from the client for client-supplied stock.
• Scope check: leather, rubber, wood, notebook and paper lines need EUDR evidence from the supplier before import from December.
• IOSS: BSI's registration is unaffected; clients who are merchant of record need their own.

Being confirmed

SKU and barcode mapping into carrier data; sourcing manufacturer references; EUDR scope screen; how carriers will bill the handling fee; 2028 tariff bands versus full classification. Positions to follow in a further update.

Key dates

Who is affected

Affected: UK warehouse orders to EU consumers; client stock imported into the EU under the client's own name; any seller using an IOSS number that is not its own.

Not affected: Berlin warehouse orders to EU consumers; UK domestic orders; B2B shipments to VAT-registered EU businesses (identifier rule does not apply).

For clients

If you are merchant of record and ship into the EU, these are yours: the duty and handling fee sit in your landed cost, the identifiers must be on your product data, and you need your own IOSS registration. BSI can provide despatch data.