New rules and obligations: Will 2026 be a nightmare for online retailers?

The coming year won’t be easy for online retailers. Many new laws will introduce additional workload and uncertainty. Below is an overview of what merchants should prepare for.

1. PPWR: The new packaging regulation

The Packaging Act has always been a major burden for merchants. Beginning in 2026, the EU Regulation on Packaging and Packaging Waste (PPWR) will replace the existing packaging directive. As of August 12, 2026, it started to apply in all Member States. 

The aim of the new Packaging Regulation is to reduce the volume of packaging waste and to increase the share of recyclable and reusable packaging. The following points are to be implemented in detail:

• Reducing of packaging waste
• Introducing stricter recycling quotas and standards (by 2030, all packaging should be recyclable)
• Promoting reusable packaging solutions, especially in shipping
• Harmonizing requirements across EU countries
• Extending producer responsibility over the full life cycle of packaging – including take-back and recycling
• Clear labeling of packaging regarding recyclability and proper disposal
  

Retailers should already start reviewing their packaging for recyclability, ensure it’s not excessively oversized, and document materials. In some cases, merchants may be required to use reusable packaging.

A positive aspect is that PPWR aims for a Europe-wide unified regulation. So far, merchants had to register in every country where they first place packaging on the market; a single EU-wide register does not exist yet.

2. The warranty label: New information required

The EU consumer rights directive has already been in force for over 10 years and still brings new obligations. From September 27, 2026, merchants are bliged to provide a warranty label. This uniform, EU-wide label is intended to let consumers see their rights regarding warranty at a glance. A QR code is also required, directing to further information.

The new warranty label resembles the existing EU energy labels. Retailers must take care to visibly present the provided label for customers. The labels will not be customizable and will be supplied by the EU in the official language(s).

The label must include:

• Notice of the minimum statutory warranty duration of two years, and that in some countries longer periods may apply
• A listing of consumer rights in case of defects: repair, replacement, reduction, or refund
• A QR code linking to an EU information page on statutory warranty rights plus national pages
  

If a product also has a manufacturer’s guarantee, a guarantee label is furthermore required to go alongside the warranty label. The design of this will also be determined by the EU. 

Labels must be integrated in color.a nested display that becomes fully visible when clicked or hovered over is also permitted. It is important that customers can see the labels before concluding the contract. In addition, the labels must not be hidden in the small print, but must be presented ‘in a prominent manner’. 

In principle, the requirement applies to all kinds of products. No exception is currently planned for perishable goods or high-wear products, since the statutory warranty obligation generally applies to these as well.

3. Revocation button

Another change that retailers will face as a result of the revision of the Consumer Rights Directive is the revocation button. To make the process of revocation easier for consumers, retailers will be forced to integrate the new button, comparable to a ‘Buy now’ button. From 19 June 2026, every shop must implement the revocation button. 

This button should be easy to find, clearly visible throughout the entire revocation period, and permanently available. It should also be possible to use it without prior registration. In practice, the button will likely be a link to a form that can be used to declare revocation. For customers who have a user account and are already logged in, the data may already be pre-filled. 

Additionally, after a revocation is declared, consumers must now receive a confirmation of receipt including the content of the revocation, date, and time of receipt.

4. Deforestation regulation: Long planned, often delayed

Since June 2023, the EU Deforestation Regulation (EUDR) has been in place. It was originally supposed to take effect by the end of 2024, but implementation was delayed. Obligations for larger and medium enterprises will begin December 30, 2025, while small businesses have a longer transition period until June 30, 2026.

The EUDR aims to prevent the sale of products contributing to deforestation or forest degradation within the EU. These include:

• Wood
• Coffee
• Cocoa
• Palm oil
• Rubber
• Beef
  

Merchants selling such goods must in future provide a due diligence declaration showing that the product was lawfully produced and that the merchant conducted a due diligence assessment.

This affects all retailers who place the raw materials concerned on the market in the EU for the first time, manufacture or sell them in the EU, or export them from the EU. The declaration relies on a three-step due diligence procedure:

1. Gathering information on origin country, GPS coordinates of production area, and legal framework
2. Assessing risk of deforestation or legal infringements
3. If needed, risk mitigation via supplier declarations or independent certifications
   

Responsibility for this declaration lies with the retailers, who may, however, seek assistance from the manufacturer or importer in obtaining the information.

5. Customs reform: Will retailers benefit from the new rules?

While changes to consumer rights often bring challenges for retailers, the customs reform actually promises simplifications for imports from non-EU countries. Starting in 2026, centralized customs procedures are intended to reduce complexity.

Previously, traders importing goods from outside the EU had to go through a dual process. If the goods were imported via a port in the Netherlands, for example, the customs declaration had to be made to the Dutch authorities. In addition, a separate declaration for import VAT was required in Germany. 

From 2026, the foreign customs declaration will automatically serve as the tax declaration in Germany, using the Centralised Clearance (CCI) system. Even if the declaration is made in another EU country, the tax will accrue in Germany. The main customs office at the retailer’s business location will be responsible. For importers, this brings significantly less bureaucracy in 2026. 

6. Other small changes of interest to businesses

In addition to customs reform, the Tax Amendment Act introduces several other changes that may be of interest to entrepreneurs. The mileage allowance will increase to €0.38 per kilometer from 2026. In addition, VAT in the catering industry will be reduced to seven percent.

From June 2026, the EU Pay Transparency Directive must also be transposed into German law. This means that larger companies in particular will be obliged to ensure greater salary transparency in job advertisements. 

The amendments to the Consumer Rights Directive also aim to regulate financial services more strictly. In the future, businesses will have to explain contracts and their consequences more clearly to consumers. 

Author:

Hanna Hillnhütter – Hanna keeps an eye on legal developments, focusing on warnings, competition law and current EU regulations.. Find more of her writing on https://www.onlinehaendler-news.de/ 

Article originally published in German on September 24, 2025

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