Why delistings are increasing – and what sellers must do to keep selling in the EU
Over the last few weeks, we have received a clear spike in urgent queries from e-commerce sellers who are in panic mode because their listings have been restricted, threatened with delisting, or already removed in one or more EU markets.
The pattern is consistent
- sellers expand cross-border faster than their compliance setup
- platforms request proof of EPR compliance at country and category level
- sellers upload nothing, upload the wrong identifiers, or upload identifiers that do not match the seller entity or brand mapping
- the platform blocks offers because it carries its own compliance and enforcement exposure if it continues to host non-compliant sellers
This is not a “platform policy trend” in isolation. In key EU markets, marketplaces have legal obligations that effectively force them to verify compliance and prevent sales where sellers are not properly registered.
What is actually driving delistings
Delisting typically happens for four operational reasons
1 – Missing registration identifiers for an applicable country and stream
If you place packaged goods or regulated products on a national market, you will usually need registration and ongoing compliance for the relevant stream, for example packaging, WEEE, batteries, and other sector-specific streams depending on the country and product category.
Packaging is the fastest trigger because every shipment contains packaging
- product packaging
- shipping packaging
- sometimes transport packaging depending on the flow and country
2 – Marketplaces are being pushed into “gatekeeper” behaviour by law
Germany is the clearest and most instructive example because the rules explicitly require marketplaces to check seller compliance and ban goods from distribution on their platform if key conditions are not met.
3 – Wrong number, wrong entity, wrong scope
Even when a seller has “a number,” platforms often reject it or later re-check it when
- the identifier belongs to a different legal entity than the seller account entity
- the identifier does not cover the relevant stream
- the registration is not verifiable in the expected way
- brand names on the registration do not align with how products are listed
4 – Sellers rely on upstream compliance without a defensible legal chain
Some sellers upload a fulfilment partner’s or supplier’s identifier assuming it covers them. That only works if the upstream party is legally the obligated producer for that exact stream in that exact country for that specific flow, and you can evidence it.
If you cannot evidence it, you should assume you remain exposed.
The structural mechanism sellers misunderstand
EPR is not “EU-wide” in execution. It is applied through national registers, national schemes, national reporting formats, and national enforcement.
E-commerce accelerates exposure because it creates multi-market placement quickly via
- cross-border D2C shipping
- inventory held in EU fulfilment centres
- warehouse replenishment shipments
- returns and reverse logistics
From a compliance perspective, the key question becomes: in which countries are you placing packaging or regulated products on the market, and under which legal entity.
Case study – Germany packaging law is the model behind delisting behaviour
Germany’s packaging regime is a practical blueprint for why marketplace delistings happen
What changed
- since 1 July 2022, electronic marketplaces must check whether online retailers offering products for sale in Germany comply with packaging-law obligations
- if a retailer is not registered in the LUCID Packaging Register and does not have the required system participation, the marketplace must ban the goods from distribution on its platform
Why this matters for e-commerce sellers
- delisting is not discretionary when the platform has a legal duty to block non-compliant offers
- “I will fix it later” often results in immediate commercial interruption because the platform cannot wait for you
The strategic takeaway
Once a market introduces explicit marketplace verification duties, delisting becomes a predictable enforcement tool, not an exceptional event.
A second pattern – France and the Unique Identifier expectation
France uses a Unique Identifier system as proof of EPR compliance, tied to the national framework established under the AGEC Act.
Practical platform reality
- marketplaces increasingly expect sellers to provide the relevant EPR identifiers for the categories they sell
- several marketplaces publicly instruct partners to obtain the French “Identifiant Unique” or UIN and submit it through their partner compliance workflow
Spain snapshot – why cross-border sellers get stuck
Spain is a frequent escalation point for marketplace sellers because cross-border sellers often discover late that registration is not optional and that local representation may be required depending on the seller’s establishment status and model.
Operational signal to watch
- sellers are commonly asked for an EPR registration number linked to the public producer register, and non-established sellers may need a Spanish authorised representative to obtain the number
Examples – what “panic mode” looks like in real seller operations
Example 1 – Cross-border D2C seller expands into Germany
Scenario
- seller starts shipping packaged goods to customers in Germany
- platform requests proof of packaging compliance
Typical failure
- seller registers too late or only completes part of the compliance chain
Commercial outcome
- offers are blocked because Germany’s marketplace verification model creates a direct path to delisting when required conditions are not met
Example 2 – Seller operates EU fulfilment and sells into multiple markets
Scenario
- inventory is stored centrally and shipped to multiple EU countries
- the seller assumes “one EU warehouse means one compliance setup”
Typical failure
- seller has registrations in one country only, but places packaging on multiple national markets
Commercial outcome
- repeated compliance requests, multi-country delisting risk, and increasing friction with platforms and partners
Example 3 – Seller uploads an upstream number
Scenario
- seller uploads a supplier’s or fulfilment partner’s identifier
- platform rejects it or later challenges it
Typical failure
- no defensible legal chain that the upstream party is the obligated producer for that flow
Commercial outcome
- seller must register anyway, but now under time pressure with listings already restricted
What sellers should do now – the audit-ready playbook
Step 1 – Define your markets based on physical reality, not storefronts
- countries you deliver to
- countries where inventory is held
- countries where you import or control inbound logistics
- countries where returns are processed or redistributed
Step 2 – Confirm which EPR streams apply
Most sellers fall into at least one of
- packaging
- WEEE if electronics are sold
- batteries if products contain or ship with batteries
- other streams depending on the country and category
Step 3 – Register correctly per country and per stream
- do not assume one registration covers the EU
- do not assume marketplace selling removes your obligations
- align registrations to the correct seller legal entity
Step 4 – Build an evidence file that survives checks
Minimum evidence discipline should include
- registrations and identifiers per country and stream
- scheme or PRO contracts where applicable
- reporting submissions and confirmations
- fee payment records and invoices
- packaging data methodology and assumptions
- internal change log showing what changed when sales footprint expanded
Step 5 – Stop treating compliance as “uploading a number”
Identifiers are only one layer. The underlying obligations often include ongoing reporting, fee payments, and evidence retention.
How RegSurance helps marketplace sellers stay compliant
RegSurance supports e-commerce sellers and brands with an end-to-end compliance operating model across Europe, including
- obligation mapping by country, channel, and fulfilment model
- packaging, WEEE, and battery structuring across jurisdictions
- registrations, scheme onboarding, and evidence management
- reporting workflows and audit readiness support
- platform readiness support to prevent delisting and recurring compliance escalations
Cloud-based compliance platform
Our secure cloud-based platform helps sellers move from reactive firefighting to controlled compliance by enabling you to
- map packaging and product flows across countries
- centralise registrations, identifiers, and evidence in one place
- structure packaging data so reporting becomes repeatable and scalable
- maintain an audit trail that holds up under marketplace and authority scrutiny
- prepare for higher data and evidence requirements as EU packaging rules evolve
FAQ – questions sellers ask when listings are already at risk
I only sell via marketplaces. Do I still need registrations
In many cases, yes, because EPR obligations are linked to placing products and packaging on national markets, and platforms increasingly require proof of compliance.
Why did I get a compliance request when my volumes are small
Many EPR regimes apply from the first unit placed on the market, and platforms typically enforce a standardised proof-of-compliance workflow rather than volume-based exceptions.
I uploaded an identifier but the platform still says I am not compliant
Most common reasons
- incorrect stream coverage
- identifier linked to a different legal entity
- missing supporting proof where the platform validates more than “registration only”
- brand and account mapping mismatch
Can I rely on a fulfilment partner’s compliance
Only if the partner is legally the obligated producer for that specific flow and you can evidence it.
If you cannot evidence it, you should assume you remain exposed.
What is the fastest route out of delisting risk
- confirm the country and stream scope
- register correctly
- upload valid identifiers aligned to your seller entity and product scope
- prepare evidence because follow-up checks are common
Disclaimer
This blog is provided for general informational purposes only and does not constitute legal, regulatory, or professional advice.
EPR obligations are country-specific and depend on your supply chain, fulfilment model, legal entity structure, product categories,
and how packaging or regulated products are placed on each national market. Marketplace enforcement practices and legal requirements
may change over time. You should obtain professional advice for your specific situation before taking or refraining from action
based on this content.