Since 12 August 2026, the European Union’s PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) has been applicable across the European Union. Its aim is to reduce packaging waste, promote recyclability, and harmonise packaging rules across the EU. For galleries and artists selling or shipping artworks to European clients from a country outside the European Union, these new rules may have a direct impact on how artworks are prepared and shipped. Whether it is a painting, a photograph, a sculpture, or a limited edition, the materials used to protect an artwork during transport may fall within the scope of the regulation.
Are galleries and artists outside the EU affected?
Potentially, yes. The PPWR provides that the concept of a “producer” may apply to a company or professional established in a third country when they make packaging available for the first time in the territory of an EU Member State, including in the context of distance sales. As a result, a gallery or artist based in the United Kingdom, the United States, Switzerland, or another non-EU country that directly ships a packaged artwork to a client located in the European Union may be subject to packaging-related obligations. This may include the materials used to protect and transport artworks: wooden crates, cardboard boxes, protective paper and cardboard, bubble wrap, plastic films, foam and cushioning materials, sleeves, and other protective materials — and, more broadly, all packaging components used for shipping. The regulation therefore does not only apply to the outer crate or box: the different components of the packaging may also fall within its scope.
What obligations apply to galleries and artists concerned?
The specific obligations may vary depending on the country where the packaging is placed on the market, as extended producer responsibility (EPR) schemes and their administrative requirements are organised at national level. A gallery or artist established outside the EU that ships artworks directly to the European Union should therefore check the requirements applicable in the relevant country or countries.
1. Appoint an authorised representative or agent where required
A gallery or artist established outside the EU may be required to appoint an authorised representative in the relevant country to fulfil certain EPR obligations on their behalf.
2. Register with the relevant national scheme
Professionals concerned must identify the EPR requirements applicable in the destination country and complete any necessary registrations. In France, producers subject to an EPR scheme must, in particular, obtain a Unique Identifier (IDU) issued by ADEME.
3. Report the packaging placed on the market
The quantities and types of packaging materials concerned must be reported in accordance with the applicable national scheme. For an artist or gallery, this may include packaging used to ship an artwork directly to a buyer or another customer located in the European Union.
4. Pay any applicable eco-contribution
Depending on the country and the type of packaging concerned, a financial contribution may be payable to an approved producer responsibility organisation. The amount generally depends on the type and quantity of materials concerned.
What if a gallery or artist ships to several European countries?
The PPWR establishes a common European framework, but EPR schemes, registers, producer responsibility organisations, and certain reporting requirements remain organised at national level. A gallery or artist based outside the EU that ships artworks directly to several European countries should therefore check the requirements applicable in each country concerned. It is recommended to seek advice from a specialised organisation or EPR representative to identify the specific steps required.
Packaging that protects artworks — and meets new European requirements
For art professionals, compliance must naturally go hand in hand with one essential priority: protecting the artwork. A fragile sculpture, photograph, work on paper, or painting may require different packaging solutions.
The aim is therefore not to eliminate essential protective materials, but to minimise unnecessary materials and over-packaging wherever possible, while ensuring that the artwork remains safe throughout transport.
Several practical measures can help galleries and artists meet these requirements: optimising packaging sizes to minimise unnecessary empty space, choosing recyclable or reusable materials where compatible with the artwork, limiting single-use components, reusing suitable crates and protective materials, and keeping records of the materials used to facilitate reporting.
What is the role of Artsper and Upela?
Using the Artsper/Upela shipping service therefore does not automatically transfer these obligations. The gallery or artist remains responsible for assessing their situation under the applicable rules and, where required, completing the necessary registrations, declarations, and payments.
What galleries and artists need to remember
Before shipping an artwork from a non-EU country to a European client, make sure to:
- Check whether the gallery or artist is considered the producer or the entity placing the packaging on the market in the destination country.
- Identify the applicable EPR obligations.
- Check whether a local authorised representative or agent is required.
- Complete the required registrations and obtain a Unique Identifier (IDU) where applicable.
- Report packaging quantities and materials in accordance with national requirements.
- Pay any applicable eco-contributions.
- Opt for packaging that is optimised, recyclable, or reusable where compatible with the protection of the artwork.
- Anticipate these steps before shipping to avoid delays or administrative difficulties.
The PPWR marks a new step in the regulation of packaging across Europe. For international galleries and artists shipping artworks directly to European clients, packaging-related obligations must now be taken into account as part of the sales and shipping process.
Artsper and Upela help simplify the logistics of your shipments. Regulatory obligations relating to packaging remain the responsibility of the gallery or artist where they are legally considered the producer or the entity placing the packaging on the market.