The way we deal with waste is changing fast. Governments around the world are done letting brands ship products with zero thought about what happens when they break, expire, or get returned. Enter Extended Producer Responsibility (EPR), a policy model that makes producers financially and operationally accountable for their products’ full life cycle, including after consumers are done with them.

And while most ecommerce operators are bracing for the added costs, smart brands are already asking a different question: What if we could turn EPR compliance into a competitive advantage?

Let’s dig into how EPR works, what’s shifting globally, and how Cahoot’s peer-to-peer returns program just might be the most elegant solution ecommerce sellers never saw coming.

What Is Extended Producer Responsibility?

Extended Producer Responsibility, or EPR, is a policy approach that shifts the financial responsibility and logistical burden for waste management away from governments and consumers and places it squarely on the shoulders of producers. That means brand owners, manufacturers, and importers must now manage the end-of-life of their products. Whether it’s packaging waste, electronics, beverage containers, or textiles, producers are expected to pay for or directly handle the collection, reuse, recycling, or disposal of their waste.

And it’s not optional anymore. EPR programs have already been implemented or introduced in many countries, from Canada to the EU to parts of the U.S. EPR has been widely adopted across the OECD and beyond, and the scope continues to grow. Even developing countries are starting to adopt similar policy approaches to address waste management, limited resources, and environmental impacts.

The idea is simple:

If you make it, you should figure out how to unmake it.

Why EPR Matters for Ecommerce (and Fast)

The EU’s Packaging and Packaging Waste Regulation (PPWR) generally began applying on August 12, 2026. But not every requirement started on that date. The regulation phases in major obligations through 2028 and 2030, so ecommerce brands need to distinguish what applies now from what they should prepare for next.

What Applies Now: PPWR Compliance and PFAS Restrictions

As of August 12, 2026, the PPWR applies across the EU. The most immediate product-level change is a restriction on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. Packaging placed on the EU market on or after that date cannot contain PFAS at or above the limits established by the regulation: 25 parts per billion for any individually measured PFAS, 250 parts per billion for the sum of measured PFAS, or 50 parts per million for total PFAS, including polymeric PFAS.

These restrictions can affect grease- or water-resistant packaging such as takeaway containers, fast-food wrappers, microwave popcorn bags, bakery paper, and pizza boxes. Brands, importers, and packaging suppliers should confirm material specifications and retain the technical documentation needed to demonstrate compliance. Food-contact packaging placed on the EU market before August 12, 2026 may remain on the market, but packaging manufactured earlier and first placed on the market after that date must comply. The full PFAS limits and documentation requirements are set out in Article 5 of the PPWR.

Other baseline PPWR duties also apply now. Packaging placed on the EU market must comply with the requirements currently applicable to its materials and intended use, including the regulation’s general recyclability and reusability rules. Manufacturers and importers must also meet the conformity-assessment, technical-documentation, declaration, and traceability duties that apply to their roles. That does not mean the detailed 2030 recyclability grades or the later recycled-content and waste-reduction targets have started early.

What Changes in 2028: Harmonized Packaging Labels

Beginning in 2028, packaging sold in the EU is scheduled to use a harmonized labelling system that identifies material composition and helps consumers sort packaging correctly. Corresponding labels will also appear on waste receptacles. Under the PPWR, the packaging requirement applies from August 12, 2028 or 24 months after the relevant implementing rules enter into force, whichever is later. Ecommerce brands should use the lead time to map packaging materials, collect supplier data, and prepare artwork and product-information systems for the new labels.

What Changes in 2030: Recyclability, Recycled Content, and Waste Reduction

From 2030, the PPWR begins applying several of its most consequential circular-packaging measures. Packaging will need to meet design-for-recycling criteria and qualify within the permitted recyclability grades. Minimum recycled-content requirements will begin for specified plastic packaging. The EU will also introduce limits on excessive empty space, restrictions on certain single-use plastic packaging formats, and reuse targets for selected packaging categories. Exact obligations and exemptions depend on the packaging type, business role, and secondary rules adopted by the European Commission.

Packaging Is Not the Only EPR Change

The EU’s revised Waste Framework Directive entered into force on October 16, 2025 and requires every Member State to establish an EPR scheme for textile and footwear products. Member States have 30 months from the directive’s entry into force to establish those schemes, so implementation will arrive through national laws rather than as one EU-wide obligation beginning on a single date.

Most ecommerce brands don’t manufacture the products they sell, but that doesn’t necessarily mean they’re off the hook. Depending on the law and sales model, the responsible “producer” may be the brand owner, manufacturer, importer, distributor, or a seller supplying customers across borders. If you sell to consumers in EU countries, existing national EPR schemes may already require registration, fees, and reporting even while later PPWR requirements are still being phased in.

A few examples:

• France requires REP producers to obtain a unique IDU and submit annual declarations; Germany requires registration with the LUCID Packaging Register, system participation for packaging subject to system participation, and regular volume reporting; Austria has packaging EPR schemes managed through collection and recovery systems.
• As of July 1, 2025, covered producers in Oregon must register with an approved Producer Responsibility Organization, report data to the PRO, and pay membership fees under the Recycling Modernization Act.

Bottom line: the legislation is no longer just about compliance; it’s reshaping how brands think about production, materials, costs, and returns.

The Challenge: EPR Compliance Is Complex, Costly, and Ongoing

Here’s the hard truth: complying with EPR is expensive. Brands must:

• Register in each country or state
• Report SKU-level data on materials used
• Pay eco-modulation fees based on how sustainable the product or packaging is
• Handle logistics for collection, reuse, or recycling
• Prove proper disposal through auditable documentation
• Comply with applicable marketplace EPR rules to avoid suspension or deactivation of non-compliant listings on Amazon Germany.

This is a ton of work. And worse, it’s ongoing; producers must continually track and report quantities sold, what was returned, how it was processed, and where the materials went. For ecommerce operators already dealing with slim margins and tight cash flow, EPR can feel like an existential threat.

So what’s a brand to do?

Enter Cahoot: Turning Returns into an EPR Compliance Asset

Here’s where Cahoot’s peer-to-peer ecommerce returns solution changes the game.

Returns are one of the biggest blind spots in EPR. Returned goods often fall through the cracks of reuse and recycling programs, creating waste and compliance headaches. Traditionally, a returned item is shipped back to a warehouse, inspected, and often discarded or sent to liquidation, especially in fast fashion or electronics. That’s a wasted product, wasted materials, and additional shipping, all of which hurt your EPR score.

But what if that returned product could skip the warehouse altogether and get shipped directly to the next buyer?

That’s exactly what Cahoot’s peer-to-peer returns model does.

Instead of bringing a return back into centralized inventory, Cahoot reassigns it in real-time to the next customer who wants it. The return is rerouted, minimizing extra handling, materials, and emissions. And yes, it’s fully traceable for EPR reporting.

Here’s How Cahoot Solves for EPR:

1. Reduces Waste and Increases Reuse

Returned products are resold, not discarded. That extends product life, lowers end-of-life management costs, and keeps items out of landfills, key outcomes for EPR compliance.

2. Cuts Down on Packaging Waste

Because the return never goes back to the original warehouse, the need for repackaging is eliminated. That’s less packaging waste and fewer new materials in circulation.

3. Minimizes Reverse Logistics Emissions

No second trip across the country. No return to origin. Just direct-to-new-customer fulfillment. This slashes the carbon footprint of the return journey and helps brands meet sustainability targets.

4. Enhances Product Stewardship Reporting

With Cahoot, returns are tracked from the original buyer to the next. That data visibility gives brands a documented chain of custody they can use for EPR program reporting.

5. Avoids Fees and Penalties

Many EPR shifts include eco-modulated fees, meaning the greener your product’s life cycle, the less you pay. Cahoot helps brands reduce costs by showing responsible, circular product management.

EPR and Returns: A Match Made for Reinvention

Let’s be honest, most brands aren’t thinking about returns when they think about EPR legislation. But they should be. A returned product that gets trashed is the ultimate EPR failure. One that gets rerouted and reused? That’s a policy win, an environmental win, and a cost-saving win.

What’s more, Cahoot gives ecommerce operators a rare opportunity: To not just comply with EPR, but to lead.

Final Thoughts: Don’t Just Comply, Differentiate

EPR isn’t going away. In fact, it’s spreading fast, and consumers are paying attention. Brands that embrace reuse, reduction, and responsibility will earn trust. Those who treat returns like an afterthought may face penalties, bad PR, or worse, delisting from key markets.

The good news? Cahoot’s peer-to-peer returns solution is already helping brands across categories, from apparel to electronics, cut costs, reduce environmental impacts, and prove EPR compliance in a way that scales with growth.

That’s not just smart compliance, that’s smart business.

Written By:

Manish Chowdhary

Manish Chowdhary is the founder and CEO of Cahoot, the most comprehensive post-purchase suite for ecommerce brands. A serial entrepreneur and industry thought leader, Manish has decades of experience building technologies that simplify ecommerce logistics—from order fulfillment to returns. His insights help brands stay ahead of market shifts and operational challenges.

The European Green Deal isn’t just a buzzword, it’s a mandate that’s reshaping how business gets done. It’s Europe’s moonshot plan to become the first climate-neutral continent by 2050, cutting emissions and pollution across every industry. For ecommerce brands, this is both a wake-up call and an opportunity. In a climate-neutral European Union, doing business as usual isn’t going to cut it. Sustainability is now a must-have, not a nice-to-have. And surprisingly, one of the secret weapons in meeting these ambitious goals might just be rethinking something as routine as product returns.

What Is the European Green Deal? (In Plain English)

In case you missed it, the European Green Deal (EGD) is the European Union’s sweeping strategy to tackle climate change and drive sustainable development. Think of it as the EU’s growth strategy for the 21st century, a plan to transform Europe into a fair, prosperous society with a modern, resource-efficient, and competitive economy that leaves no one behind. The headline goals? Cut net greenhouse gas emissions by at least 55% by 2030 and achieve climate neutrality by 2050. In other words, become a climate-neutral continent within a few decades. No pressure, right?

This Green Deal isn’t a single law but a whole portfolio of policies touching everything: clean energy, circular economy practices, sustainable agriculture (hello, Farm to Fork strategy), transportation, construction, and more. It’s backed by the European Climate Law, making these emission-cut targets legally binding, and a “Fit for 55” package of initiatives to overhaul regulations from energy taxes to carbon pricing mechanisms. The European Commission and European Parliament are all in on this, reviewing old laws and crafting new ones to align with a climate-neutral economy. We’re talking about policies like an updated EU Emissions Trading System, a Carbon Border Adjustment Mechanism (to prevent so-called carbon leakage from less-regulated countries), a circular economy action plan, and even a Nature Restoration Law to revive ecosystems. The Nature Restoration Regulation entered into force on 18 August 2024 and requires EU countries to restore at least 20% of land and sea areas by 2030 and all ecosystems in need of restoration by 2050.

The European Green Deal is massive in scope, but its essence is simple: economic growth without trashing the planet. It aims to decouple growth from resource use, meaning you can have a sustainable economy without burning through natural resources or spewing greenhouse gas emissions. It’s also about an inclusive transition; the EU’s Just Transition Mechanism is funneling billions to ensure EU member states and industries (even those hooked on fossil fuels) can go green in a fair and inclusive way. This is not just politics or altruism; it’s a growth strategy for a competitive, climate-neutral European economy.

Why Ecommerce and Retail Can’t Ignore It

So, what does this sweeping environmental policy have to do with your ecommerce operation or retail brand? In a word: everything. The Green Deal’s tentacles reach into sustainable supply chains, energy efficiency, packaging, shipping, and yes, even how you handle returns.

European regulators and civil society alike are increasingly scrutinizing the environmental impacts of products from cradle to grave. If you’re selling in the EU (or even just shipping to Europe), you’ll face new expectations about sustainable industry practices and corporate sustainability. For instance, the push for a circular economy means you’ll need to design products (and processes) for reuse, repair, or recycling instead of the landfill. The EU’s Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025 and will generally apply from 12 August 2026, bringing stricter EU-wide rules on packaging, reuse, and recyclability. The EU Biodiversity Strategy and sustainable development goals embedded in the Green Deal signal that everything from your sourcing to your delivery methods should tread lighter on the planet.

And let’s not forget carbon. The EU’s climate agenda could soon touch logistics directly, think emissions trading for the transportation sector or fuel taxes for shipping. If you’re running an ecommerce fulfillment operation, those delivery vans and long-haul trucks are on the radar. The power sector that charges your warehouses is shifting to renewable energy sources, and energy-intensive data centers and industrial processes are expected to become more energy-efficient or face penalties. The bottom line: whether it’s reducing greenhouse gas pollution or minimizing waste, EU policies are going to impact how you source, make, package, and deliver goods.

The Hidden Sustainability Sinkhole: Online Returns

Okay, now for the plot twist, one area that’s often overlooked in sustainability plans is ecommerce returns. Yes, that seemingly mundane process of customers sending stuff back is actually a huge sustainability sinkhole. Online returns have exploded alongside the ecommerce boom, and with them comes a truckload (literally) of emissions and waste.

Consider this: NRF and Happy Returns estimated that 16.9% of annual retail sales were returned in 2024, and 19.3% of online sales were expected to be returned in 2025. Online apparel return rates are materially higher than the overall average; Coresight Research estimated the average return rate of online apparel orders at 24.4% for the 12 months ended March 6, 2023. Each return typically means extra shipping, additional packaging, and sometimes scrapping of perfectly good products. In 2023, Optoro reported that returns amounted to 8.4 billion pounds of landfill waste, showing that the landfill burden remains enormous. Optoro-cited materials continue to attribute roughly 24 million metric tons of CO2 emissions to returns. Let that sink in: all that back-and-forth shipping and wasted product is pumping out greenhouse gases, undermining the fight against climate change.

From a climate neutrality standpoint, returns are a big problem. One report found that the transport phase typically adds up to 30% to the emissions of the initial delivery. And if those returns end up destroyed or in a dump, it’s not just a carbon hit, it’s a failure of the circular economy model. The circular economy action plan in the EU Green Deal aims to design waste out of the system, yet here we are literally throwing away products by the ton. Global greenhouse gas emissions from freight are rising, and unnecessary return shipments are part of the story.

Then there’s packaging waste. Online shopping already uses several times more packaging per item than traditional retail. Returns often mean even more packaging, sometimes new boxes, plastic wrap, and labels, contributing to the piles of packaging waste that EU member states are under pressure to reduce. With Europe pushing initiatives to curb single-use packaging and boost recycling, the current returns status quo (which can be “one-and-done” use of packaging and product) just isn’t sustainable.

In short, ecommerce returns are a sustainability blind spot. If you’re an ecommerce pro eyeing EU markets (or just trying to run a responsible business), you can’t afford to treat returns the old way. Doing so would undermine your climate neutrality goals, rack up your carbon footprint, and possibly put you afoul of emerging regulations around waste and emissions. The climate crisis demands we find a better way to handle returns in a resource-efficient, environmentally sustainable manner.

Enter Peer-to-Peer Returns: A Game-Changer for Sustainable Ecommerce

So, how do we fix this? How can online retailers and brands slash the footprint of returns to align with the Green Deal vision of a sustainable economic model? One answer is reimagining the reverse logistics process altogether, and this is where Cahoot’s peer-to-peer ecommerce returns solution comes in. It’s a fresh approach that turns the conventional returns model on its head.

Cahoot has pioneered a peer-to-peer returns program that is cheaper, faster, and more sustainable than the status quo. Instead of shipping a return from the customer back to a distant warehouse (and then maybe to a refurb center or a new buyer), Cahoot enables customers to send that return directly to the next customer who wants the item. In essence, the returned product is instantly resold while it’s still in transit. No detour through a storage facility, no time wasted sitting on a shelf, and no extra cross-country trucking just to end up back in inventory. By skipping the warehouse and cutting out an entire leg of transportation, this model eliminates unnecessary carbon emissions and saves lots of time and money.

Here’s why this approach is a sustainability trifecta:

• Fewer Shipping Miles: Every return that goes straight to a new owner is one less trip to a centralized return center and then to a new buyer. That means burning less fossil fuel in transit. Fewer trucks on the road and planes in the air = lower carbon emissions. For a brand concerned with reducing greenhouse gas emissions, this is a big win.
• Reuse of Products (Circular Economy in Action): Instead of products being discarded or sitting idle, they get a second life immediately. This directly supports the circular economy ethos of the EU Green Deal by keeping products in use longer and out of the waste stream. It’s essentially enabling reuse and product life extension at scale, which is exactly what a sustainable supply chain should do.
• Less Packaging Waste: If the original packaging can be used to send the item to the next customer, we avoid consuming new boxes and plastic. That cuts down on packaging waste and the demand for new packing materials (which in turn saves resources and energy). It aligns with the EU’s push for packaging reuse and waste reduction.
• Energy Efficiency & Reduced Processing: No need for energy-intensive warehouse operations to check, repackage, and restock the item. Skipping the warehouse not only saves labor but also electricity and heating/cooling at facilities, contributing to overall energy efficiency in the logistics chain.
• Data & Optimization: The Cahoot system uses AI to grade and approve returned items for resale, ensuring only quality products circulate to the next buyer. This kind of smart system can eventually tie into a better industrial strategy for sustainability, using tech to minimize waste. It also provides transparency that can be reported in sustainability metrics (imagine telling your customers or regulators how many pounds of goods you kept out of landfill via direct resell!).

Crucially, this peer-to-peer model helps companies tackle both climate impact and compliance with emerging rules without sacrificing the bottom line. It’s not philanthropy; it’s a growth strategy for the sustainable era. By reselling nearly 48% of returns immediately through this network, brands can reclaim revenue that would otherwise be lost. They save on return shipping and warehousing costs, which is money back in the business, all while doing right by the planet. That financial incentive makes it easier to invest in green improvements elsewhere, too. In a way, Cahoot’s solution turns environmental sustainability into a competitive advantage rather than a cost center.

Aligning with EU Goals and Beyond

EU lawmakers postponed the application dates for parts of the CSRD and CSDDD in 2025 and then gave final approval to a broader simplification package on 24 February 2026, so companies in scope should check the updated reporting timeline before relying on earlier compliance assumptions.

It’s almost like Cahoot’s returns solution was tailor-made for the EU Green Deal’s objectives. It checks multiple boxes on the EU’s sustainability agenda:

• Climate Neutrality & GHG Reduction: Fewer transportation emissions contribute to the EU’s emissions targets (directly reducing the carbon footprint of ecommerce operations).
• Circular Economy & Waste Reduction: Immediate reuse of returned products means less waste, supporting EU targets to cut waste and increase product longevity.
• Sustainable Industry Innovation: This model exemplifies how industrial strategy and innovation can solve environmental problems, exactly the kind of private-sector initiative EU policymakers encourage to meet climate goals.
• Consumer Engagement in Sustainability: European consumers are increasingly eco-conscious. Offering a peer-to-peer returns option signals a brand’s commitment to sustainability, aligning with the European Climate Pact spirit of involving citizens and civil society in the green transition. Shoppers get to participate by buying a “like-new” product at a discount, which comes with the feel-good factor of saving an item from the dumpster.
• Corporate Sustainability Reporting: As EU institutions move toward stricter reporting on environmental impact (see: Corporate Sustainability Reporting Directive), a company using innovative returns solutions can better report reductions in emissions and waste. It’s a concrete action to show investors and regulators that the company is serious about sustainable development and not just greenwashing.

Lastly, let’s zoom out. The United Nations and the global community are watching pioneers in sustainability. If a solution like Cahoot’s can scale, it doesn’t just help meet EU mandates; it could influence best practices worldwide. The European Green Deal might be the catalyst, but the idea of a sustainable economic model for ecommerce has no borders. Cutting down carbon and waste in returns is just smart business for the planet, whether you’re in the EU, the US, or anywhere else.

Conclusion: Turning Mandates into Opportunities

The EU Green Deal is transforming the rules of the game for businesses, especially in retail and ecommerce. Rather than seeing it as a compliance headache, savvy brands see a chance to innovate. Returns, often treated as a boring afterthought, are actually a golden opportunity to boost sustainability and efficiency in one go. By embracing concepts like peer-to-peer returns, ecommerce companies can not only reduce greenhouse gas emissions and waste in line with EU goals, but also surprise themselves by improving customer loyalty (eco-conscious shoppers love green initiatives) and recovering revenue that used to be written off.

The road to a climate-neutral economy will require every tool in the toolbox. Rethinking returns is just one piece of the puzzle, but it’s a powerful one. It shows how a fair and inclusive green transition can also be good for business. So as the EU leads with ambitious climate and environmental objectives, it’s time for ecommerce operations to get creative and align with those policies. The Green Deal mandates might feel daunting, but with the right strategies (and a little ingenuity from companies like Cahoot), we can turn sustainability into a win-win: for the planet and the profit line. In the end, saving the world and running a competitive economy don’t have to be at odds; the Green Deal is nudging us to prove it, one return shipment at a time.

Written By:

Manish Chowdhary

Manish Chowdhary is the founder and CEO of Cahoot, the most comprehensive post-purchase suite for ecommerce brands. A serial entrepreneur and industry thought leader, Manish has decades of experience building technologies that simplify ecommerce logistics—from order fulfillment to returns. His insights help brands stay ahead of market shifts and operational challenges.