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Shopware & E-Commerce

E-commerce compliance calendar 2027: every EU deadline for Shopware merchants

Between November 20, 2026 and January 1, 2027 five sets of rules take effect or move to a new stage for online merchants in the EU: the Consumer Credit Directive, the AI Act's transition period, the new product liability regime, the Deforestation Regulation and, in Germany, mandatory e-invoicing. 2027 brings the battery passport, the customs reform and the Cyber Resilience Act. Anyone trying to keep that as a list in their head will lose track.

Hence this calendar: every deadline that affects a Shopware store, in chronological order from November 2026 to 2030, with the question "who does it hit and what has to happen in the store?" – and with a primary source. We checked every date on November 7, 2026 against the legal text, the EU Official Journal or the competent authority, because quite a few have shifted from the original texts. Where we only had secondary sources, it says so. German transposition acts are named where the directive leaves room; the EU regulations apply the same way in every member state.

The next four deadlines

  • November 20, 2026 – Consumer Credit Directive: your own invoice payment stays exempt if you defer yourself, interest-free and with at most 50 days to pay; third-party installment and "pay later" offers now fall under consumer credit law even below €200.
  • December 2, 2026 – AI Act: the transition period for machine-readable marking by providers of older AI systems ends. Your deployer duties – chatbot disclosure, visible labelling – have applied unchanged since August 2, 2026.
  • December 9, 2026 – product liability: software is a product, fulfilment service providers are liable, and every distributor is liable who doesn't name its supplier within one month of being asked.
  • December 30, 2026 – EUDR: due diligence for wood, coffee, cocoa, soy, palm oil, cattle and rubber; downstream traders need their suppliers' reference numbers. Books have been removed from the annex.

As with every legal topic here: we're software engineers, not lawyers. The calendar is a working basis for you and your legal counsel, not legal advice.

The calendar: November 2026 to 2030

Deadlines for online merchants from November 2026 to 2030 (as of November 7, 2026)
DateRulesWho it hitsWhat to do in the storeFines / status
Nov 20, 2026Consumer Credit Directive (EU) 2023/2225, German act BGBl. 2026 I No. 139B2C stores with invoice or installment paymentOwn invoice payment only up to 50 days, interest-free, no third party; checkout ads with “0 %” need standard informationcivil law; in force
Dec 2, 2026AI Act, Art. 111(4) (Digital Omnibus)Providers of older generative AI systemsEnd of the transition for machine-readable marking; deployer duties apply since Aug 2, 2026up to €15 million or 3 %; in force
Dec 9, 2026Product Liability Directive (EU) 2024/2853, German act BGBl. 2026 I No. 321Manufacturers, importers, fulfilment providers, distributors, marketplacesKeep supplier data per item (one-month deadline); software counts as a productcivil liability, no fine; published
Dec 30, 2026EUDR (EU) 2023/1115 as amended by 2025/2650Large and medium traders of wood, coffee, cocoa, soy, palm oil, cattle, rubberRecord suppliers’ reference numbers; books are removedat least 4 % of EU turnover; in force
Jan 1, 2027German e-invoicing, Section 27(38) VAT ActB2B issuers with prior-year turnover above €800,000Issue XRechnung or ZUGFeRD, no PDFno fine, risk to input tax deduction; confirmed
Jan 12, 2027Data Act (EU) 2023/2854, Art. 29Cloud and hosting providersSwitching charges disappear – relevant to the hosting contractin force
Feb 18, 2027Battery Regulation (EU) 2023/1542, Art. 13 and 77Manufacturers and importers; distributors indirectlyQR code on all batteries; battery passport for e-bike, industrial and EV batteriesnational; date fixed, implementing act delayed
Jun 30, 2027EUDRMicro and small enterprisesas Dec 30, 2026, except timber under the old Timber Regulation4 %; in force
Aug 18, 2027Battery Regulation, Art. 48Companies with €40 million turnover or moreSupply chain due diligence for raw materialspostponed from 2025
Sep 21, 2027Union Customs Code (EU) 2026/2108Importers, distance sellers, platformsMain part of the customs reform applies; e-commerce rules from Jul 1, 2028published Sep 19, 2026
Oct 31 / Dec 31, 2027German Packaging Implementation Act, ZSVR approvalProducer responsibility organisations / producers without system participation dutyApply for approval of own take-back and transport packagingSection 66 VerpackDG; in force
Dec 2, 2027AI Act, high-risk under Annex IIIDeployers of standalone high-risk AIAI credit checks in checkout: deployer duties under Art. 26€15 million or 3 %; postponed from Aug 2, 2026
Dec 11, 2027Cyber Resilience Act (EU) 2024/2847Manufacturers of software and IoT goods, plugin vendors included; distributorsCE, declaration of conformity, vulnerability handling, five years of updates; distributors check CE€15 million / 2.5 % or €10 million / 2 %; in force
Dec 30, 2027EUDR, new products in Annex ITraders of the newly added productsCheck the range against the updated Annex I4 %; adopted
Jan 1, 2028German e-invoicing, Section 27(38) nos. 2 and 3 VAT ActAll businessesE-invoices for all B2B invoices, end of the EDI exceptionconfirmed
Jul 1, 2028Customs: Regulation (EU) 2026/382 and Customs Code Art. 287Third-country distance sellers, platforms, importersEnd of the €3 flat duty; launch of the EU customs data platform, platforms become “deemed importers”published
Aug 2, 2028AI Act, high-risk under Annex IManufacturers of regulated products with AIRelevant to stores only as distributors of such productspostponed from Aug 2, 2027
Aug 12, 2028PPWR (EU) 2025/40, Art. 12Everyone placing packaging on the market – printed own-brand boxes includedHarmonised material label; or 24 months after the implementing actsup to €200,000 in Germany; date subject to change
Sep 27, 2028Section 15b German UWG expiresMerchants with legacy stock bearing old environmental claimsSell off or relabel remaining stock with “climate neutral” claimsunfair-competition claims, no fine
Jan 1, 2030PPWR, Art. 6, 24 and 29Shippers, online merchantsEmpty space at most 50 %, recyclability grades A to C, 40 % reuse for transport packagingup to €200,000 in Germany; or three years after the implementing act
Jun 27, 2030German BFSG, Section 38(1) (EAA Art. 32)Service providers with old products and old contractsOld contracts only – the store itself has had to be accessible since Jun 28, 2025up to €100,000 in Germany; in force

Every date checked on November 7, 2026 against the primary source (EUR-Lex, German law databases, authority pages); details and sources are in the sections below. PPWR dates for labelling and empty space depend on implementing acts and may slip.

What already applies since 2024 – and is often still unfinished

The calendar starts with November 2026. Ten obligations are already in force and still being worked through in many stores:

What already applies since 2024 – and is often still unfinished
SinceRulesShort status
Dec 13, 2024General Product Safety Regulation (EU) 2023/988Manufacturer name with postal and email address, responsible person for non-EU manufacturers, product image and type, warnings in the local language – in the listing, not in a PDF. Enforcement is mostly via warning letters
Jun 28, 2025European Accessibility Act (Germany: BFSG)B2C stores accessible without grace period, microenterprises exempt – checklist for Shopware
Aug 18, 2025Battery Regulation, Chapter VIIIRegistration, take-back duty also in distance selling
Jul 1, 2026End of the €150 customs exemption, €3 flat duty per item until Jul 1, 2028Consignments up to €150 to EU consumers
Jul 19, 2026Ecodesign Regulation: ban on destroying unsold clothing, accessories and footwearLarge companies; medium-sized from 2030; records for five years
Jul 23 / 31, 2026Right to repair, German act BGBl. 2026 I No. 212Choice notice and twelve months' extension for contracts from Jul 31, 2026 – the law in detail
Aug 2, 2026AI Act, Art. 50 transparencyChatbot disclosure and visible labelling – labelling obligation for stores
Aug 12, 2026PPWR and German Packaging Implementation ActPackaging register stays; authorised representative for foreign direct shippers to Germany
Sep 11, 2026Cyber Resilience Act, Art. 14 reporting duties24-hour early warning, 72-hour notification via the ENISA platform
Sep 27, 2026EmpCo: unfair-competition amendments and information dutiesHarmonised warranty notice, guarantee label, update period, repairability – duties on the product page

The deadlines one by one

November 20, 2026: Consumer Credit Directive

Directive (EU) 2023/2225 applies from November 20, 2026; Germany transposed it with the act of May 12, 2026 (BGBl. 2026 I No. 139). The point for stores sits in the exemption for deferred payment: it survives only if you defer, interest-free, with no charges beyond limited late fees, full payment within 50 days and no third party involved. Large online providers get only 14 days. Anything with a payment service provider – invoice payment via Klarna, PayPal or Ratepay, installments, "pay later" – is consumer credit, and the old €200 minimum is gone. The duties then sit with the lender, but your checkout advertising with "0 %" or "buy now, pay later" needs the standard information.

December 2, 2026: AI Act, end of the transition

The Digital Omnibus (Regulation (EU) 2026/1744, in force since July 27, 2026) postponed the high-risk duties – Annex III to December 2, 2027, Annex I to August 2, 2028 – but not the transparency duties under Art. 50. Those apply since August 2, 2026. The only relief: providers of generative systems on the market before August 2 have until December 2, 2026 for machine-readable marking of their output (new Art. 111(4)). That's a provider duty. Your deployer duties – chatbot disclosure, visible labelling of realistic AI images – don't change. Which generators already mark their images machine-readably and what a store can read from that is in our article on C2PA and IPTC metadata; the Shopware implementation is our plugin EU AI Act Compliance.

December 9, 2026: new product liability regime

Product Liability Directive (EU) 2024/2853 applies to products placed on the market from December 9, 2026; the German Bundestag passed the new Product Liability Act on October 8, 2026, published October 27 (BGBl. 2026 I No. 321). Three changes hit stores directly. First: software is a product – so are Shopware plugins, apps and agency software, with liability for missing security updates. Second: fulfilment service providers are liable when no importer or authorised representative in the EU can be reached. Third: every distributor is liable who, when asked by an injured party, doesn't name an economic operator in the EU or its supplier within one month. In practice: keep supplier and manufacturer data per item so you can deliver it within four weeks. The €500 deductible and the €85 million liability cap are gone. There are no fines – it's strict liability.

December 30, 2026 and June 30, 2027: Deforestation Regulation

After two postponements the EUDR applies from December 30, 2026 to large and medium-sized companies and from June 30, 2027 to micro and small enterprises. The amending Regulation (EU) 2025/2650 also simplified things: only the first party placing goods on the market files the due diligence statement; downstream traders receive the reference numbers and – only the first downstream one – have to record them. Books, newspapers and prints were struck from Annex I. A delegated act of September 17, 2026 adds new products that apply from December 30, 2027. Fines: at least 4 % of EU annual turnover.

January 1, 2027: issuing e-invoices in Germany

Section 27(38) of the German VAT Act is unchanged: anyone with more than €800,000 turnover in 2026 must issue structured e-invoices for domestic B2B sales from January 1, 2027 – XRechnung or ZUGFeRD, not a PDF. From January 1, 2028 it applies to everyone, and the EDI exception ends. The Ministry of Finance confirmed the timetable with its third circular of October 15, 2026. For Shopware that means: identify B2B customers in checkout (VAT ID), set up the document generator or a plugin for e-invoices. There is no dedicated fine; the pressure comes via the recipient's input tax deduction. Other member states run their own e-invoicing timetables.

February 18, 2027: battery passport and QR code

From February 18, 2027 every battery carries a QR code (Art. 13(6) Battery Regulation), and LMT batteries in e-bikes and e-scooters, industrial batteries above 2 kWh and EV batteries get the battery passport (Art. 77). The date stands; what's late is the implementing act on access rights, whose deadline passed on August 18, 2026 – the Commission announced it for the fourth quarter of 2026. For the store: product data and images with QR code, passport link in listings, take-back notices stay.

September 21, 2027 and July 1, 2028: customs reform

Regulation (EU) 2026/2108 of September 16, 2026 creates the new Union Customs Code and the EU Customs Authority. The main part applies from September 21, 2027; the distance-selling rules and the EU customs data platform for e-commerce follow on July 1, 2028 – the same day the €3 per item flat duty expires that has applied since the €150 exemption ended on July 1, 2026. After that, platforms and distance sellers become "deemed importers" with regular duty rates. An additional handling fee per distance-selling consignment has been decided; amount and start are set only by delegated act.

December 2, 2027: high-risk AI under Annex III

For most stores the high-risk part of the AI Act is far away – with one exception: AI-based creditworthiness assessment of consumers is in Annex III no. 5 b. If your checkout uses a payment provider that decides on invoice payment with AI support, you are a deployer under Art. 26 – with duties from December 2, 2027, no longer from August 2026. The provider duties sit with the service provider.

December 11, 2027: Cyber Resilience Act in full

The CRA hits stores from two sides. As a manufacturer counts anyone providing products with digital elements for payment – commercial Shopware plugins, themes, apps, IoT goods. From December 11, 2027: security by design, vulnerability handling, a software bill of materials, CE marking with declaration of conformity and security updates for at least five years. As a distributor of hardware or software you then have to check CE marking and manufacturer details (Art. 20). The reporting duties for actively exploited vulnerabilities already apply since September 11, 2026 – 24-hour early warning, 72-hour notification, final report after 14 days via the ENISA platform. Fines up to €15 million or 2.5 % for manufacturers, €10 million or 2 % for distributors.

August 12, 2028 and January 1, 2030: Packaging Regulation

The PPWR applies since August 12, 2026; its stages come later. From August 12, 2028 – or 24 months after the implementing acts, whichever is later – every package needs the harmonised material label; with printed own-brand boxes you are the packaging producer yourself. From January 1, 2030: at most 50 % empty space in e-commerce packaging, recyclability grades A to C and a 40 % reuse quota for transport packaging including shipping. In Germany fines under Section 66 VerpackDG reach €200,000.

September 27, 2028: end of the EmpCo legacy-stock rule

Section 15b of the German Unfair Competition Act, inserted on October 22, 2026, requires a proportionality test for injunction claims concerning goods placed on the market before September 27, 2026 with old environmental claims or labels – not a sell-off period, but a buffer. It expires on September 27, 2028. By then, remaining stock with "climate neutral" or generic "eco-friendly" claims has to be sold or relabelled. Websites and stores were never covered by it.

Announced, but still without a date

  • Digital Product Passport: as of November 7, 2026 there was no delegated act requiring a product passport. The first binding passport is the battery passport on February 18, 2027; textiles are expected in 2028 at the earliest.
  • Digital Fairness Act: the Commission proposal against dark patterns and subscription traps was in the work programme for the fourth quarter of 2026 and hadn't been published by early November. Probably not binding before 2029.
  • Digital Omnibus on GDPR and cookies: the Council adopted its negotiating mandate on October 21, 2026, Parliament has no position – not applicable law.

What has shifted from the original texts

What has shifted from the original texts
RulesOriginallyNow
AI Act, high-risk Annex IIIAug 2, 2026Dec 2, 2027
AI Act, high-risk Annex IAug 2, 2027Aug 2, 2028
AI Act, Art. 50(2) for legacy systemsAug 2, 2026Dec 2, 2026
EUDRDec 30, 2024, then Dec 30, 2025Dec 30, 2026 / Jun 30, 2027
Battery Regulation, due diligenceAug 18, 2025Aug 18, 2027
Battery Regulation, implementing act on passport accessAug 18, 2026open, announced for Q4 2026
€150 customs exemptionwith the customs reformbrought forward to Jul 1, 2026, flat duty until Jul 1, 2028
Textile labelling, revisionproposal Q2 2026not tabled
Digital Fairness Actproposal Q4 2026not tabled

Unchanged are consumer credit (Nov 20, 2026), product liability (Dec 9, 2026), German e-invoicing (Jan 1, 2027 and Jan 1, 2028), the battery passport (Feb 18, 2027), the CRA (Sep 11, 2026 and Dec 11, 2027) and the PPWR stages – though the PPWR dates for labelling and empty space are tied to implementing acts and may still slip.

Three sets of duties, three plugins

Three of the duties in this calendar we've turned into Shopware plugins, because theme tweaks and spreadsheets don't model them cleanly over time:

  • AI Act, Art. 50: EU AI Act Compliance implements the transparency badge, chatbot disclosure, aggregate disclosure and the evidence via an AI register – fully local, for Shopware 6.6 and 6.7, available in the store.
  • Right to repair and EmpCo: Right to Repair & EmpCo guides claims through the remedy process with a timestamped choice notice, calculates the twelve-month extension and shows repairability on the product page – for Shopware 6.7, currently on request. Which gap it fills in the store is shown in our comparison of returns plugins.
  • Accessibility, criterion 1.1.1: Alt-Text Optimizer Pro generates alt text for thousands of product images through your own OpenAI key – the most visible building block of accessibility, compared with the alternatives in our alt text generator comparison.

For the remaining duties – supplier data for product liability, EUDR reference numbers in the product master, e-invoicing, QR codes for batteries – custom adjustments are usually cheaper than another subscription. How we build Shopware plugins and what such a development costs is on our pages.

Quarterly routine: keeping the calendar current

A calendar is only as good as its upkeep. Four steps per quarter that take us an hour:

  1. Check the dates: read every deadline of the next six months once more at the primary source – EUR-Lex, the national law database or the authority's page. Postponements show up there first, not in newsletters.
  2. Match against your business: hold range, payment methods, destination countries and turnover thresholds against the "who it hits" column. New product groups (EUDR annex, Annex II of the repair directive) change the answer.
  3. Check store data: add the fields the next deadline needs to the product master – manufacturer data, reference numbers, QR code links, repairability values.
  4. Secure the evidence: for every implemented duty, record since when and how – screenshot, export, log. In a dispute what counts isn't that you did it but that you can show it.

Frequently asked questions

Which EU laws change for online merchants in 2027?

Dated 2027: German e-invoicing for issuers above €800,000 turnover (January 1), battery passport and QR code on batteries (February 18), EUDR for micro and small enterprises (June 30), the new Union Customs Code (September 21), high-risk duties of the AI Act under Annex III (December 2) and full application of the Cyber Resilience Act (December 11). Just before, at the end of 2026: the Consumer Credit Directive, the new product liability regime and the EUDR for larger companies.

Has the AI Act been postponed for stores?

Only in part. The Digital Omnibus postponed the high-risk duties to December 2, 2027 (Annex III) and August 2, 2028 (Annex I). The transparency duties under Art. 50 – chatbot disclosure, visible labelling of AI images – apply unchanged since August 2, 2026. The transition until December 2, 2026 concerns only machine-readable marking by providers of older AI systems.

What changes on December 9, 2026 in product liability?

For products placed on the market from that day, the new regime applies: software counts as a product, fulfilment service providers are liable when no EU importer can be reached, and every distributor is liable who doesn’t name its supplier or an EU economic operator within one month of being asked. The €500 deductible and the liability cap are abolished.

When does the EUDR apply to small online stores?

For micro and small enterprises established by December 31, 2024, from June 30, 2027; for everyone else from December 30, 2026. As a downstream trader you don’t file your own due diligence statement but must receive your suppliers’ reference numbers. Books and printed matter were removed from the annex.

Does a German store have to issue e-invoices from 2027?

For domestic B2B sales yes, if turnover in 2026 exceeded €800,000 – from January 1, 2027. From January 1, 2028 the duty applies to all businesses. B2C invoices aren’t affected. A structured e-invoice is XRechnung or ZUGFeRD; a PDF from the store isn’t enough. Other member states have their own e-invoicing timetables.

When is the Digital Product Passport coming?

The first binding product passport is the battery passport from February 18, 2027 for e-bike batteries, industrial batteries above 2 kWh and EV batteries. For other product groups there was no delegated act as of November 2026; a passport for textiles is expected in 2028 at the earliest.

Sources

Primary sources, retrieved November 7, 2026. Secondary sources are marked as such in the text.

Bottom line

The density of the deadlines is the problem, not their weight. None of the duties in this calendar is unsolvable for a store – but five of them land in six weeks around the turn of the year, and several hinge on data in the product master that nobody maintains today: manufacturer data, reference numbers, QR code links, update periods.

Take the table, cross out what your range and payment methods don't touch, and look at what's left. For the "what to do in the store" column it's worth working out once whether a custom adjustment or a plugin solves the task for good – and that's what we're happy to talk about in a free initial call.