PPWR for online sellers and e-commerce: what the packaging rules mean for you

This is general information about Regulation (EU) 2025/40, screening-level and not legal advice. Some detail depends on implementing acts still pending as of 9 July 2026. Confirm anything you act on with qualified counsel or an accredited body.

Most online sellers think about packaging as the thing on the product. The retail box, the label, maybe a poly bag. Under Regulation (EU) 2025/40 that is only one layer. The moment you pick an order, drop it in a bigger carton, pad it with paper or air pillows, seal it with tape and slap on a mailer — you have created more packaging, and you are on the hook for it. This guide walks the parts that are new for e-commerce, and where the money and the deadlines land.

Which of your packaging is caught

The regulation covers packaging at every level, and it names your shipping layer specifically. Three categories matter for a typical online order:

• Primary (sales) packaging — what holds the product itself: the retail box, bottle, blister, poly bag. This is caught whether you make it or buy the product pre-packed.
• Transport packaging — the outer carton, pallet wrap and protective materials used to move goods. Under Regulation (EU) 2025/40 this level carries its own duties.
• E-commerce packaging — the regulation defines this as transport packaging used to deliver a product sold online (or through another distance contract) directly to a consumer. That is the box, mailer, tape and void fill you add in the warehouse. It counts.

So the honest answer to "does my shipping box count?" is yes. If you buy blank cartons and fill them yourself, you are the producer of that e-commerce packaging and you carry the obligations for it. That single fact is what catches out sellers who assumed compliance was their supplier's problem.

The empty-space limit — the one that changes your boxes

Article 10 of Regulation (EU) 2025/40 caps the empty-space ratio at 50% for grouped, transport and e-commerce packaging, from 1 January 2030. Put plainly: the void inside the box — the gap around the product and its primary packaging, plus the fillers you use to take up that gap — must not exceed half the box volume.

This is aimed squarely at the "big box, small product" habit. A phone case rattling around in a 30 cm carton, a paperback shipped in a mailer built for a hardback, three items packed in a carton sized for ten. If more than half the box is air and void fill, that packaging needs redesigning before 2030.

Two practical notes. First, the general minimisation duty under Article 10 — packaging reduced to the weight and volume needed for function and safety — applies from day one, 12 August 2026, and you must hold technical documentation showing you have done it. Second, the precise method for measuring the empty-space ratio for a given format is set out in the regulation and its annexes, and the harmonised standards behind it are still being firmed up. Treat the 50% cap as fixed and the exact measurement procedure as something to confirm for your format. There is more detail in the minimisation and empty-space guide.

Minimisation and recyclability, for a warehouse

Beyond the empty-space number, two design duties reshape what you buy in bulk. Minimisation means no packaging layer without a functional reason — the extra sleeve, the double box, the oversized mailer all need justifying or dropping. Recyclability means the outer packaging you standardise on has to hit the design-for-recycling grades that come in from 2030; packaging that cannot be graded recyclable eventually cannot be placed on the market. For a seller shipping thousands of parcels, these are procurement decisions: right-size your carton range, cut the void fill, and pick outer materials that grade well. Our recyclability grades guide covers the A/B/C scale and the cut-off dates.

EPR — register and pay in every country you sell into

This is the obligation most online sellers underestimate, because it is not a design change — it is a registration and a recurring bill, in each market. Under Article 45 of Regulation (EU) 2025/40, if you make packaging available in a member state you are a producer for extended producer responsibility there, and you must register and pay fees in that state. Ship to Germany, France and Spain and you register in Germany, France and Spain. There is no single EU-wide packaging EPR registration today.

Fees are eco-modulated — adjusted by how recyclable the packaging is — so the design decisions above feed straight into your ongoing cost. Better-graded packaging, lower fee. The EPR guide goes into the national registers (LUCID in Germany, and the equivalents elsewhere) and how the producer role is decided.

Two e-commerce-specific twists:

• Non-EU sellers need an authorised representative. If you have no establishment in a member state — a US, UK or Asian brand shipping into the EU — you must appoint an authorised representative for EPR in each member state where you make packaging available, to carry out your producer obligations there. That is a named party, per market, not a formality you can defer.
• Marketplaces will check you. Online marketplaces carry their own duties to verify that the third-party sellers listing through them meet their producer obligations. In practice a marketplace can ask for your EPR registration numbers and restrict or de-list sellers who cannot produce them. If you sell through a marketplace as well as your own store, expect to be asked.

The timeline for e-commerce

Regulation (EU) 2025/40 applies from 12 August 2026. From that date the framework is live: the minimisation duty, the EPR registration obligations and the marketplace checks all bite. The design rules with hard numbers come later — the 50% empty-space cap and the recyclability design requirements apply from 1 January 2030, with further recycled-content and recyclability steps through the 2030s. So the near-term work is registration and documentation; the 2030 work is the box redesign. The full timeline guide lays out every date.

Frequently asked questions