PPWR for Online Retail: More Than Just Licensing

The PPWR makes packaging compliance in online retail about more than registration and scheme participation. Regulation (EU) 2025/40 generally applies from 12 August 2026, but individual requirements start later. An e-commerce magazin article published on 29 October 2026 highlights why retailers also need to review box selection, supplier evidence and packing workflows.

PPWR: Understanding the 50% empty-space limit

Article 24 sets a maximum 50% empty-space ratio for filled grouped, transport and e-commerce packaging. It applies by 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later. The limit therefore does not automatically apply to every parcel from 1 January 2030.

The Commission must establish the calculation method by 12 February 2028. Paper padding, air cushions, bubble wrap and foam count towards empty space as filling materials. Relevant special conditions and exemptions also need assessment. Sales packaging has a separate rule: by 12 February 2028, the operator filling it must reduce empty space to the minimum necessary for functionality, including product protection. That rule does not impose a universal numerical 50% cap on sales packaging.

Recyclability and recycled content have different timetables

There is no single start date for all requirements. For recyclability grades A, B or C, Article 6 refers to 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. A material combination is not automatically prohibited merely because of its name; its actual construction and the applicable criteria matter.

Article 7 distinguishes plastic packaging categories. The 35% post-consumer recycled-content target covers “other plastic packaging”, rather than every plastic pack without food contact. Contact-sensitive packaging and single-use plastic beverage bottles have separate targets. Application begins by 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later. Exemptions and the calculation per manufacturing plant and year need separate consideration.

PPWR conformity: Check the role and applicable requirements

Manufacturers must demonstrate compliance with the requirements that apply and prepare the necessary technical documentation and EU declaration of conformity. Retention is five years for single-use packaging and ten years for reusable packaging, measured from placing on the market. Importers have their own checking and document-availability duties. Businesses should not declare future recyclability requirements already satisfied before those requirements apply.

The Article 5 PFAS limits for food-contact packaging have applied since 12 August 2026. The Commission’s guidance explains the relationship between general application, conformity assessment and later detailed rules.

Authorised representatives and fulfilment providers

Direct cross-border sales to end users can trigger Article 45(3) EPR representative requirements in the destination country. The Commission still describes relief for small businesses as a proposal. A negotiating position does not replace an amendment that has entered into force.

For fulfilment, distinguish the operator filling packaging from manufacturer and EPR producer responsibilities. The empty-space duty concerns the filling operator, which may be the fulfilment provider. Contracts should allocate tasks and evidence clearly but cannot override statutory responsibilities.

What online retailers can prepare now

• Capture product data: Record dimensions, volume and protection requirements digitally.
• Review box sizes: Plan suitable formats and packaging trials before reducing material.
• Request evidence: Ask suppliers for material data and conformity documents appropriate to their role.
• Map stocks and dates: Check placing-on-market dates and transitional provisions instead of using up non-compliant packaging without assessment.
• Review destination markets: Assess registration, scheme participation and representative requirements separately for each country.

ECOPV-EU supports online and mail-order retailers with packaging registration, scheme participation and EPR representation. This article provides general information and does not constitute legal advice.

Sources: PPWR, particularly Articles 5–7, 15, 18, 24 and 45; Commission guidance and information; e-commerce magazin, 29 October 2026. Checked on 3 November 2026.

AI-generated concept illustration of a packing station; not a measured empty-space calculation.