The EU's new Packaging and Packaging Waste Regulation (PPWR) is the most significant overhaul of European packaging law in over 30 years. For e-commerce merchants shipping within the EU, it isn't just an environmental initiative — it's a compliance deadline with real financial and operational consequences. Shipments that use non-compliant packaging after the regulation's phase-in dates risk customs delays, carrier rejection, and fines. Understanding what PPWR requires, when it applies, and how to adjust your fulfilment workflow now is the difference between a smooth 2026 and a costly scramble.
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The Packaging and Packaging Waste Regulation — formally Regulation (EU) 2025/40 — entered into force in February 2025 and begins phasing in substantive requirements from 2026 onward. It replaces Directive 94/62/EC, which had governed EU packaging waste since 1994. Unlike the old directive, which required member states to pass their own implementing legislation, the new regulation is directly applicable in all 27 EU member states from day one. That means no waiting for national laws — the same rules apply whether you're shipping from Amsterdam, Milan, or Warsaw.
The regulation was developed under the EU Green Deal and the Circular Economy Action Plan. Its core ambition is to reduce total packaging waste generated per capita by 15% by 2040 compared to 2018 levels, while simultaneously making all packaging placed on the EU market recyclable or reusable by 2030. For e-commerce operators, the most operationally impactful provisions are the packaging minimisation rules, the recyclability performance grades, the restrictions on certain packaging formats (including some single-use plastics), and the extended producer responsibility (EPR) obligations that now apply uniformly across the EU.
The old Directive 94/62/EC set targets but left most of the detail to member states. The result was a patchwork of national rules — Germany had its own packaging act (VerpackG), France its AGEC law, and each country enforced different recycling targets and EPR schemes. PPWR harmonises this: one regulation, one set of standards, one set of deadlines. For sellers operating across multiple EU markets, that is genuinely good news on complexity — but it also means there is nowhere to hide behind a softer national implementation.
PPWR defines packaging across three categories, all of which are relevant to e-commerce:
| Category | Definition | E-commerce examples |
|---|---|---|
| Sales packaging (primary) | Packaging presented to the end consumer as a sales unit | Product box, blister pack, poly bag around the product itself |
| Grouped packaging (secondary) | Packaging grouping a number of sales units for retail or dispatch | Multi-pack outer box, bundle wrap, gift set packaging |
| Transport packaging (tertiary) | Packaging facilitating transport and protecting from damage | Shipping carton, mailer bag, void fill, bubble wrap, paper fill, strapping |
All three categories are in scope. Crucially, the Commission has confirmed that packaging used exclusively for online order fulfilment — including e-commerce-specific outer cartons, protective inserts, and branded mailer boxes — falls within the regulation's scope. There is no carve-out for B2C e-commerce packaging.
Some sellers previously assumed that transport and secondary packaging used for e-commerce dispatch sat outside packaging waste rules because it never appears on a shop shelf. Under PPWR, this interpretation is explicitly closed off. E-commerce fulfilment packaging is in scope. If your outer cartons, mailer bags, or void fill do not meet the recyclability grade requirements by 2030, you will be placing non-compliant packaging on the EU market — regardless of whether those items are ever seen in a retail context.
PPWR applies to any "economic operator" that places packaging or packaged goods on the EU market. For e-commerce, the key actors are producers (brands that create packaged goods), packers and fillers (fulfilment centres that pack orders), and importers introducing packaged goods from outside the EU. If your warehouse is in the EU and you pack orders there, you are a packer/filler under PPWR. If you are a brand selling your own packaged products, you are a producer. Many e-commerce merchants are both.
PPWR does include provisions for micro-enterprises (fewer than 10 employees, annual turnover or balance sheet below €2 million), who may be exempt from certain reuse obligations. However, the core requirements — recyclability grades, minimisation rules, labelling, and EPR registration — apply regardless of company size once you are placing packaging on the EU market. There is no volume threshold below which the regulation simply does not apply.
Sellers based outside the EU that sell into the EU via direct-to-consumer channels or through EU-based marketplaces are also in scope, provided their packaged goods enter the EU market. Marketplaces facilitating those sales may be treated as the "responsible economic operator" if the non-EU seller has not appointed an EU-authorised representative. If you sell on Amazon.eu, Zalando, or any EU marketplace and ship packaged goods into the EU, PPWR applies to you.
Packaging compliance meant navigating 27 different national laws. A German seller needed VerpackG registration via LUCID; a French seller needed AGEC compliance; an Italian seller dealt with CONAI. Rules varied, EPR fees differed, and cross-border sellers faced a compliance maze.
One regulation, one set of requirements, directly applicable across all 27 EU member states. Sellers shipping across the EU face a unified rulebook — simpler to audit, simpler to document, and with consistent recyclability and minimisation standards for every market.
PPWR contains over 60 articles covering everything from design standards to EPR schemes. For e-commerce fulfilment teams, the requirements below have the most direct operational impact.
From 2030, the ratio of empty space in packaging (air space relative to the total pack volume) must not exceed 40%. For transport packaging specifically, this means that if you routinely ship small products in large cartons padded out with void fill, you will need to rationalise your carton sizes. The 40% threshold is measured as the volume of the packaged product as a proportion of the inner volume of the packaging — not the weight of void fill used.
All packaging placed on the EU market must be recyclable, subject to four performance grades defined by the European Commission in delegated acts. The grades run from A (recyclable at scale) to D (not recyclable under current conditions). From 2030, packaging must achieve at least grade C or above. From 2035, only grades A and B will be permitted. Grade D packaging — which includes many multi-layer plastic laminates, metalised films, and certain coated papers — will be prohibited from the EU market from 2035.
For economic operators with more than 1,000 transport packaging units per year (a threshold most mid-to-large e-commerce operations will exceed), PPWR sets reuse targets. By 2030, 10% of transport packaging must be offered in reusable form; by 2040, this rises to 50%. The regulation requires that end consumers are able to return reusable packaging at the point of delivery or via collection points — meaning this is not a purely internal supply-chain change but affects your reverse logistics setup.
From 2028, all packaging must carry a harmonised label indicating: the material composition of each packaging component, the recyclability grade, and (where applicable) whether the packaging is reusable. The label must be machine-readable (QR code linking to a digital product passport or equivalent data carrier). For high-volume e-commerce operations printing their own packaging, this means updating artwork and print specifications before the 2028 deadline.
PPWR restricts or prohibits certain substances in packaging, including PFAS (per- and polyfluoroalkyl substances) used in grease-resistant paper packaging (common in food e-commerce) and certain heavy metals. Some of these restrictions apply from 2026, earlier than the main minimisation and recyclability deadlines.
PPWR uses a phased approach, with different obligations activating at different dates. The table below summarises the key milestones relevant to e-commerce operators.
| Date | Obligation | Who it applies to |
|---|---|---|
| February 2025 | PPWR enters into force | All EU economic operators |
| 2026 (delegated acts) | Recyclability performance grade criteria published; PFAS and substance restrictions begin | All packaging producers and importers |
| 2028 | Harmonised labelling (including QR code / digital product passport) mandatory for all new packaging | All economic operators placing packaging on the EU market |
| 2030 | All packaging must achieve recyclability grade C or above; 40% empty space limit applies; 10% reuse target for transport packaging (operators >1,000 units/year) | All EU economic operators; reuse target for larger operators |
| 2035 | Only recyclability grades A and B permitted; grade C and D packaging prohibited | All EU economic operators |
| 2040 | 50% reuse target for transport packaging | Operators above the 1,000 unit threshold |
Switching packaging suppliers, redesigning carton sizes, and renegotiating contracts with 3PLs takes time — often 12 to 18 months for mid-size operations. The 2030 deadlines sound distant, but the delegated acts defining exactly which materials meet each recyclability grade will be published in 2026. Once those criteria are confirmed, you need time to test alternatives, update artwork for 2028 labelling, and train your warehouse team. Merchants who begin their packaging audit in 2026 will have far more supplier options and negotiating leverage than those who wait until 2029.
Because PPWR is a regulation (not a directive), the core requirements are identical across all 27 member states. However, national authorities retain enforcement power, and some member states are also running parallel national schemes that interact with PPWR obligations.
Germany already has one of the EU's most rigorous packaging laws: the Verpackungsgesetz (VerpackG), which requires all sellers shipping packaged goods to end consumers in Germany to register with the LUCID packaging register at verpackungsregister.org and participate in a licensed dual-system EPR scheme. PPWR does not replace VerpackG immediately — both apply in parallel during the transition. Germany's Umweltbundesamt (Federal Environment Agency) has indicated that PPWR's harmonised recyclability grades will be incorporated into VerpackG enforcement guidance from 2026. For sellers already compliant with VerpackG, the additional PPWR layer is largely additive rather than contradictory.
France's AGEC law (Anti-Gaspillage pour une Économie Circulaire) predates PPWR and introduced several measures — including a phase-out of single-use plastics and mandatory EPR for packaging — that align with PPWR's direction. French sellers already participating in an eco-organisation (such as Citeo) should review whether their declared packaging volumes and material categories need updating to reflect PPWR's expanded scope. The French Ministry for Ecological Transition is expected to publish PPWR implementation guidance for existing AGEC participants in late 2025.
Member states without pre-existing national packaging regulations equivalent to VerpackG or AGEC will rely entirely on PPWR as implemented through their national competent authorities. Italy's existing CONAI system and Spain's ECOEMBES packaging recovery scheme will need to align with PPWR's harmonised EPR producer responsibility rules by the dates specified in PPWR's EPR chapter. Sellers participating in those national schemes should watch for updated guidance from their national EPR administrators.
Compliance with PPWR starts with knowing exactly what packaging you use, in what quantities, made from what materials — and then mapping each against the regulation's requirements. Below is a practical process for e-commerce fulfilment teams.
List every packaging type you use: outer cartons, mailer bags, poly bags, tissue paper, void fill, tape, labels, inserts. For each, record: material composition, dimensions, average volume utilisation rate, and annual usage volume.
Once the European Commission publishes its delegated acts on recyclability performance grades (expected 2026), cross-reference each packaging material against the grade criteria. Flag any materials that fall into grade C or D — these will need to be replaced before 2030 and 2035 respectively.
For each carton size you use, calculate the average ratio of product volume to inner carton volume across your order history. Any carton size averaging more than 40% empty space will be non-compliant from 2030. Identify which SKUs or product categories are driving the worst ratios.
If your annual transport packaging volume exceeds 1,000 units (virtually guaranteed for any active e-commerce operation), you are subject to the reuse targets. Evaluate whether your carriers and 3PL partners support return flows for reusable transport packaging. This is a supply chain change that requires coordination beyond your own warehouse.
Work with your packaging designer or supplier to plan the harmonised label layout (material composition + recyclability grade + QR code) for all packaging that will be in use from 2028. Build the QR code data infrastructure — or confirm with your EPR scheme administrator that they will provide the data carrier service.
If you are already registered with a national EPR scheme (LUCID in Germany, Citeo in France, CONAI in Italy, ECOEMBES in Spain), review whether your existing declarations cover all packaging types now in scope under PPWR. The expanded definition of "packaging" in PPWR may bring items previously treated as non-packaging materials into scope for EPR fee calculation.
One of the less obvious compliance challenges PPWR creates is operational: if you need to assign the right package to every order consistently, doing that manually at any meaningful volume is not realistic. This is where ShippyPro Automation becomes a compliance tool, not just an efficiency tool.
ShippyPro's Automation feature uses a visual workflow builder structured around triggers, conditions, and actions. When an order is imported, a workflow can fire an Add parcels action that automatically assigns a pre-configured compliant package to that order — no manual intervention needed. The key is the setup work you do beforehand: define your PPWR-compliant package sizes in the My Packages section, then build workflows that assign the right package based on order conditions. Instead of warehouse staff making individual packaging decisions (with all the inconsistency that implies), the system applies the rule consistently at the moment each order arrives.
A practical PPWR-ready Automation setup works by mapping your pre-audited, compliant package sizes to specific products or order profiles. The conditions available within a workflow include product name, SKU, EAN, product weight, and item quantity — as well as order-level attributes like destination country, store, delivery option, and payment method. In practice this means you can build workflows such as: assign Package A (your smallest compliant box) to all orders containing SKUs from a specific product category; assign Package B to orders with item quantity above five; or route orders destined for Germany to a specific compliant mailer format. The ShippyPro shipping platform runs these workflows automatically across all incoming orders without manual intervention.
Because ShippyPro Automation assigns packages based on product identity and order attributes (not automatic dimensional calculation), the compliance work happens at setup time: audit your SKU range against your package sizes now, identify which combinations produce more than 40% empty space, and configure your workflows to route those SKUs to a smaller compliant package. Done once, enforced automatically on every order from that point forward.
ShippyPro Automation triggers on order import, which means it works with whatever sales channels and stores you have connected. Orders flowing in from Shopify, WooCommerce, Magento, or any of ShippyPro's 80+ marketplace and store integrations are processed through your packaging workflows automatically. For merchants building custom fulfilment pipelines, ShippyPro's API allows packaging assignment logic to be triggered directly from your OMS or WMS, so compliance rules apply regardless of which channel the order originates from.
PPWR and national EPR schemes require annual declarations of packaging volumes placed on the market, broken down by material type. If your shipping platform records which packaging type was assigned to each order, generating those EPR reports becomes straightforward: filter by packaging type, sum the volumes, and export to your EPR scheme's declaration format. Without that data, you are estimating — and EPR auditors increasingly expect precise figures, not approximations. The invoice analysis and reporting tools within a shipping platform can support this documentation workflow. Pair it with the track and trace data to build a complete per-shipment record for compliance audits.
Based on the pattern of errors seen across European packaging EPR compliance programmes, the following mistakes are the most likely to create problems for e-commerce merchants under PPWR.
| Mistake | Why it happens | How to avoid it |
|---|---|---|
| Treating PPWR as a future problem | The 2030 main deadlines feel distant; other priorities win | The 2026 substance restrictions and 2028 labelling requirements are immediate. Start the audit now. |
| Underreporting packaging volumes to EPR schemes | Companies forget to include secondary and transport packaging in their declarations | PPWR explicitly includes all three packaging categories. Audit every packaging touchpoint in your fulfilment process, not just product boxes. |
| Assuming supplier compliance equals your compliance | "Our packaging supplier said their materials are recyclable" | PPWR places responsibility on the economic operator placing packaging on the market — that is you, not your supplier. Get written material data sheets and cross-reference against the published recyclability grade criteria. |
| Ignoring the reuse obligation threshold | Operators assume reuse targets only apply to very large companies | 1,000 transport packaging units per year is a low threshold. Most e-commerce merchants above early startup stage will be in scope. Plan your reverse logistics accordingly. |
| Not updating EPR declarations after PPWR scope expansion | Existing registrations cover only what was previously required under national law | Review your national EPR declarations against PPWR's expanded packaging definition. Items previously treated as non-packaging materials may now be in scope for EPR fees. |
| Missing the 2028 labelling deadline for existing packaging stock | Companies have large stocks of pre-printed packaging without PPWR labels | PPWR includes a transition period for existing packaging stock, but new packaging produced after the 2028 date must be labelled. Plan your stock rotation so you are not using non-labelled packaging after the cutoff. |
Under PPWR, national enforcement authorities have the power to require economic operators to withdraw non-compliant packaging from the market. For e-commerce, this means your shipments could be stopped at a national level if your packaging is found to be non-compliant after a market surveillance check. This is not just a fine risk — it is an operational stop. Sellers who are not registered with the required EPR schemes or who cannot demonstrate recyclability grade compliance for their packaging face the most exposure. Do not wait for an enforcement notice to trigger your compliance programme.
The ShippyPro resources hub includes further guides on EU regulatory compliance for e-commerce merchants. For merchants also navigating customs documentation alongside PPWR, the Ship & Collect tool can help standardise shipment data across EU destinations. And if you are building PPWR compliance into a broader operational review, the rate optimiser can help you evaluate whether switching to smaller, PPWR-compliant packaging formats changes your carrier cost profile — smaller packs often qualify for lower dimensional weight charges alongside their compliance benefit.
Use the Automation workflow builder to assign pre-configured compliant packages to orders automatically — triggered by product SKU, weight, item quantity, destination, and more.
Explore Automation →Centralise all your EU shipping operations, carrier contracts, and packaging rules in one platform — with full visibility across every shipment.
See the Platform →Audit your carrier invoices and shipping data to build accurate packaging volume reports — essential for EPR declarations under PPWR.
Analyse Invoices →PPWR is not the only regulatory change hitting EU e-commerce in 2026. Read our guide to the EU customs reform and what it means for your shipments.
Read the Guide →Switching to PPWR-compliant smaller packaging often reduces dimensional weight charges. See how the rate optimiser helps you find the cheapest compliant option.
Try the Optimiser →Guides, checklists, and tools for EU e-commerce compliance, carrier setup, and shipping optimisation — all in one place.
Visit the Hub →PPWR entered into force in February 2025, but its main operational requirements phase in over time. Substance restrictions (including PFAS in food-contact packaging) begin in 2026. Harmonised labelling with QR codes becomes mandatory for all new packaging from 2028. The 40% empty space minimisation limit and the recyclability grade requirements (grade C minimum) apply from 2030. The strictest recyclability rules (grades A and B only) take effect from 2035. E-commerce sellers should start their packaging audit immediately, since supply chain changes and artwork updates take 12 to 18 months to implement.
Yes. PPWR explicitly covers all three categories of packaging: sales (primary), grouped (secondary), and transport (tertiary). Shipping cartons, mailer bags, poly bags, void fill, protective inserts, bubble wrap, and paper fill used in e-commerce fulfilment are all in scope. There is no exemption for packaging used exclusively for online order dispatch. The European Commission has confirmed that e-commerce-specific packaging formats fall within the regulation's definition of "transport packaging."
From 2030, the ratio of empty space within packaging must not exceed 40% of the total inner volume of the pack. In practice, this means the volume occupied by the product(s) must account for at least 60% of the inner volume of the packaging. The calculation uses the product's dimensional volume compared to the inner volume of the carton or mailer — not the weight of any void fill used. E-commerce merchants should calculate this ratio across their carton range using order history data and identify which carton sizes will need to be replaced or retired before the 2030 deadline.
Yes, during the transition period. PPWR and existing national packaging laws run in parallel until PPWR's harmonised EPR provisions fully supersede national schemes. In Germany, VerpackG registration via the LUCID register at verpackungsregister.org remains mandatory for all sellers shipping packaged goods to German end consumers. In France, AGEC-based obligations through schemes like Citeo also continue to apply. Sellers should maintain their existing national EPR registrations while also monitoring PPWR implementation guidance from national authorities, which is expected throughout 2025 and 2026.
ShippyPro's Automation feature uses a visual workflow builder (trigger, conditions, actions) to assign pre-configured packages to orders automatically via the Add parcels action. Conditions available include product name, SKU, EAN, weight, and item quantity, as well as order-level attributes like destination country, store, and delivery option. The key to PPWR compliance is mapping your SKU range to compliant package sizes during setup — the automation then enforces those assignments consistently on every order, removing the manual discretion that leads to non-compliant packaging decisions at scale.
ShippyPro's automation tools help EU e-commerce merchants assign compliant packaging automatically, track packaging data for EPR reporting, and manage carrier operations across all EU markets from one platform.
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