The EU’s Packaging and Packaging Waste Regulation has applied since 12 August 2026, but its requirements arrive in stages. For e-commerce brands, the immediate priorities include packaging documentation, traceability and applicable substance restrictions. The 50% empty space limit comes later.
Here are the key dates to plan around and the practical steps to discuss with your packaging suppliers and fulfillment partner.
What is PPWR?
PPWR is the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It entered into force on 11 February 2025 and replaces the previous Packaging Directive, with transitional provisions.
It covers packaging placed on the EU market, including product packaging, shipping boxes, mailers and packaging components. Brands outside the EU are also affected when supplying packaged goods to EU customers.
The duties differ by role. A brand, packaging manufacturer, importer and fulfillment provider do not automatically have the same responsibilities.
What applies now
Conformity documentation. The responsible manufacturer must assess conformity and prepare technical documentation and an EU declaration of conformity for the requirements that currently apply. A brand commissioning packaging under its own name can be the manufacturer under PPWR, even if another company physically produces it. Importers have their own verification and record-keeping duties.
Traceability. Packaging identification and manufacturer contact information are current requirements, with importer information where applicable. The later sorting-label deadlines do not postpone these obligations. Accompanying documents can be used in specified circumstances.
Substance limits. Restrictions on certain heavy metals and the duty to minimise substances of concern apply to packaging generally. Food-contact packaging first placed on the EU market from 12 August 2026 must meet PPWR’s PFAS concentration limits. This is relevant to food and food-supplement packaging. An outer parcel is not automatically food-contact packaging simply because it contains packaged food.
National EPR obligations. Extended producer responsibility, or EPR, still involves national registration, financing and reporting. In Germany, LUCID registration and system participation where required remain relevant. Foreign sellers supplying directly to German end users must also check the mandatory authorised-representative requirement. PPWR does not create one registration covering every EU market.
Existing packaging-minimisation requirements also continue during the transition.
Key PPWR dates for e-commerce
| Date | What to plan for |
|---|---|
| 12 August 2026 | General application begins, including current conformity, traceability and applicable substance requirements. |
| By 12 February 2028 | Empty space in sales packaging must be reduced to the minimum needed for its function and product protection. The Commission’s calculation methodology for outer packaging is also due by this date. |
| 12 August 2028 or later | Harmonised material and sorting labels apply from the later of this date or 24 months after the relevant implementing acts enter into force. E-commerce packaging is included. |
| From 1 January 2030 | New packaging design requirements under Article 10 require weight and volume to be reduced to the necessary minimum, subject to the regulation’s exceptions. |
| 1 January 2030 or later | The 50% empty space limit starts on the later of 1 January 2030 or three years after the calculation-methodology acts enter into force. |
Further recyclability and recycled-content requirements also have their own phased deadlines and exceptions. If you use plastic packaging, include those requirements in your supplier discussions. This timeline focuses on the main parcel-related milestones; it is not an exhaustive list of PPWR obligations.
How the 50% empty space rule works
The rule concerns grouped, transport and e-commerce packaging. It compares the outer packaging’s volume with the sales packaging it contains, rather than simply the size of a bare product. Paper fill, air pillows and similar materials count as empty space.
The detailed methodology will address practical issues such as irregular shapes, fragile products and orders containing several items. Reviewing box sizes now is useful preparation; the final calculation must follow that methodology.
Exemptions include using a product’s sales packaging as its shipping packaging, and reusable packaging within a reuse system. Other applicable requirements still need to be met, including the relevant packaging-minimisation rules.
What e-commerce brands should do now
- Map your packaging. List each product pack, shipping box, mailer and filling material, with its size, composition and supplier.
- Clarify responsibilities. Confirm which business is the manufacturer, importer and EPR producer under the rules. Identify who fills the shipping packaging, because Article 24 places its empty-space duty on that operator.
- Collect the relevant evidence. Request material information and applicable conformity documents. Check that packaging identification links to the records you keep.
- Check your measurements. Record product dimensions, the dimensions of sales packaging and shipping-packaging sizes. Bare-product measurements alone will not tell you how much space an order uses.
- Test real orders. Review your best-selling products and common combinations. Try more suitable packaging sizes and check protection, packing time and damage rates before changing the standard process.
- Review each destination market. Keep registrations, EPR arrangements and any required authorised representatives up to date.
If you are also planning seasonal volumes, our peak season checklist covers stock, shipping and returns preparations.
Packaging with SMS Fulfillment
At SMS Fulfillment, our custom packaging services include branded boxes, tapes, stickers and fillers. For kitted orders, we can also advise on box sizes and how products fit together.
Planning a packaging change alongside your fulfillment in Austria? Send us your product list, current packaging details and typical order combinations so we can discuss your requirements.
We offer customised quotes within 24 hours, with no minimum order quantity.
[Get your fulfillment offer](https://fulfillmentsms.com/contact-us/)
FAQ: EU packaging rules for e-commerce
Does PPWR apply to sellers outside the EU?
Yes, when their packaging is placed on the EU market. This includes Swiss and UK brands supplying EU customers. The precise obligations depend on each operator’s role.
Is the empty space limit 40% or 50%?
The final regulation sets a maximum of 50%. It applies from 1 January 2030 or three years after the relevant methodology acts enter into force, whichever is later.
Does adding more filling material reduce the empty space ratio?
No. Paper fill, air pillows and similar materials count as empty space.
Do I have to throw away packaging produced before 12 August 2026?
Not automatically. The Commission allows accompanying documents to provide certain identification and manufacturer details for existing stock. However, an earlier production date is not a blanket exemption: food-contact packaging first placed on the EU market from 12 August 2026 must still meet the PFAS limits. Packaging already placed on the market before that date can remain on the market.
Does PPWR replace national packaging registration?
No. National EPR arrangements continue, although PPWR can change who is responsible. Check the rules in every market where you supply customers.
