In brief
- The EU Packaging and Packaging Waste Regulation, known as PPWR, has applied across the Union since 12 August 2026. Member States must set their penalties by 12 February 2027.
- What already applies to an online shop: it is the “producer” of the packaging it ships in each country where it delivers directly to consumers, with a written authorised representative in every other EU country.
- Marketplaces must obtain the seller’s registration number in the customer’s country before letting it sell.
- From 2030, an e-commerce parcel may not contain more than 50% empty space, filling material included. A 3-litre product shipped in a 9-litre box is 66.7% empty: over the limit.
- The 40% reusable packaging target for 2030 does not apply to cardboard boxes.
Regulation (EU) 2025/40 on packaging has applied since 12 August 2026. For an online shop, two obligations already count: registering as a producer in each country where it delivers to consumers, and appointing an authorised representative there when it is not established in that country. Others arrive in 2028 and 2030: harmonised labelling and a 50% cap on empty space in parcels. Cardboard boxes, for their part, are outside the re-use target.
How we checked On 13 October 2026 we read Regulation (EU) 2025/40 on EUR-Lex, Articles 3, 12, 24, 29, 44, 45, 68 and 71. The empty-space calculations in this article apply the definition in Article 24; we did them ourselves. The official calculation method will be set by the Commission by 12 February 2028 at the latest.
What already applies since 12 August 2026?
The regulation defines the “producer” as the manufacturer, importer or distributor that makes packaging or packaged products available for the first time on a territory, including through distance sales. A French shop delivering directly to consumers in Germany, Italy or Spain is therefore a producer in each of those countries, for the boxes, bags and filling it ships there.
Three practical consequences:
- Register in the producer register of each delivery country, before the first making available. The regulation provides for harmonised national registers, to be set up within 18 months of a first implementing act; in Germany, the LUCID register still takes registrations. Check the register in force in each country.
- Appoint an authorised representative in writing in each EU country where you deliver without being established. That is Article 45(3). In Germany, national law also requires the mandate to be written in German, as we explained for selling in Germany.
- Fund the end of life of that packaging through the extended producer responsibility of the country concerned, usually through a compliance scheme.
What must marketplaces check?
Article 45(4) requires platforms that let consumers conclude distance contracts with sellers, within the meaning of the Digital Services Act, to obtain, before letting a seller offer products to consumers in a country, its producer registration number in that country, and a self-certification that it complies with extended producer responsibility. A seller with no number in the customer’s country fails the condition the platform must check: that is often how the obligation is discovered.
How much empty space may a parcel contain in 2030?
From 1 January 2030, or three years after the Commission’s calculation method if that comes later, the empty space ratio of e-commerce packaging may not exceed 50%. Empty space is the difference between the volume of the parcel and that of the sales packaging it contains, and filling material counts as empty space: crumpled paper, air cushions, bubble wrap, chips.
| Parcel | Box volume | Packed product volume | Empty space ratio |
|---|---|---|---|
| Box 30 × 20 × 15 cm | 9 litres | 3 litres (box 20 × 15 × 10 cm) | 66.7%, over the limit |
| Box 25 × 18 × 12 cm | 5.4 litres | 3 litres | 44.4%, compliant |
Two exemptions matter for a shop. Sales packaging used directly as the shipping parcel is outside the limit, provided it is itself minimised. And the calculation method will take account of irregularly shaped, fragile or multiple products in one parcel. For clothing shipped without a box, in a bag, it is that method, expected by 12 February 2028 at the latest, that will settle the calculation.
From 12 February 2028, those who fill sales packaging must also reduce its empty space to the minimum needed to protect the product.
Will you have to switch to reusable packaging?
Not for cardboard boxes. Article 29 requires that from 2030, 40% of transport packaging, including in e-commerce, be reusable within a re-use system: pallets, foldable crates, trays, boxes. But its paragraph 4 expressly excludes packaging “in the form of cardboard boxes”. A shop shipping in cardboard boxes is therefore not covered by that target. And micro-enterprises making no more than 1,000 kg of packaging available per year in a country are exempt.
When does labelling change?
From 12 August 2028, or 24 months after the implementing acts if they come later, packaging will carry a harmonised label showing its material, in pictograms, to help sorting. Transport packaging is exempt, except e-commerce packaging: the shipping box or bag will therefore carry the label too. A QR code can be added.
The timeline for an online shop
| Date | What changes |
|---|---|
| 12 August 2026 | Regulation applies: distance producer status, authorised representative in every other country, checks by marketplaces |
| 12 February 2027 | Member States set and notify their penalties, which must include administrative fines for Articles 24 to 29 |
| 12 February 2028 | Empty-space calculation method; empty space minimised in sales packaging |
| 12 August 2028 at the earliest | Harmonised labelling, e-commerce packaging included |
| 1 January 2030 at the earliest | 50% empty space cap in e-commerce parcels; re-use targets, excluding cardboard boxes |
What should you do now?
- List the countries where you deliver directly to consumers, and for each, check your producer number and your authorised representative.
- Check your marketplaces: they will ask for the number for each customer’s country. Better to have it before they block your listings.
- Measure your parcels: for your ten best-selling products, box volume and packed product volume. Above 50% empty space, review your range of boxes. It also saves on shipping, which is charged by volume.
- Consider sales packaging as the parcel for products that allow it: it is outside the limit.
- Prepare the label for your shipping packaging for 2028, with your box supplier.
What this says about the bigger picture
The packaging regulation moves Europe from a patchwork of national laws to a single rule, but one administered country by country: a register and a representative per delivery country. For a shop selling in several countries, the cost of entering a new market now lies as much in that administration as in translating the site. And the empty-space cap turns an environmental question into a logistics one: the right box size.
That country-opening and logistics work is what we do through our e-commerce and marketplaces expertise.
What this article is not Legal advice. It describes the regulation as of 13 October 2026. Several obligations depend on forthcoming implementing acts, which will specify the calculation and sometimes the date.
Sources
Page opened on 13 October 2026.
- Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste, Articles 3, 12, 24, 29, 44, 45, 68 and 71, EUR-Lex. View
FAQ
When does the PPWR apply?
Since 12 August 2026, across the EU. Several obligations have later dates: national penalties by 12 February 2027, harmonised labelling from 12 August 2028 at the earliest, and the 50% empty-space cap in e-commerce parcels from 1 January 2030 at the earliest.
How much empty space is allowed in an e-commerce parcel?
50% at most, from 2030. Empty space is the difference between the volume of the parcel and that of the sales packaging it contains, and filling material counts as empty space. A 3-litre product in a 9-litre box exceeds the limit (66.7%); in a 5.4-litre box, it complies (44.4%).
Will shipping boxes have to be reusable?
No. The target of 40% reusable transport packaging from 2030 expressly excludes cardboard boxes (Article 29(4)).
Do you need an authorised representative to sell in another EU country?
Yes, when you deliver directly to consumers in an EU country where you are not established: Article 45(3) requires you to appoint, in writing, an authorised representative for extended producer responsibility in each of those countries.
Can Dotsland help?
Yes. We inventory countries, numbers and representatives with you, and audit your parcel formats. Start with the list above, then get in touch.