Labelling & formats
PPWR and e-commerce packaging
Last regulatory verification: 12 August 2026 · 3 official sources
Online sellers ship their own packaging. Which PPWR rules hit e-commerce hardest — empty space, minimisation, labelling and roles — and what to fix first.
Free PPWR Check60 seconds. Find out whether this packaging should be reviewed.Short answer
E-commerce packaging is explicitly in scope of PPWR. The obligations that hit online sellers hardest are the 50% empty space cap from 2030, the minimisation duty from 2026, and the fact that a seller who has shippers or mailers produced to its own specification is usually the one placing that packaging on the market.
The obligations that actually apply to a shipment
What applies to e-commerce packaging
Empty space ratio no higher than 50% in e-commerce packaging
Phases in- Legal basis
- Article 24
- Who it binds
- Online seller / final distributor
- From
- 1 January 2030
- Evidence
- Ratio calculated per box size, with dimensions and void-fill treatment recorded
Packaging minimised in weight and volume
In force- Legal basis
- Article 10
- Who it binds
- Manufacturer / operator placing on the market
- From
- 12 August 2026
- Evidence
- Documented justification per configuration
Technical documentation and Declaration of Conformity
In force- Legal basis
- Article 39 and Annex VII
- Who it binds
- Whoever places the packaging on the market under its own name
- From
- 12 August 2026
- Evidence
- Annex VII file plus a signed Declaration for own-brand shippers and mailers
Economic operator identification on the packaging
In force- Legal basis
- Articles 15–19
- Who it binds
- Manufacturer, importer
- From
- 12 August 2026
- Evidence
- Name, registered trade name, address and batch identification
Harmonised labelling on e-commerce packaging
Pending secondary act- Legal basis
- Article 12
- Who it binds
- Manufacturer / producer
- From
- After the labelling act transition
- Evidence
- Harmonised material and sorting symbols on the shipper
| Requirement | Legal basis | Who it binds | From | Evidence |
|---|---|---|---|---|
| Empty space ratio no higher than 50% in e-commerce packagingPhases in | Article 24 | Online seller / final distributor | 1 January 2030 | Ratio calculated per box size, with dimensions and void-fill treatment recorded |
| Packaging minimised in weight and volumeIn force | Article 10 | Manufacturer / operator placing on the market | 12 August 2026 | Documented justification per configuration |
| Technical documentation and Declaration of ConformityIn force | Article 39 and Annex VII | Whoever places the packaging on the market under its own name | 12 August 2026 | Annex VII file plus a signed Declaration for own-brand shippers and mailers |
| Economic operator identification on the packagingIn force | Articles 15–19 | Manufacturer, importer | 12 August 2026 | Name, registered trade name, address and batch identification |
| Harmonised labelling on e-commerce packagingPending secondary act | Article 12 | Manufacturer / producer | After the labelling act transition | Harmonised material and sorting symbols on the shipper |
Own-brand boxes make you the manufacturer
Fix the box range before anything else
Most e-commerce empty space failures are a range problem, not a design problem. Operations that ship a broad size mix through three or four cartons will fail the 50% test on a large share of orders. Adding intermediate sizes, or introducing right-sizing at pack-out, typically resolves more of the portfolio than any material change — and it reduces void fill and freight cost at the same time. See the empty space ratio with a worked calculation.
Marketplaces and fulfilment partners
Using a third-party fulfilment provider does not transfer the obligation for packaging you specify. Where the provider supplies its own generic packaging, the position depends on who placed it on the market. Either way, agree in writing who holds the documentation and who answers an authority's request — and confirm your fulfilment partner's box range supports the empty space cap before 2030, not after.
Non-EU sellers shipping into the EU
Selling from outside the EU into it does not remove the packaging obligations; it changes who carries them. There will be an importer, or an operator acting as one, and that operator has verification duties. See importer requirements.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- Commission PPWR GuidanceCommission guidance
- Commission PPWR FAQCommission guidance
- Sources last verified
- 12 August 2026
- Content last updated
- 12 August 2026
- First published
- 12 August 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.