PPWR 2026: What requirements will e-commerce businesses need to meet from 12 August?

The Packaging and Packaging Waste Regulation (PPWR) – Regulation (EU) 2024/1781 – will apply from 12 August 2026. Replacing Directive 94/62/EC, which has governed packaging and packaging waste since 1994, the new regulation introduces significant changes across several areas.

For many e-commerce businesses, the PPWR is primarily associated with extended producer responsibility (EPR), which requires companies to register with national authorities and pay fees for packaging placed on the market. This is understandable, as EPR is one of the most widely discussed aspects of the regulation. However, the PPWR goes considerably further, introducing specific requirements for packaging design, recyclability, recycled content and labelling. It also places greater emphasis on reusable packaging, an issue of particular importance to online retailers.

The obligations that apply to a business also depend on its role in the supply chain. Manufacturers, importers, distributors, retailers operating their own online stores and marketplace sellers are all subject to different requirements. A single business may fulfil several of these roles simultaneously.

In this article, we examine the key PPWR requirements affecting e-commerce businesses, including the relevant deadlines and the obligations associated with each role.

What is the PPWR and how does it differ from existing legislation?

PPWR stands for Packaging and Packaging Waste Regulation, the EU regulation governing packaging and packaging waste.

Unlike the previous legislation, the PPWR extends beyond packaging waste management to cover the entire packaging lifecycle, from design and recyclability to labelling and information requirements. Extended producer responsibility (EPR) is just one element of this broader regulatory framework.

Another significant change for e-commerce is that the PPWR explicitly addresses distance selling and online marketplaces. The previous directive was introduced before the rapid growth of e-commerce and did not contain specific provisions for online sales.

What is your role under the PPWR, and how does it affect your obligations?

The PPWR defines several roles within the packaging supply chain. The requirements that apply to your business depend on which role, or combination of roles, it fulfils.

Producer

Under Article 3(1)(11) of Regulation (EU) 2024/1781, a producer includes an entity that:

• Manufactures or packages products under its own brand and places them on the domestic market.
• Resells products supplied by other businesses under its own brand.
• Places products originating from another EU Member State or a non-EU country on the domestic market.
• Sells products online directly to consumers in another EU Member State, even if the business is established in Poland.

The final point is particularly relevant to Polish e-commerce businesses engaged in cross-border sales. A company selling directly to German consumers through its own online store is considered a producer in Germany for PPWR purposes and must therefore fulfil the corresponding obligations in that market.

Importer

An importer is an entity established in the EU that places packaging or packaged products manufactured outside the EU on the market. If a manufacturer based outside the EU (e.g. China, South Korea or Turkey), has not appointed an authorised representative in the EU, the importer assumes responsibility for meeting the relevant PPWR requirements. In practice, this means ensuring that the packaging complies with applicable design, labelling and EPR requirements, as though the importer had manufactured it.

Distributor

A distributor is an entity that makes packaging or packaged products available on the market without being their manufacturer or importer. Although distributors are not directly responsible for meeting packaging design requirements, they must verify that their suppliers, whether manufacturers or importers, fulfil their obligations. A distributor may also incur secondary liability if it places products on the market despite knowing, or having reasonable grounds to believe, that the supplier has failed to comply with the PPWR.

E-commerce retailer using shipping packaging

Any e-commerce business that dispatches products to customers uses transport or shipping packaging. The PPWR introduces packaging minimisation requirements, including the maximum 40% empty space rule, alongside targets for reusable packaging. These requirements apply regardless of whether the business is classified as a producer, importer or distributor.

Marketplace seller

Businesses selling through platforms such as Amazon, Zalando, Allegro or eBay must meet the same PPWR requirements as retailers operating their own online stores. The main difference is that, from 12 August 2026, marketplace operators will be required to collect EPR registration numbers and packaging declarations of conformity from sellers, and restrict access for businesses that do not hold the required registrations.

Overview of roles and responsibilities

 

Role	E-commerce example	Packaging minimisation	EPR	Labelling	Reusable packaging
Producer	Own-brand retailer, cross-border seller	Yes	Yes	Yes	Yes
Importer	Business importing products from Asia or the UK	Yes	Yes	Yes, if not addressed by manufacturer	Yes
Distributor	Wholesaler or reseller of third-party brands	Yes, for its own transport packaging	Supplier verification	Supplier verification	Yes, for its own packaging
E-commerce retailer shipping products	Any online business dispatching orders	Yes	Depends on role	Depends on role	Yes
Marketplace seller	Seller on Amazon, Allegro or Zalando	Yes	Yes, as required by the platform	Yes	Yes

Obligation 1 – EPR: How does the PPWR change existing requirements?

Many e-commerce businesses are already registered under EPR schemes in selected countries, such as LUCID in Germany, UIN in France and CONAI in Italy. So what changes does the PPWR introduce to extended producer responsibility?

A harmonised definition of producer

Until now, each Member State has applied its own definition of a producer for EPR purposes. This has led to gaps and inconsistencies: businesses required to register in one country have sometimes been exempt in another because of differences in national interpretations.

From 12 August 2026, the harmonised definition of producer under Article 3 of the PPWR applies across all EU Member States. Selling products online to consumers in a particular EU country therefore triggers an EPR registration obligation in that market, without the exemptions previously available under certain national rules.

Expanded reporting requirements

The PPWR broadens the range of packaging covered by registration and reporting obligations. Businesses will need to report on additional types of packaging, including e-commerce shipping packaging and grouped packaging. Reporting will also require more detailed breakdowns by packaging material and category.

Higher recycling targets

The PPWR increases the minimum national packaging waste recycling targets that producer responsibility organisations (PROs) must achieve. These higher targets may, in turn, lead to increased EPR fees for producers.

Comparison: Existing EPR requirements and the 2026 PPWR

Area	Existing requirements	From 12 August 2026
Definition of producer	Varies between countries, creating inconsistencies	Harmonised definition covering cross-border e-commerce
Registration requirements	Country-specific obligations requiring individual assessment	Registration required when selling into an EU market
Reporting requirements	Limited scope, varying by country	Expanded reporting covering additional packaging categories and materials
Packaging minimisation	No EU-wide requirement	Maximum 40% empty space and restrictions on unnecessary double walls
Recyclability	Primarily voluntary declarations	Mandatory assessment from 2026; grades A or B required from 2030
Recycled content	No mandatory minimum	Minimum recycled content requirements for plastic packaging from 2030
Labelling	National, non-harmonised requirements	Harmonised material codes and QR codes from 2028
Reusable packaging	No specific e-commerce target	10% by 2030 and 50% by 2040
Online marketplaces	No general verification obligation	Requirement to collect EPR information and restrict non-compliant sellers

Obligation 2 – Packaging minimisation and design

The maximum 40% empty space rule

One of the most specific and operationally significant PPWR requirements concerns the amount of empty space permitted in transport and shipping packaging. Under this rule, empty space must not account for more than 40% of the total volume of a shipping package.

Empty space refers to the space between the product, or its primary packaging, and the outer walls of the shipping package. It also includes void-fill materials such as bubble wrap, paper filling, polystyrene and air cushions ­­­– provided that the space they occupy is not necessary to protect the product.

Example calculation: A cardboard box measuring 30 × 20 × 15 cm has a total volume of 9,000 cm³. The product and the protective materials needed to secure it occupy 5,000 cm³. This leaves 4,000 cm³ of empty space, equivalent to 44% of the package’s total volume. The package therefore does not meet the PPWR requirement. To achieve compliance, the box must be made smaller so that empty space accounts for no more than 40% of its total volume (≤ 3,333 cm³).

This rule applies to shipping packaging selected by an e-commerce business when preparing an order for dispatch. It does not apply to a product’s original primary packaging as supplied by the manufacturer, unless the business is also responsible for manufacturing that packaging.

Restrictions on unnecessary packaging features

The PPWR prohibits packaging features such as double walls, false bottoms and other structural elements that make packaging appear larger without serving a protective or informational purpose. These restrictions are particularly relevant to presentation and gift packaging.

Hazardous substances

From 12 August 2026, packaging must not contain substances of very high concern (SVHCs) at concentrations exceeding the limits established under the REACH Regulation. This is particularly relevant to per- and polyfluoroalkyl substances (PFAS), which have traditionally been used in paper coatings for food packaging.

For importers, this means checking the chemical composition of packaging supplied by manufacturers outside the EU and obtaining the necessary declarations of conformity before August 2026.

Obligation 3 – Recyclability and recycled content

Recyclability assessment (from 2026)

From 12 August 2026, producers must assess the recyclability of their packaging in accordance with the methodology established by the European Commission through forthcoming delegated acts. The PPWR introduces a three-tier recyclability classification system:

• Grade A: Packaging collected and recycled at scale, with more than 70% of the collected material stream undergoing effective recycling.
• Grade B: Packaging that is technically recyclable but not yet recycled at scale because the necessary infrastructure is limited.
• Grade C: Packaging that cannot be recycled using currently available methods.

From 1 January 2030, packaging classified as Grade C may no longer be placed on the EU market. Producers and importers who fail to complete the necessary assessments by this deadline risk having their products blocked from sale.

Minimum recycled content in plastic packaging (from 2030)

The PPWR introduces mandatory minimum recycled content requirements for plastic packaging:

• Plastic transport and shipping packaging, such as stretch film, packaging tape and plastic mailing bags: 35% recycled content from 1 January 2030.
• Non-food plastic packaging other than bottles: 35% from 2030, increasing to 65% from 2040.
• Non-food plastic bottles: 30% from 2030, increasing to 65% from 2040.

Source: Regulation (EU) 2024/1781, Article 7 and Annex II, Part B.

For e-commerce businesses using plastic packaging, such as mailing bags or stretch film for securing pallets, meeting these requirements may involve revising packaging procurement specifications or changing suppliers. Compliance will therefore require operational changes rather than a one-off administrative exercise.

Obligation 4 – Reusable packaging in e-commerce

Article 26(5) of the PPWR requires businesses using transport and shipping packaging to progressively increase the proportion of reusable packaging.

“Reusable packaging”, as defined in the PPWR, is packaging designed and placed on the market for repeated use over multiple cycles. The minimum number of reuse cycles will be specified in delegated acts issued by the European Commission.

Meeting the reusable packaging targets requires a structured approach. Simply labelling packaging as returnable will not be sufficient. Businesses aiming to meet the 10% target by 2030 should already be considering the following steps:

• Exploring packaging pooling systems, where reusable packaging is shared between businesses, or deposit-return schemes.
• Piloting reusable packaging with a selected group of customers.
• Assessing the logistics involved in collecting and returning used packaging.

Although the 2030 deadline leaves several years for implementation, experience with other EPR regulations suggests that businesses which delay preparations until the final year often struggle to meet their obligations on time.

Obligation 5 – Packaging labelling

The packaging labelling requirements set out in Article 12 of the PPWR take effect on 12 August 2028, two years after the regulation’s main application date.

All packaging placed on the EU market will need to carry the following information:

1. Material identification code: A harmonised code identifying the material from which the packaging is made, in accordance with Annex VI of the PPWR.
2. Waste sorting instructions: A pictogram and accompanying information indicating the appropriate waste collection container.
3. QR code or other data carrier: Providing additional information about the packaging material, composition, recyclability grade, producer and relevant EPR registration details.
4. Reusable packaging label (where applicable): Information identifying the packaging as reusable, together with details of the return system and intended number of reuse cycles.
5. Recycled content information (where applicable): Information indicating the proportion of recycled material used in the packaging.

These requirements are particularly significant for importers: products imported from Asia or the United States typically do not carry labels that meet the new requirements. Importers who fail to ensure compliant labelling before August 2028 will have two options: relabel products after importation or revise their packaging specifications with overseas suppliers.

The first option increases operating costs, while the second requires time for supplier negotiations and potential changes to manufacturing processes.

Online marketplaces – What changes for sellers and platform operators?

For marketplace sellers

Article 45 of the PPWR requires online marketplace operators to collect information from sellers confirming their EPR registration status and the conformity of their packaging with PPWR requirements. Platforms must verify that sellers hold valid EPR registrations in the countries where they sell their products while failure to hold the required registrations may result in account suspension.

Amazon and Zalando already apply similar verification measures in selected markets, including Germany (LUCID) and France (UIN). Under the PPWR, these requirements will be extended to all EU markets served by the platforms and to all sellers.

This means that, from 12 August 2026, sellers operating across Amazon’s German, French, Italian, Spanish, Dutch and Swedish marketplaces must hold valid EPR registrations in each of those countries, rather than only in Germany and France.

For sellers established outside the EU

A business established outside the EU, for example in China, the UK or the United States, that sells to EU consumers through Amazon EU is considered a producer under the PPWR, thus subject to the regulation’s requirements. The business may fulfil these obligations directly by registering in the relevant EU countries or through an appointed authorised representative.

If a seller fails to comply, the marketplace operator, such as Amazon, may be held liable to the extent that it has failed to carry out the required checks, which in turn serves as a strong incentive to ensure that their sellers comply.

For marketplace operators

Marketplace operators must maintain up-to-date records of sellers’ EPR registration numbers, verify that registrations remain valid and restrict access for sellers that fail to meet the requirements. The extent of a platform’s liability depends on whether it knew, or reasonably should have known, that a seller was non-compliant.

PPWR implementation timeline – Key dates and requirements

Date	Requirement	Businesses affected
12/08/2026	Packaging minimisation: maximum 40% empty space and restrictions on unnecessary double walls	All businesses using shipping packaging
12/08/2026	Restrictions on hazardous substances (PFAS, SVHCs) in packaging	Producers and importers
12/08/2026	Harmonised EPR requirements: registration and reporting under the PPWR definition	Producers and importers
12/08/2026	Marketplace obligations: collecting sellers’ EPR information and restricting non-compliant sellers	Marketplace operators
12/08/2026	Packaging recyclability assessments and supporting documentation	Producers and importers
12/08/2026	Packaging labelling: material codes, waste sorting instructions and QR codes	Producers and importers
01/01/20230	Grade A or B recyclability required for all packaging	Producers and importers
01/01/20230	Minimum recycled content requirements for plastic packaging	Producers and importers
01/01/20230	10% reusable packaging target for e-commerce shipments	E-commerce businesses shipping products
01/01/2040	50% reusable packaging target for e-commerce shipments	E-commerce businesses shipping products

Where should you start? An action plan based on your role

PPWR compliance involves more than completing a registration or submitting a declaration. It requires a series of decisions and operational changes, implemented in the right order. The following priorities can help you determine where to begin, depending on your business’s role.

If you manufacture your own packaging

Start by auditing your existing packaging to check whether it meets the maximum 40% empty space requirement and complies with the restrictions on substances of very high concern (SVHCs). These requirements apply from 12 August 2026, making them an immediate priority. Packaging changes take time, particularly when they involve redesign, testing and new procurement arrangements.

At the same time, consider assessing the recyclability of your packaging, even before the European Commission finalises the methodology through delegated acts. Identifying packaging that requires material changes at an early stage can help you avoid costly last-minute modifications.

If you import products from outside the EU

Your priority should be to establish whether your overseas supplier or manufacturer has appointed an authorised representative in the EU and whether its packaging meets the PPWR requirements. If these conditions are not met, the importer assumes responsibilities equivalent to those of a producer, so consider including specific PPWR compliance clauses in new supplier contracts.

You should also verify the chemical composition of the packaging, particularly its PFAS and SVHC content, and assess whether imported products will meet the labelling requirements taking effect in 2028.

If you distribute products from other brands

Distributors placing third-party branded products on the market must verify that their suppliers comply with the PPWR. The regulation also introduces secondary liability for businesses that place products on the market when the manufacturer or importer has failed to meet the relevant requirements. Reviewing supplier agreements and introducing specific PPWR compliance clauses can help manage this risk.

Any transport packaging you use yourself, including crates, pallets and stretch film, is also subject to packaging minimisation requirements and reusable packaging targets.

If you sell through online marketplaces

Your first priority should be to review your EPR registrations and determine which platforms and countries will require additional declarations from 12 August 2026. Amazon and Zalando have already indicated plans to expand their EPR requirements in 2026. Sellers without valid registrations risk having their accounts suspended.

You should also check whether the platforms you use have published specific PPWR packaging compliance requirements, including the maximum 40% empty space rule and recyclability declarations.

Summary

The PPWR introduces far-reaching changes to packaging requirements across several areas. Extended producer responsibility remains a central element of the regulation, but it is by no means the only obligation.

For e-commerce businesses, the key requirements taking effect on 12 August 2026 include the maximum 40% empty space rule for shipping packaging, harmonised EPR obligations incorporating a new definition of producer that covers cross-border sales, and new responsibilities for online marketplaces to verify seller compliance. Additional packaging labelling requirements will follow in 2028. By 2030, businesses will also need to meet the applicable recyclability standards, minimum recycled content requirements and reusable packaging targets.

None of these changes can be implemented overnight. Redesigning packaging requires time for development, testing and supply chain adjustments, while introducing reusable packaging systems can take several months.

At EFF, we help businesses identify their PPWR obligations based on their role in the supply chain and prepare for compliance. Our support covers everything from packaging audits and EPR registrations to preparing the necessary compliance documentation. [Link]

Frequently asked questions (FAQ)

What is the PPWR and when does it apply?

The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2024/1781, is the EU regulation governing packaging and packaging waste. Published in June 2024 and applied 12 August 2026, with packaging labelling requirements taking effect on 12 August 2028, it replaces Directive 94/62/EC and, as an EU regulation, is directly applicable in all Member States.

I already comply with EPR requirements. Do I need to do anything else to comply with the PPWR?

Yes. EPR is only one aspect of the PPWR. The regulation also introduces the maximum 40% empty space rule for shipping packaging, mandatory recyclability assessments, new labelling requirements from 2028 and reusable packaging targets from 2030. Existing EPR registrations may also need to be updated after 12 August 2026 to cover additional packaging types and reporting categories.

What is the maximum 40% empty space rule, and how can I check whether my packaging complies?

Under this rule, the space between the product and the outer walls of the shipping package, including void-fill materials, must not exceed 40% of the package’s total volume. To check compliance, measure the total volume of the package and the space occupied by the product and its necessary protective materials. If the remaining space accounts for more than 40% of the total volume, the packaging needs to be adjusted.

I import products from Asia. What obligations does the PPWR impose on me?

An importer assumes responsibilities equivalent to those of a producer if the overseas manufacturer has not appointed an authorised representative in the EU. These responsibilities include EPR obligations, recyclability assessments and ensuring that imported products carry compliant packaging labels. Before August 2026, you should verify that your suppliers meet the PPWR requirements concerning packaging composition, including restrictions on PFAS and SVHCs, and obtain the relevant declarations of conformity.

I sell on Amazon and Allegro. What changes from 12 August 2026?

Article 45 of the PPWR requires online marketplaces to collect sellers’ EPR registration numbers and verify their registration status. Amazon and Zalando already require EPR registration numbers in selected countries. From 12 August 2026, these requirements will extend to all EU countries and all sellers. Failure to maintain valid EPR registrations may result in account suspension.

When do the new packaging labelling requirements, including QR codes, take effect?

The requirements take effect on 12 August 2028, two years after the PPWR’s main application date. Packaging will need to carry material identification codes, waste sorting instructions, QR codes containing packaging information and, where applicable, information about reusability and recycled content.

What will change regarding reusable packaging?

Reusable packaging is designed for repeated use over a specified minimum number of cycles. From 1 January 2030, at least 10% of packaging used for e-commerce shipments must be reusable. Implementing a reusable packaging system, including pilot schemes, reverse logistics and selecting an appropriate packaging pooling solution, requires at least one to two years of preparation.

What are the penalties for failing to comply with the PPWR?

The PPWR leaves Member States responsible for determining the level of penalties, while requiring them to introduce sanctions that are “effective, proportionate and dissuasive”. Experience with existing national EPR schemes shows that fines can reach tens or even hundreds of thousands of euros. In Germany, for example, failure to register with LUCID can result in a fine of up to €200,000. Non-compliance with the PPWR may also lead to marketplace sales restrictions or products being withdrawn from the market.

Sources

• Regulation (EU) 2024/1781 of the European Parliament and of the Council of 22 May 2024 on packaging and packaging waste. Official Journal of the European Union, L 2024/1781, 22 June 2024.
• European Commission. (2024). Packaging and Packaging Waste Regulation – Key Provisions for Economic Operators. ec.europa.eu/environment/packaging
• PRO Europe. (2025). PPWR Implementation Guide for Producers and Distributors. pro-e.org
• European Environment Agency. (2024). Packaging Waste in Europe – Key Findings from EEA Analysis. eea.europa.eu