Sales, Grouped, Transport, E-Commerce: Which PPWR Rules Apply to Which Level
Four Words That Decide Which Rules Apply
A filling line finishes its run. Twenty-four bottles go into a printed case, twelve cases go onto a pallet, the pallet is wrapped in stretch film and closed with two straps. The same product, ordered from the brand's webshop, leaves the warehouse in a single shipping box with a delivery label on it. One product, four objects — and under Regulation (EU) 2025/40, every one of them is packaging placed on the EU market.
They are not the same kind of packaging, and that is not filing hygiene. Which of four categories an object falls into decides whether the empty-space ratio reaches it, which re-use target it counts towards and whether the harmonised label is owed on it at all. The regulation has applied since 12 August 2026, and the packaging level is the switch that wires a unit to its obligations.
The Four Categories the Regulation Defines
The definitions sit in Article 3(1), points (5) to (8), and they are worth quoting rather than summarising: each carries an operative test that settles the close cases.
Sales packaging — Article 3(1)(5)
"‘sales packaging’ means packaging conceived so as to constitute a sales unit consisting of products and packaging to the end user at the point of sale" — Article 3. The test is the sales unit at the point of sale: the bottle and its label, the tube and its carton. Note the opening words, "conceived so as to": they open all four definitions, and they are why classification follows function rather than material.
Grouped packaging — Article 3(1)(6)
"‘grouped packaging’ means packaging conceived so as to constitute a grouping of a certain number of sales units at the point of sale, irrespective of whether that grouping of sales units is sold as such to the end user or whether it serves as a means to facilitate the restocking of shelves at the point of sale or to create a stock-keeping or distribution unit, and which can be removed from the product without affecting its characteristics". It deliberately covers groupings a consumer never sees — the shelf-ready tray, the restocking case — and it closes on a test: the packaging comes off without affecting the product.
Transport packaging — Article 3(1)(7)
"‘transport packaging’ means packaging conceived so as to facilitate the handling and transport of one or more sales units or a grouping of sales units, in order to prevent damage to the product from handling and transport, but which excludes road, rail, ship and air containers". Two hard points follow. Transport packaging such as pallets, stretch film and strapping counts as packaging in its own right under Article 3(1)(7) — Article 29(1) names the formats expressly, listing pallets and then "flexible formats or pallet wrappings or straps for stabilisation and protection of products put on pallets during transport". And the exclusion is literal and narrow: road, rail, ship and air containers sit outside the definition, while everything stacked on the pallet inside them is packaging.
Where a unit lands among the four levels is settled here. When the goods arrive from outside the Union, it is the role that changes the obligations, and that is the subject of our article on transport packaging for importers.
E-commerce packaging — Article 3(1)(8)
"‘e-commerce packaging’ means transport packaging used to deliver products in the context of sale online or through other means of distance sales to the end user". A category of its own, built on the third and not a synonym for it: the parcel is regulated at the transport level even though a consumer opens it on a doorstep, and that double nature is what earns it separate treatment under the label.
Primary, Secondary, Tertiary: The Same Trio, Not a Second List
Warehouses, ERPs and supplier questionnaires rarely say "sales packaging"; they say primary, secondary, tertiary. Recital 10 is explicit: "Sales packaging, grouped packaging and transport packaging should be defined separately. Duplication of terminology should be avoided. In this Regulation therefore sales packaging corresponds to primary packaging, grouped packaging to secondary packaging and transport packaging to tertiary packaging." That is a recital rather than an obligation in itself, but it settles the vocabulary question.
The practical move follows: keep one vocabulary, treat the other as an input alias. A file arriving with "tertiary" in the level column has to be understood and come back out as transport packaging. What must never happen is the two vocabularies living side by side as separate values: the moment "Transport" and "Transport (tertiary)" are both selectable, one portfolio becomes two disjoint populations, each looking complete to whoever reads it. And the trio has no fourth word — which is why parcels end up filed as "tertiary".
What Changes When the Level Changes
Four provisions read the level and act on it differently.
| Provision | The levels the text names | When it bites |
|---|---|---|
| Article 24 — empty-space ratio | Grouped packaging, transport packaging, e-commerce packaging | 1 January 2030, or three years after the implementing acts under Article 24(2) enter into force, whichever is the latest |
| Article 12(1) — harmonised label | Does not apply to transport packaging, except e-commerce packaging | 12 August 2028, or 24 months after the implementing act under Article 12(6) enters into force, whichever is the latest |
| Article 29 — re-use targets | Operators using transport packaging within the territory of the Union | Set out in Article 29 — and not the same figure for every level |
| Article 6(1) — design for recyclability | All packaging placed on the market, transport packaging included | Since 12 August 2026 |
Empty space: the article that names three levels
Article 24 caps the empty space ratio and says in one sentence who has to hold it: "By 1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest, economic operators who fill grouped packaging, transport packaging or e-commerce packaging shall ensure that the maximum empty space ratio, expressed as a percentage, is 50 %". Grouped, transport, e-commerce: those are the three levels the article names, and working out which of your units are among them is the question at this stage. The date has a moving part too — "whichever is the latest" belongs to the sentence, not to a footnote. Measuring the ratio is another job entirely: how the percentage is computed, how void fill counts and what the file behind the figure must show are in our packaging minimisation and empty-space guide. This article stops at the whether.
Re-use targets: the same word, different numbers
Article 29 is the clearest case of an obligation whose size depends on a category, and its scope comes first: the targets bind the economic operators that use transport packaging within the territory of the Union, whatever the country the packaging arrives from. The criterion is use inside the Union, not the import flow. The figures are not the same for every level, and the level you have on record decides which one you fall under; they sit in our guide to the 2030 re-use targets and in Article 29 itself.
The harmonised label: transport is out, e-commerce is in
Article 12(1) is the sharpest demonstration that the level is a switch rather than a filing label: the harmonised label does not apply to transport packaging, except e-commerce packaging. Two boxes a warehouse team calls by the same word do not carry the same markings — the parcel is caught, the restocking case is not. And the timing is where the common error sits: the obligation is not owed before 12 August 2028, or 24 months after the entry into force of the implementing act under Article 12(6), whichever is the latest.
What applies at every level, whatever the box
None of this makes the transport level a blind spot. Article 6(1) — "All packaging placed on the market shall be recyclable" — has applied since 12 August 2026 to every level, transport included, and the A, B and C performance grades of the design-for-recycling criteria become binding on 1 January 2030 at the earliest. The scope provision is just as flat: the regulation applies to all packaging, regardless of the material used, whether that packaging is used in or its waste originates from industry, other manufacturing, retail or distribution, offices, services or households — so there is no B2B exemption to shelter under. The paperwork holds at every level too: the EU declaration of conformity follows the model in Annex VIII, the technical documentation Annex VII.
One date trap deserves naming, because it is repeated everywhere. The Article 10(1) weight-and-volume minimisation duty applies from 1 January 2030. Only the Article 10(2) prohibition — packaging whose characteristics aim only to increase the perceived volume of the product, such as double walls and false bottoms — has applied since 12 August 2026. Two paragraphs of one article, two dates.
Classifying a Portfolio Without Guessing
Classify the function in the flow, not the object
All four definitions turn on "conceived so as to". That is a function test, and function depends on the flow: the same plastic crate is sales packaging when it leaves with the product as the unit the customer buys, and transport packaging when it only moves stock between your own warehouses. The level therefore belongs to the product and the channel together, never to the object alone — and a portfolio that keeps one level per article code, with no channel dimension, misfiles every reference that ships by two routes.
One shipment, several packaging units
The bottle, the case of 24, the pallet, the film and the straps are five packaging units, not one packaging with five parts. Sales, grouped and transport packaging are each a separate packaging unit under Article 3(1)(5) to (7) — a pallet, its stretch film and its strapping are transport packaging under Article 3(1)(7), assessed and declared in their own right. A supplier questionnaire that files them under freight gets the text wrong. Counting units rather than shipments is what makes the workload visible: one loaded pallet carries several evidence trails.
What these four words do not cover
A closed vocabulary should be honest about its edges. These four values cover Article 3(1)(5) to (8) and nothing else. Article 3 defines other terms that are not levels: the definition of "producer" at Article 3(1)(15) speaks of "transport packaging, service packaging, or primary production packaging". Those two do their work inside that definition, where they bear on who registers and reports — not as a fifth level. The rule to hand your teams is short: a line that does not fit one of the four is not a candidate for the nearest box. It is a question.
One Definition, Four Doors
A classification is only as good as the discipline that feeds it, and portfolio data never arrives through a single channel: the form somebody fills in, the workbook imported from a supplier, the ERP calling an API, the assistant proposing an update. Four doors, one field, three rules.
One option list has exactly one definition. The values offered by all four doors come from a single source — same values, same order, no local copy. A list duplicated for one integration is not a copy of the classification: it is a second classification, and two of them over one portfolio disagree the day someone reports.
Synonyms come in, they never go out. "Tertiary", "secondary", "grouping", a French column header — all recognised at the door and normalised on the way in, while what gets stored, reported and printed on the declaration stays the regulation's own word. Asking every supplier to change vocabulary is not a plan; translating at the boundary is.
An unknown value stays unknown. A level that cannot be recognised does not become the first entry in the list, and it does not become a default: it comes back as a question. A guessed level is a wrong level, and it commands the empty-space ratio, the labelling and the re-use target that follow from it. None of this is specific to software: it is what any data owner does with a closed vocabulary that carries legal consequences.
How PPWR Connect Helps
PPWR Connect is a software publisher — not an authorised representative, not a compliance scheme, not a notified body. What it does with packaging levels is what this article argues for: every reference carries a level per channel, drawn from one closed list and recognised whichever way the data arrives — typed in, imported, pushed through the API or proposed by the assistant. From that field the obligations are recalculated per unit, and the evidence attaches to the unit; a worked example sits in the live demo.
To find out which levels your own portfolio actually contains, start with the free PPWR readiness assessment. The software holds the classification and the paper trail; the decision on each line stays with the operator who signs the declaration.