Conformitatea PPWR pentru comerțul electronic: regulile privind spațiul gol, EPR și obligațiile vânzătorilor online
PPWR and E-Commerce: Why Online Sellers Face Unique Packaging Challenges
The EU Packaging and Packaging Waste Regulation (EU) 2025/40 — commonly known as the PPWR — applies to all packaging placed on the EU market, and e-commerce packaging is no exception. In fact, online retailers, marketplaces, and fulfilment service providers face some of the most demanding new obligations, including strict empty-space limits, transport packaging rules, and expanded producer responsibility across 27 member states.
With the main compliance deadline of August 12, 2026 now just months away, e-commerce businesses that ship into or within the EU must act now. This article breaks down exactly what the PPWR means for online sellers and how to prepare.
Empty Space Capped at 50%: Article 24, in Force from January 1, 2030
One of the most talked-about PPWR provisions for e-commerce is the empty-space cap of Article 24(1). It binds the economic operators who fill grouped packaging, transport packaging and e-commerce packaging — online shipping boxes and mailers are squarely in scope, sales packaging is not — and it applies from January 1, 2030, or three years after the entry into force of the implementing acts adopted under Article 24(2), whichever is the latest. Three separate duties usually travel together under the single word minimisation, and they do not share a date:
- Empty space must not exceed 50% of the total packaging volume, from January 1, 2030 (Article 24(1)). The ratio is measured between the product(s) and the outer packaging, including any void-fill materials.
- Packaging weight and volume must be reduced to the minimum necessary to ensure product safety, hygiene, and consumer acceptance during transport — that is Article 10(1), which applies from January 1, 2030; EN 13428:2004 stays the designated yardstick until then.
- Double walls, false bottoms, and unnecessary layers — packaging whose characteristics aim only to increase the perceived volume of the product — must not be placed on the market. That one is Article 10(2), and it has applied since August 12, 2026.
For e-commerce operators who routinely ship small items in oversized boxes, this is a fundamental shift, and the lead time is the point: the 50% cap lands on January 1, 2030, but the box range and the fulfilment lines that have to meet it are specified years earlier. The calculation methodology comes from the Article 24(2) implementing act, due on February 12, 2028 and not adopted — so measure your own product-to-box ratios now instead of waiting for it.
Who Is Responsible? Economic Operator Roles for Online Sales
The PPWR introduces clearly defined roles under Articles 15–22, and e-commerce creates unique scenarios where multiple parties share obligations:
| Role | Who in E-Commerce | Key PPWR Obligations |
|---|---|---|
| Manufacturer | Company that designs/produces the shipping packaging | Declaration of Conformity (DoC), recyclability assessment, technical documentation |
| Producer (Art. 3(15)) | Brand or online retailer first making packaging available on the EU market | EPR registration in each member state, eco-contribution fees, reporting obligations |
| Fulfilment Service Provider | 3PL warehouse, Amazon FBA, or similar | Compliance verification, labelling, minimisation enforcement at fulfilment |
| Online Marketplace | Amazon, Zalando, Cdiscount, etc. | Verify seller EPR registration, may bear co-responsibility under Art. 45 |
| Importer | EU entity importing products from non-EU sellers | Full manufacturer obligations if original manufacturer is outside EU |
Critically, under PPWR's online-marketplace and fulfilment-service-provider rules, online marketplaces that facilitate sales by non-EU sellers may be treated as the responsible producer if the actual seller has no EU establishment. This means platforms like Amazon, eBay, or AliExpress could bear EPR and DoC obligations for third-party sellers.
Transport Packaging and Grouped Packaging: What Counts?
E-commerce relies heavily on transport packaging — the outer box, padded mailer, or stretch wrap used for shipping. Under the PPWR, transport packaging is subject to the same recyclability, minimisation, and labelling requirements as any other packaging category. Key points:
- Grouped packaging (e.g., a multi-item order packed together) must comply individually with the 50% empty-space cap for the combined shipment, from January 1, 2030 (Article 24(1)).
- Void-fill materials (bubble wrap, air pillows, paper fill) are classified as packaging components and must be recyclable and declared in the DoC.
- Reusable packaging systems (Art. 26–27) offer exemptions from certain single-use restrictions and may benefit e-commerce operators offering return-and-reuse programmes from 2030 onward.
PFAS Ban and Food-Contact E-Commerce Packaging
From August 12, 2026, per- and polyfluoroalkyl substances (PFAS) are banned in food-contact packaging (Article 5(1)). For e-commerce businesses selling food products — meal kits, grocery delivery, direct-to-consumer food brands — this means:
- All food-contact packaging materials must be PFAS-free, including grease-resistant coatings on cardboard.
- Testing and documentation must demonstrate compliance, with results retained for at least 5 years.
- Suppliers of food-contact packaging must provide written declarations of PFAS-free status.
EPR Obligations Across 27 Member States
E-commerce sellers shipping cross-border face one of the most complex PPWR challenges: Extended Producer Responsibility (EPR) registration in every EU member state where they place packaging on the market. Under Articles 44–45, producers must:
- Register with the national EPR scheme in each target market (or appoint an authorised representative).
- Pay eco-contribution fees based on the weight and type of packaging placed on each market.
- Submit annual packaging data reports to each national authority.
- Comply with eco-modulation criteria that vary by country — for example, France's CITEO applies bonus/malus based on recyclability.
For a DTC brand selling to 10 EU countries, this could mean 10 separate registrations, 10 reporting calendars, and 10 different fee structures — a significant administrative burden without the right compliance tools.
Key Deadlines for E-Commerce Operators
| Date | Requirement | E-Commerce Impact |
|---|---|---|
| Aug 12, 2026 | DoC mandatory, PFAS ban (food-contact), Article 10(2) ban on packaging built only to look bigger | All shipping packaging must comply; fulfilment processes need updating |
| Aug 12, 2028 | Harmonised labelling under Article 12 becomes mandatory; Digital Product Passport (delivered via ESPR, Reg. (EU) 2024/1781) is reachable through the Article 12 QR-code data carrier | All packaging must carry the Article 12 label and QR-code data carrier linking to material and recyclability data |
| Jan 1, 2030 | Empty-space ratio capped at 50% for grouped, transport and e-commerce packaging (Article 24(1)); Article 10(1) weight-and-volume minimisation | Shipping boxes and mailers must be sized to the order; the calculation methodology comes from the Article 24(2) implementing act, due on February 12, 2028 and not adopted |
| Jan 1, 2030 | Below-Grade-C packaging banned from the EU market (Article 6 + Annex II); first Article 7(1) recycled-content step applies per plastic packaging category | Packaging failing the ≥70% recyclability threshold is no longer admissible; plastic packaging must meet the Article 7(1) minima that apply to each category (contact-sensitive vs non-contact-sensitive) |
| Jan 1, 2030 | Reuse targets for transport packaging (Art. 26) | E-commerce operators using >10,000 units/year may need reusable packaging systems |
| Jan 1, 2038 | Only recyclability grades A & B allowed | Complete shift to fully recyclable mono-material packaging |
How to Prepare Your E-Commerce Packaging Now
With only months until the August 2026 deadline, e-commerce businesses should take immediate action:
- Audit your shipping packaging portfolio — measure actual empty space ratios across your most common box sizes and product combinations. Identify the SKUs that exceed the 50% threshold and re-size them before January 1, 2030.
- Right-size your packaging — implement variable box-sizing or on-demand packaging solutions at fulfilment centres to minimise empty space automatically.
- Collect Declarations of Conformity — request DoCs from all packaging suppliers for every material and component (boxes, mailers, tape, void-fill, labels).
- Map your EPR obligations — identify every EU country you ship to and verify your registration status with each national EPR scheme.
- Verify PFAS compliance — if you ship food products, obtain PFAS-free declarations from all food-contact packaging suppliers immediately.
How PPWR Connect Helps E-Commerce Businesses
PPWR Connect is built to simplify compliance for e-commerce operators dealing with complex, multi-market packaging obligations. The platform automates DoC collection from suppliers, tracks EPR registrations across all 27 EU member states, assesses recyclability grades for every packaging component, and generates audit-ready compliance reports — all from a single dashboard. Whether you're a DTC brand, an online marketplace, or a 3PL provider, PPWR Connect gives you the visibility and control to meet the August 2026 deadline with confidence.