PPWR Packaging Regulation: What Changes for Ecommerce

Ecommerce packaging is about to change radically. The European PPWR regulation (Packaging and Packaging Waste Regulation) introduces new rules on recyclability, reuse, and reduction of packaging materials that directly affect every merchant shipping packages across Europe.

TL;DR: Regulation (EU) 2025/40, known as the PPWR, has been in force since February 11, 2025, and applies from August 12, 2026, with obligations phased in through 2040. For ecommerce merchants the main obligations start in 2030: empty space in parcels capped at 50%, recyclable packaging, and a minimum share of recycled plastic. The EU label on materials arrives no earlier than August 12, 2028. Those who comply early turn an obligation into a competitive advantage.

For D2C brands selling in Italy and across Europe, ignoring the PPWR is not an option. The penalties are significant, and consumers are increasingly sustainability-conscious.

What is the PPWR: the regulation in brief

The PPWR, Packaging and Packaging Waste Regulation, is Regulation (EU) 2025/40, which replaces the previous packaging directive (94/62/EC), repealed as of August 12, 2026. Unlike the directive, which left wide margins for transposition by individual member states, the regulation is directly applicable across all EU countries without national transposition.

The European Parliament adopted its position on April 24, 2024, and the Council gave its approval on December 16, 2024. The regulation is dated December 19, 2024, was published in the Official Journal of the EU on January 22, 2025, has been in force since February 11, 2025, and applies from August 12, 2026 (Art. 71). Among its objectives, each member state must reduce packaging waste per capita, compared with 2018, by at least 5% by 2030, 10% by 2035, and 15% by 2040 (Art. 43).

Why the PPWR directly concerns ecommerce

In the recitals of the regulation, the EU legislator writes that packaging waste has increased, both in absolute terms and per capita, and that the decline in reuse is amplified by the growth of takeaway food and ecommerce (recital 114). This is why the PPWR has rules written specifically for "e-commerce packaging," meaning the packaging used to deliver products to people who buy online (Art. 3).

The PPWR addresses this problem with measures specific to the ecommerce sector:

Empty space in the parcel capped at 50%, to curb so-called "over-packaging" (Art. 24)
Recyclability obligations for all packaging (Art. 6)
Packaging weight and volume reduced to the minimum necessary (Art. 10)
A harmonized label on materials, mandatory for ecommerce packaging too (Art. 12)

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Implementation timeline: what happens and when

The PPWR obligations do not all kick in at once. Implementation is progressive, with different deadlines for different obligations. Some apply from a fixed date or a few years after the acts in which the Commission defines the technical details, whichever comes later: below we give the fixed date, which is the earliest possible.

2025-2026: entry into force and application

January 22, 2025: Regulation (EU) 2025/40 is published in the Official Journal of the EU
February 11, 2025: it enters into force
August 12, 2026: it applies, and Directive 94/62/EC is repealed, with some transitional provisions (Art. 70). From this date, whoever manufactures the packaging must show on it, or through a QR code, their name or trademark and a postal address (Art. 15)

2027-2029: penalties, technical rules, and labels

February 12, 2027: deadline for each member state to set penalties (Art. 68)
January 1, 2028: deadline for the Commission to adopt the design-for-recycling criteria and the recyclability performance grades A, B, and C (Art. 6)
February 12, 2028: whoever fills sales packaging must reduce empty space to the minimum necessary, product protection included (Art. 24)
August 12, 2028: harmonized label on materials, or 24 months after the implementing acts that define it, whichever is later (Art. 12)

2030 and beyond: the main obligations

January 1, 2030: packaging recyclable to at least grade C (Art. 6), empty space of no more than 50% in ecommerce packaging (Art. 24), weight and volume reduced to the minimum necessary (Art. 10), minimum shares of recycled plastic (Art. 7), and a ban on certain single-use formats, such as plastic used to group several products in shops or single-use toiletry bottles in hotels (Art. 25 and Annex V)
2030: each member state reduces packaging waste per capita by 5% compared with 2018 (Art. 43)
2035: 10% reduction in packaging waste per capita; from January 1, 2035, packaging must also be recycled at scale (Art. 6)
January 1, 2038: only grade A or B packaging allowed (Art. 6)
2040: 15% reduction in packaging waste per capita and higher shares of recycled plastic (Art. 7 and Art. 43)

Recycled content targets for plastic

Packaging Type	By 2030	By 2040
Contact-sensitive PET packaging (for example for food, cosmetics, medicines), excluding beverage bottles	30%	50%
Contact-sensitive packaging in other plastics, excluding beverage bottles	10%	25%
Single-use plastic beverage bottles	30%	65%
Other plastic packaging	35%	65%

The shares apply to the plastic parts of each packaging unit and are calculated as an average per manufacturing plant and per year. Exempt, among others, are compostable plastic packaging and plastic parts weighing less than 5% of the packaging unit (Art. 7). The first deadline is January 1, 2030, or three years after the implementing act on the calculation method, whichever is later.

Impact on ecommerce: what changes concretely

The excessive void rule

One of the most relevant provisions for ecommerce is the cap on empty space in shipping packaging (Art. 24). The PPWR establishes that:

From January 1, 2030 (or three years after the implementing acts on the calculation method, if later), whoever fills ecommerce packaging must ensure that empty space does not exceed 50% of the parcel's volume
Empty space is the difference between the volume of the parcel and that of the sales packaging inside it, and the space taken up by filler (paper cuttings, air cushions, bubble wrap, polystyrene chips, and the like) counts as empty space
Those who ship the product directly in its sales packaging, without an outer box, are exempt from this cap, but the sales packaging must meet the minimization rules (Art. 10)
The Commission sets the calculation method through implementing acts, taking into account easily damaged products, irregularly shaped ones, liquids, and the space needed for the shipping label

In practice, from 2030 shipping a small product in a large box filled with paper or air will no longer be allowed. The merchant (or their logistics partner) must select the correct packaging format for each order. For fragile products, protection remains the priority, and our guide to the best way to pack fragile items for shipping explains how to pack them properly, with the measurements given in carriers' guides.

Labeling obligations

The information required on packaging comes in three stages:

From August 12, 2026: whoever manufactures the packaging, or has it manufactured under their own name or trademark, must show on the packaging or through a QR code their name or trademark and a postal address, plus a type, batch, or serial number that identifies it; if that is not possible, in a document accompanying the product (Art. 15)
From August 12, 2028 at the earliest: a harmonized EU label, made of pictograms, showing the materials the packaging is made of, to help consumers sort their waste (Art. 12). Transport packaging is exempt, but ecommerce packaging is not
In Italy, already today: the environmental labeling required by the Italian Environmental Code (Testo unico ambientale), mandatory since January 1, 2023, with the nature of the materials and information for consumers on where the packaging should end up (Art. 219(5) of Legislative Decree 152/2006)

For ecommerce merchants, this translates to the obligation to use boxes, envelopes, and filler materials that carry this information. Packaging suppliers are updating their products, but responsibility for compliance lies with the manufacturer: whoever produces the packaging, or has it produced under their own name or trademark, such as a box printed with the store's logo. If you are a micro-enterprise and your supplier is located in the EU, your supplier counts as the manufacturer for these obligations (Art. 15).

Material restrictions

The PPWR introduces progressive restrictions that also affect materials:

Expanded polystyrene (EPS) and other fillers: they are not among the formats banned by Annex V, but from 2030 they count as empty space in the 50% calculation (Art. 24)
Non-recyclable plastic: from 2030 packaging that does not reach at least recyclability grade C cannot be placed on the market, and from 2038 at least grade B will be required (Art. 6)
Multi-material packaging: the design-for-recycling criteria take into account whether materials can be separated for recycling (Art. 6)

EPR (Extended Producer Responsibility) obligations

The PPWR strengthens the extended producer responsibility principle. Whoever the regulation calls a "producer" is responsible for the end-of-life management of the packaging they make available for the first time in a member state, including the boxes used for ecommerce shipments (Art. 45). This translates to:

In Italy, participation in CONAI (the National Packaging Consortium), which the Italian Environmental Code requires of packaging producers and users, unless they run an alternative system (Art. 221 of Legislative Decree 152/2006)
Registration in the register of producers provided for by the regulation in every member state where packaging is made available for the first time, with data to report every year by June 1 (Art. 44)
If you sell directly to consumers in another member state, for example to Italy from abroad, you are the producer there, and you must appoint an authorized representative for extended producer responsibility in that country (Art. 3 and Art. 45)

How to comply: practical guide for merchants

Step 1: Audit your current packaging

First, analyze your current packaging:

How many box formats do you use?
What is the average ratio between product and packaging?
What materials do you use (cardboard, plastic, polystyrene, paper)?
Do your packaging materials display composition information?
Does your packaging supplier guarantee PPWR compliance?

Step 2: Size optimization

The most impactful action is reducing void in shipments:

Adopt a multi-format system, with box sizes chosen to fit the products you ship most often
Use padded envelopes for products that do not require rigid boxes
Implement a right-sizing system that selects the correct packaging for each order
Eliminate unnecessary filler material

This optimization has a double benefit: it reduces shipping costs (less volume = less volumetric weight) and moves closer to PPWR compliance.

Step 3: Transition to compliant materials

Plan the transition to materials meeting PPWR requirements:

Corrugated cardboard, including FSC-certified: widely available; you will be able to check each package's recyclability grade against the EU criteria due by January 1, 2028
Kraft paper for filling: replacement for polystyrene, but from 2030 it also counts as empty space
Paper envelopes: alternative to plastic envelopes for non-fragile products
Paper adhesive tape: replacement for plastic tape
Cardboard inserts: replacement for plastic protections

Step 4: Update labeling

Ensure all your packaging materials display the required information (today the Italian environmental labeling, and from 2028 at the earliest the EU label):

Contact your packaging supplier to verify compliance
If you use custom packaging, update the design to include mandatory markings
If your 3PL provides packaging, verify it is compliant

Step 5: Documentation and reporting

Prepare the necessary documentation:

Register of packaging materials used with annual quantities
CONAI status checked (membership and any declarations, for Italy)
Technical specifications of materials (recyclability data sheets)

Transition costs

PPWR compliance has a cost, which depends on your volumes and materials and can be kept down if you plan it in time. We have not found reliable data on average costs, so the table lists the items rather than figures: for numbers you need quotes from your suppliers.

Action	What it involves	What it can save
Packaging audit	Internal time or a consultant, one-time	The basis for optimization
Right-sizing (multi-format)	More box sizes to manage	Cheaper shipping, when the carrier charges by volumetric weight
Transition to compliant materials	Prices to request from suppliers	No rushed packaging replacement in 2030
Labeling update	Artwork to redo, one-time	Labels in line with the deadlines
CONAI and EPR consultancy	A recurring cost, if you use a consultant	Correct declarations

Right-sizing, in particular, can pay for itself: when the carrier calculates the rate on volumetric weight, a smaller parcel costs less to ship.

How Tissquad can help

Tissquad runs logistics for online stores from its warehouse in Campania, in the Naples area. It receives your goods, picks and packs orders, ships them with several carriers, and handles cash on delivery and returns. The main PPWR packaging obligations start in 2030, and in the meantime it pays to agree in writing with whoever prepares your orders on formats, materials, and who does what, as we explain in the FAQ. To talk it through, contact us or see how our fulfillment works.

Frequently asked questions

Does the PPWR apply to small ecommerce businesses too?

Yes. The regulation applies to all packaging (Art. 2), and the 50% empty space cap has no exemption for small businesses. There is some relief for micro-enterprises: for example, if you have packaging manufactured under your name or trademark by a supplier located in the EU, the supplier counts as the manufacturer for the manufacturer's obligations (Art. 15).

What are the penalties for non-compliance?

Penalties for breaches of the PPWR are set by each member state, by February 12, 2027 (Art. 68). In Italy, the penalties of the Environmental Code currently apply (Legislative Decree 152/2006, Art. 261): for example, €5,000 for producers and users who fail to meet the collection obligation through CONAI or an alternative system, and from €5,000 to €25,000 for placing packaging on the market without the environmental labeling. This article is not legal advice.

Can I continue using plastic packaging?

Yes, but with increasing restrictions. Packaging plastic must be recyclable (from 2030, or 24 months after the EU criteria if later) and contain a minimum percentage of recycled material (from 2030, or three years after the calculation method if later). Non-recyclable plastics will be progressively eliminated. Transitioning to alternative materials (paper, cardboard) is advisable starting now.

Is my 3PL responsible for packaging compliance?

It depends on the obligation. Whoever manufactures the packaging, or has it manufactured under their own name or trademark, is responsible for its compliance (Art. 15). Whoever fills the ecommerce packaging is responsible for the empty space, from 2030 (Art. 24). The fulfillment service provider must ensure that storage, packing, and shipping do not compromise the compliance of the packaging it handles (Art. 20). It is essential to put in writing who does what, including for EPR documentation.

How does the PPWR impact shipping costs?

In the short term, the PPWR may increase the cost of some packaging materials. In the medium term, the empty space cap pushes toward smaller parcels, and when the carrier calculates the rate on volumetric weight a smaller parcel costs less. The net effect depends on how much empty space your parcels have today: it is worth measuring it with the audit in step 1.