The PPWR has been operational for two months. The new European packaging regulation , i.e. Regulation (EU) 2025/40, has applied since 12 August 2026 (EUR-Lex) and changes the way every box leaving the warehouse is designed, documented and filled. For those who sell online, the parcel is the only packaging the customer always sees, and in the ecommerce logistics model it passes through the hands of several parties before reaching its destination.
What the PPWR is and why it concerns those who ship online
PPWR stands for Packaging and Packaging Waste Regulation. It replaces the old Directive 94/62/EC and aims to reduce packaging waste, make everything placed on the market recyclable and push reuse where it makes sense. For ecommerce the point of contact is direct, because the text explicitly namesecommerce packaging, the packaging used to ship the product to the end consumer.
From directive to regulation: the same rules in all 27 EU countries
The difference between a directive and a regulation is not a detail for lawyers. A directive must be transposed by each State through a national law, and so over the years different rules have accumulated on labels, contributions and definitions. The PPWR regulation , instead, applies directly and in the same way throughout the Union. For those who sell in several countries, this means that a box that is compliant in Italy will also be compliant in Germany or France, even though for now some national rules coexist pending the implementing acts.
Manufacturer, supplier, distributor: the roles in the ecommerce supply chain
The regulation distributes obligations according to role. The manufacturer is whoever produces the packaging, or the packaged product, and markets it under its own name; the importer brings packaging into the EU from third countries; the distributor makes it available on the market without modifying it.
A D2C brand that signs the packaging of its product and then places it in a box for shipping can have several roles at the same time, so the first exercise is to map them, packaging by packaging.
What is already mandatory from 12 August 2026
Not all obligations kicked in on 12 August. The guidelines published by the European Commission help to distinguish them, although they are not legally binding.
Declaration of conformity and technical documentation
First of all, according to the guidelines, packaging placed on the market must be accompanied by an EU declaration of conformity and by technical documentation supporting it. In practice, the manufacturer must be able to demonstrate that the material meets the requirements of the regulation. For an ecommerce business, this means asking suppliers of cardboard, mailers and void fill for their declaration and keeping it, and preparing its own declaration for the packaging it signs with its brand.
Restricted substances
The limits on heavy metals in packaging and the ban on PFAS above the thresholds set for food-contact packaging are already in force. Those who ship food gifting or supplements must therefore also check the primary packaging, not just the outer box.
EPR registration and data on packaging placed on the market
Extended producer responsibility remains: those who place packaging on the market must be registered in the producer register and report quantities by material. In Italy the reference remains the CONAI system and the material consortia, pending the harmonised register format that the Commission has yet to adopt. Those who make distance sales to other Member States must also check registration obligations there.
Logistics ready for the new packaging rules
The next deadlines: from 2028 to 2030
The most demanding deadlines for those who ship online are further away, but they affect formats, suppliers and material stocks and must be prepared in good time:
- from 12 August 2028 at the earliest, theenvironmental labelling of packaging becomes harmonised at EU level, with common pictograms defined by an implementing act; until then, national rules remain valid in Italy;
- from 1 January 2030, packaging must be designed to reduce weight and volume to the minimum necessary for its function (Art. 10), and marketing or customer perception will no longer be enough to justify excess volume;
- also from 1 January 2030, or three years after the acts defining the calculation method if later, ecommerce packaging may not exceed 50% empty space;
- from 2030, recyclability requirements by performance grade and reuse targets for some transport packaging also come into play.
The empty space limit deserves particular attention, because filling material counts as empty space. Air cushions, crumpled paper and chips do not help to stay within 50%: only a box of the right size does. And the obligation, according to the guidelines, falls on whoever fills the packaging.
What changes in the warehouse: boxes, void fill and formats
Translated into operations, the PPWR shifts the problem from the packaging supplier to the packingbench. Those who today work with two or three universal box formats and make up the difference with void fill will need to review their range well before 2030, because packaging orders and buffer stocks are planned on long cycles. The same applies to bulky or irregular products, where shipping bulky parcels already imposes format and cost constraints today.
Reducing box formats without slowing down packing
The instinct would be to multiply box sizes to get closer to each product, but every additional format takes up space, complicates reordering and slows down the operator who has to choose. Useful work starts from data: which combinations of items appear most often in orders, which dimensions cover most shipments, where empty space is systematically high. From there, a reasoned set of formats is defined, with clear assignment rules for whoever prepares the parcel. A packaging service managed by the logistics partner can include this analysis in the onboarding phase.
Primary packaging and shipping packaging
Many beauty and D2C fashion brands have invested in primary packaging: cases, gift boxes, tissue paper. With the PPWR it is worth looking at primary and secondary packaging together, because a product already protected by a rigid case could travel in a paper mailer instead of a box, while a fragile item requires the opposite. The choices made over the years on sustainable packaging remain valid, but they need to be reread in light of the definitions and thresholds of the regulation, which are more precise than any voluntary guideline. For ecommerce packaging and sustainable packaging , the thresholds of the regulation become the new minimum reference.
PPWR and peak season: what to check before Black Friday and Christmas
The peak is not the time to change formats, but it is the right time to avoid mistakes. In November and December, emergency suppliers and seasonal gift packaging are added, and this is where documentation gaps arise: a batch of Christmas boxes bought in a hurry without a declaration of conformity is a risk that can be avoided with a written request to the supplier. In our logistics checklist for Black Friday and Christmas , packaging control is among the checks to be completed by T-30. Peak data on the formats used and on empty space, analysed in January, then become the basis for the work towards 2030.
How to work with your logistics partner on packaging compliance
When packing is entrusted to an external partner, compliance becomes a contractual as well as an operational issue. The brand normally remains responsible for the packaging it places on the market under its own name, but whoever fills the box influences volume, void fill and choice of format. It is therefore worth clarifying in writing who purchases the materials, who keeps the suppliers' declarations, which box assignment rules apply and which data on volumes shipped by material are shared for EPR declarations.
An ecommerce fulfilment partner that works around the business calendar can help schedule the change of formats in the low-season months, away from peaks, and measure the effect of the new packing rules on times and costs.