PPWR e-commerce: what changes for packaging and shipping from 2026

Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), introduces new European rules on packaging and packaging waste. The Regulation is generally applicable from 12 August 2026, but the individual obligations do not all start on the same date.

Important note on EPR: Extended Producer Responsibility itself is not being suspended. The European Commission has proposed suspending until 1 January 2035 the application of Article 45(3) of the PPWR, concerning the obligation to appoint an authorised EPR representative in other Member States for certain cross-border sales. This proposal must not be confused with a general suspension of EPR obligations.

For an e-commerce business selling within the European Union, the PPWR is particularly relevant because packaging compliance, national EPR schemes, local registrations and eco-contributions may all apply at the same time.

Why the PPWR affects e-commerce businesses

The PPWR applies to packaging of all kinds and materials, including:

• shipping boxes;
• envelopes and bags;
• transport packaging;
• protective packaging;
• air cushions and paper fillers;
• bubble wrap;
• tapes and other packaging components.

An online retailer does not need to manufacture packaging itself to be affected. In particular, when products are sold directly to consumers in another EU Member State, the retailer may become the producer for EPR purposes in the destination market.

Packaging manufacturer and EPR producer are not the same thing

This distinction is essential.

The manufacturer of a cardboard box is normally responsible for technical packaging requirements, including design, composition, technical documentation and the applicable declaration of conformity.

The e-commerce business buying that box may nevertheless have separate EPR obligations when it uses the packaging to deliver goods to consumers in another Member State.

For example:

• Italian packaging manufacturer → Italian retailer: the packaging manufacturer is responsible for its own PPWR obligations.
• Italian retailer → French consumer: the retailer may become the relevant EPR producer for the packaging entering the French market.
• Italian retailer → German consumer: German EPR and packaging registration requirements may apply separately.

Buying compliant packaging from a supplier therefore does not automatically cover the retailer's EPR obligations in every EU country.

What are EPR, PROs and eco-contributions?

EPR – Extended Producer Responsibility means that the producer identified by the applicable legislation is responsible not only for placing packaging on the market, but also for contributing to the cost of managing the resulting packaging waste.

Depending on the country, EPR compliance may include:

• registration in a national producer register;
• obtaining an EPR registration number;
• membership of a Producer Responsibility Organisation;
• reporting packaging quantities;
• classification by material and weight;
• payment of eco-contributions;
• appointment of an authorised representative.

What is a PRO?

A PRO – Producer Responsibility Organisation is an authorised organisation that manages packaging waste obligations collectively on behalf of producers.

Different countries use different terminology:

• France: éco-organisme;
• Germany: dual system;
• Spain: SCRAP;
• Belgium: organisations such as Fost Plus and Valipac.

What is an eco-contribution?

The eco-contribution finances the collection, sorting, recycling and management of packaging waste.

It may depend on:

• packaging weight;
• material;
• number of units;
• recyclability;
• recycled content;
• design features that make recycling easier or more difficult.

The eco-contribution must be distinguished from the fee charged by an EPR consultant or authorised representative.

Authorised EPR representatives in other EU Member States

Article 45(3) of the PPWR provides, for certain cross-border situations, for the appointment of an authorised representative for Extended Producer Responsibility in each relevant Member State other than the country where the producer is established.

The representative may manage:

• national registrations;
• PRO membership;
• periodic declarations;
• eco-contributions;
• communications with national authorities;
• documentation relating to the EPR mandate.

The European Commission has proposed suspending the application of this specific requirement until 1 January 2035.

However, there is an important unresolved issue: suspending Article 45(3) at EU level would not necessarily cancel national authorised-representative requirements that already exist. France, Spain, Austria and Belgium have national EPR rules concerning foreign sellers. These provisions must therefore continue to be checked country by country.

Current EPR situation in some major EU markets

Indicative costs for small e-commerce businesses

The PPWR does not establish fixed fees for EPR representatives. Costs depend on the national system, packaging volumes, materials and the private service provider used.

Important: the amounts above are indicative. Authorised-representative fees are commercial service fees, while eco-contributions are calculated according to the rules of the relevant national EPR system.

Are small businesses exempt from EPR?

There is no general EU exemption from packaging EPR based solely on company turnover.

Member States may nevertheless provide thresholds, simplified procedures or lower contributions for small quantities.

Examples include:

• Germany: no general minimum quantity exemption from the basic packaging registration obligation;
• France: simplified arrangements are available for very small numbers of packaging units;
• Spain: simplified reporting is available below certain annual packaging quantities;
• Belgium: the 300 kg/year threshold is relevant to certain take-back obligations;
• Netherlands: the standard packaging contribution generally applies above 50,000 kg/year, subject to important exceptions.

The EU definition of a micro-enterprise generally refers to a business with fewer than 10 employees and annual turnover or annual balance-sheet total not exceeding EUR 2 million. This status, however, does not automatically remove packaging EPR obligations.

The 50% empty-space rule: not from 2026

Another common misconception is that, from August 2026, e-commerce packages may no longer contain more than 50% empty space.

This is incorrect.

The Commission must first establish the calculation methodology. The specific 50% maximum empty-space ratio for grouped, transport and e-commerce packaging will apply from:

1 January 2030, or three years after the relevant implementing acts enter into force if that date is later.

Packaging fillers such as paper, bubble wrap, air cushions and foam count as empty space for the purposes of this ratio.

Shipping outside the European Union

For shipments to the United Kingdom, Switzerland, the United States or other non-EU countries, PPWR obligations relevant to the EU business must still be considered, but the destination country's own packaging and EPR rules may also apply.

An EU-compliant package is therefore not automatically compliant with the rules of a non-EU market.

The PPWR requirement concerning authorised representatives in other Member States does not mean that an Italian online retailer automatically needs a “PPWR representative” in the United States, Switzerland or the United Kingdom. Local legislation must be checked separately.

Practical checklist for an e-commerce business

Actions to take in 2026

• Map all sales, transport and e-commerce packaging used.
• Identify the company's role in the packaging supply chain.
• Collect technical data and declarations from packaging suppliers.
• Identify all EU countries where products are sold directly to consumers.
• Check the EPR system in each destination country.
• Verify national registration requirements and PRO membership.
• Check whether a local authorised representative is required.
• Track packaging quantities by destination country and material.

Preparing for 2027–2028

• Measure empty space in the main shipping formats.
• Review oversized boxes and excessive fillers.
• Prepare data for cross-border EPR reporting.
• Monitor harmonised labelling implementing acts.
• Update supplier and logistics procedures.

Preparing for 2030

• Apply the final 50% empty-space methodology.
• Review packaging recyclability.
• Assess recycled-content requirements.
• Evaluate reusable packaging where appropriate.
• Integrate packaging and EPR data into the e-commerce or ERP back office.

Need the complete analysis?

This English version summarises the main issues for international readers.

For a more detailed analysis including deadlines, national EPR systems, estimated costs, sanctions, examples and the Italian regulatory context, read the complete Italian guide:

Read the complete PPWR e-commerce guide in Italian

Official references

• Regulation (EU) 2025/40 – official PPWR text on EUR-Lex
• European Commission – Packaging waste
• COM(2025) 982 – proposal concerning Article 45(3)

Legal notice: the information contained in this article is provided for general informational and educational purposes only and does not constitute legal, tax or environmental advice. Packaging and Extended Producer Responsibility legislation is complex, evolves over time and may impose different obligations depending on the company's role, products, packaging materials and destination markets. Before taking operational or compliance decisions, businesses should verify the legislation currently in force and, where appropriate, obtain advice from a qualified professional or the competent national authority.