The EU's Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and, in its own words, "shall apply from 12 August 2026". Unlike the directive it replaces, it is a regulation: it applies directly in every member state without national transposition. And unlike most packaging law before it, it names e-commerce specifically, defines "e-commerce packaging" as its own category, and attaches obligations to the people who fill the box: you.
This guide covers the parts that land on an online seller's packing bench and returns flow, with the article numbers so your team can check the source. It is not legal advice. It is the operational reading of a regulation that most packaging summaries write for manufacturers, not for the brand shipping 30,000 parcels a year.
Short answer: From 12 August 2026 the PPWR applies across the EU. For online sellers the operative rules are: a 50% maximum empty-space ratio for e-commerce, grouped and transport packaging (Article 24, biting by 1 January 2030 at the latest), with void fill counted as empty space; reuse targets for transport packaging from 2030 (Article 29); harmonised sorting labels on packaging from 12 August 2028, and e-commerce packaging is explicitly not exempt (Article 12); and a "minimum necessary" design rule for all packaging by 2030 (Article 10). If you ship the product in its own sales packaging, you are exempt from the 50% cap.
Who and what the PPWR covers
The regulation defines the box you ship in. Under Article 3, "'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". Transport packaging is "packaging conceived so as to facilitate the handling and transport of one or more sales units", and grouped packaging is "packaging conceived so as to constitute a grouping of a certain number of sales units".
The obligations fall on "economic operators", which the regulation defines to include "the manufacturer, the supplier, the importer, the distributor, the authorised representative, the final distributor and the fulfilment service provider". A DTC brand packing its own orders is the operator who "fills" e-commerce packaging. If a 3PL packs for you, the recitals say the regulation aims to prevent "free-riding" by fulfilment service providers too, so the obligation does not disappear when you outsource the bench.
The 50% empty-space rule (Article 24)
This is the headline for online sellers. Article 24(1): "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 %."
Three things about it matter operationally.
Void fill counts as empty. Article 24(3): "Space filled by filling materials, such as paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene or Styrofoam chips, shall be considered as empty space." The ratio is the empty space divided by the total volume of the shipping box, where empty space is "the difference between the total volume of grouped packaging, transport packaging or e-commerce packaging and the volume of sales packaging contained therein". A small product in a standard box padded with air pillows fails on paper.
The date is later than the regulation's start. The cap applies "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". The Commission must adopt the calculation methodology "by 12 February 2028", and that methodology must account for irregular shapes, multi-item orders, liquids, fragile goods and "the minimum space on the transport packaging to enable shipment labels to be affixed". So the rule is set, the maths is pending, and the hard date is 2030 or later.
Two exemptions are written in. Article 24(5): "Economic operators using sales packaging as e-commerce packaging or using reusable packaging within a system of re-use shall be exempt from the obligation laid down in paragraph 1". Ship the product in its own retail box, or in a reusable mailer inside a return system, and the 50% cap does not apply to that shipment.
Separately, Article 24(4) puts a "minimum necessary" duty on sales packaging itself by 12 February 2028, again counting filling materials as empty space.
Reuse targets for transport packaging (Article 29)
Article 29(1): "From 1 January 2030, economic operators that use transport packaging, or sales packaging used for transporting products, including for products distributed via e-commerce, within the territory of the Union, in the form of pallets, foldable-plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters of any size or material ... shall ensure that at least 40 % of such packaging in total is reusable packaging within a re-use system." From 1 January 2040 the same operators "shall endeavour to use at least 70 %".
Read that list again: "boxes" is in it, and "including for products distributed via e-commerce" is explicit. The 40% is measured across the operator's transport packaging in total, not per parcel, and Article 29(3) tightens it to 100% reusable for transport packaging moving between economic operators inside the same member state. Exemptions in Article 29(4) cover dangerous goods, custom-designed packaging for large machinery, and flexible food-contact formats. Consumer parcels are not exempt.
Sorting labels, and e-commerce packaging is not exempt (Article 12)
Article 12(1): "From 12 August 2028 ... packaging placed on the market shall be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting. The label shall be based on pictograms". Transport packaging is generally excused from this, with one carve-out that matters here: "With the exception of e-commerce packaging, this obligation does not apply to transport packaging". The box a consumer opens at home must carry the sorting label; the pallet wrap between your 3PL and a carrier hub does not.
Packaging minimisation for everyone (Article 10)
Article 10(1): "By 1 January 2030, the manufacturer or importer shall ensure that the packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality". Article 10(2) targets packaging "with characteristics that aim only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers". For a brand that imports its own branded boxes, that obligation is yours as the importer.
What changes at the packing bench
The PPWR is an operations problem before it is a compliance problem, and it interacts with the returns flow.
- Box selection becomes a rule, not a habit. Picking the smallest carton that fits the order is exactly what a pick-and-pack system with cartonisation does. If your warehouse software chooses the box, the 50% ratio is a configuration; if a packer chooses it, it is training and audit.
- Returns get a second life. Reusable e-commerce packaging within a re-use system earns the Article 24 exemption and counts toward the Article 29 target. That only works if the mailer comes back, which makes the return label and the return flow part of the packaging plan.
- Sales packaging as shipping packaging is the cheapest exemption. Products already in a sturdy retail box can ship in that box. That is a merchandising and damage-rate decision, and the carrier data on damage by lane is what should drive it.
- Multi-item orders are the hard case. Article 24(2) instructs the Commission's methodology to account for "packaging containing more than one sales packaging or product", which is most e-commerce orders. Watch the implementing act due by 12 February 2028.
For the wider compliance cluster, see the EU withdrawal button rule that applied from 19 June 2026, the General Product Safety Regulation for online sellers, and the 14-day right of withdrawal that shapes every EU return.
How Pango fits
Pango runs pick and pack on the same order record as carrier routing, tracking and returns. Carton choice is a rule the system applies per order, so the smallest fitting box is the default rather than the packer's guess. Return labels and the reverse leg run through the same carriers as the outbound parcel, which is the plumbing a reusable-packaging loop needs. And because damage rates by carrier and lane sit next to the packaging decision, the choice between a protective shipper and a product's own box is made on data. The regulation asks operators to decide these things deliberately; Pango is built so they are decided once, as rules, and then run.
See it on your own orders
Bring your top 20 SKUs and your current carton list. We will show you what the empty-space ratio looks like per order today, and how cartonisation rules and a reusable return loop change it. Book a demo.
