PPWR in e-commerce: shipping packaging, empty space and online-store obligations

Online stores are one of the groups that PPWR affects most strongly and most quickly. The reason is simple: every parcel you ship is packaging within the meaning of the regulation - the box, the courier envelope, the film, the tape and the filler. And that means new obligations: determining your role, documentation and - over a longer horizon - changes to the packing operation itself.

Regulation (EU) 2025/40 (PPWR) entered into force on 11 February 2025, and its key provisions will apply from 12 August 2026 - directly, without national implementation. Some requirements (including the empty-space limit and recyclability classes) will start to apply later, in stages up to 2030. Below we explain what this specifically means for e-commerce and where the most common misunderstandings lie.

Who in e-commerce does PPWR apply to?

PPWR uses a functional definition of packaging and a broad concept of the entity placing it on the market. In practice it applies to:

• B2C stores selling their own products from a warehouse in Poland
• marketplace sellers (Allegro, Amazon, eBay) placing packaging on the market for the first time
• dropshippers - subject to the caveat that the scope of responsibility depends on the cooperation model (more on this below)
• importers selling, through their own platform, products sourced from outside the EU

Importantly, SMEs are not automatically exempt - the scope of obligations depends on your role in the supply chain, not on company size.

Is an online store the manufacturer of the packaging?

Not necessarily - and this is an important correction to a common simplification. A store may play different roles with respect to different elements of the parcel, because PPWR distinguishes between product (sales) packaging, grouped packaging and transport (shipping / e-commerce) packaging.

• If you commission the production of shipping packaging under your own name or trademark, or independently decide on its specification, you may be its manufacturer.
• For standard, unbranded boxes or envelopes, the manufacturer may remain their supplier. Buying an ordinary box and packing an order in it does not automatically make you its manufacturer.
• Separately, you need to determine who is responsible for EPR (more on this later).

Practical takeaway: do not assume you must issue a declaration of conformity for every box you buy. First determine which element of the parcel you are the manufacturer of, and for which you are merely an entity further down the chain.

The table below shows how the role may differ depending on the sales model:

Check the exact role for your sales model ->

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PPWR, dropshipping and marketplaces

In dropshipping, responsibility is not automatic - it depends on the cooperation model. What matters includes who packs the product, who commissions or defines the packaging specification, whose brand it bears, who imports the product, and from and to which country it goes. For direct sales to an end user in another EU country, the store may become an EPR producer in the recipient's country - but this does not automatically mean it is also the manufacturer of the packaging in every configuration.

In the marketplace model there is an additional element: PPWR requires platforms to obtain registration numbers and the seller's declaration of compliance with EPR obligations before admitting the seller to sell. In practice, platforms (e.g. Allegro, Amazon) already verify registration today and can suspend a seller's account without the required entries.

When does the 50% empty-space limit start to apply?

This is the topic surrounded by the most misinformation. The most important point: the empty-space limit does not start to apply on 12 August 2026.

PPWR introduces a maximum empty-space level of 50% in e-commerce, transport and grouped packaging (Article 24). This obligation will start to apply on 1 January 2030, or three years after the entry into force of the implementing act defining how empty space is calculated - whichever date is later. The Commission is to adopt this method by 12 February 2028.

For sales (commercial) packaging there is a separate obligation: from 12 February 2028, the filler must reduce empty space to the minimum necessary for the product's functionality and protection and demonstrate this in the documentation - without a rigid percentage threshold.

The "40% from August 2026" you may come across online is a double error: the numerical value for grouped/transport/e-commerce packaging is 50%, and the hard deadline is 1 January 2030 at the earliest. Until the end of 2029, the existing requirements on reducing packaging weight and volume apply.

Does filler count as empty space?

Yes. Filling materials - paper shreds, air pillows, bubble film, sponge and foam fillers, wood wool, polystyrene or Styrofoam chips - are treated as empty space, not as product. Adding more filler does not "save" compliance; what matters is choosing a smaller, right-sized box.

The future calculation method is to take into account cases where additional space is necessary - for product protection, irregular shape, susceptibility to damage, liquid products or a space for the shipping label. The detailed rules for documenting such situations have not yet been defined (they will appear in an implementing act by 12 February 2028).

Recyclate, PFAS and recyclability - the key deadlines

Beyond packaging minimisation, it is worth planning the remaining requirements according to their dates of application:

• PFAS (from 12.08.2026): a ban in food-contact packaging above set thresholds, plus heavy-metal limits. This is the earliest applicable requirement - important if you sell food, coffee, supplements or ready meals.
• Recyclate in plastic packaging (from 2030 or later): for many non-contact plastic packages, e.g. films and shipping envelopes, the target level will be essentially 35% from 2030 and 65% from 2040. It is calculated as an average per plant and year; there are exceptions, and the exact classification depends on the type of packaging.
• Recyclability classes A-C (from 2030 or later): they will start to apply from 1 January 2030, or 24 months after the entry into force of the acts defining the criteria. Until then, it is worth preparing data on construction, materials, components, labels and closures, which will be needed for the future assessment.
• Harmonised labelling (from 12.02.2028): material and sorting pictograms.
• Declaration of conformity and technical documentation: if the store is the manufacturer of a given packaging item, it is responsible for drawing them up. If it acts as an importer or distributor, its obligations consist of verifying, retaining or ensuring the availability of the documentation - depending on the role.
• Traceability (Article 22, from 12.08.2026): the ability to indicate who you received the packaging or packaged product from and to whom it was delivered. The information must be kept for 5 years for single-use packaging and 10 years for reusable packaging.

PPWR, EPR and BDO - how do the obligations differ?

Packaging compliance and EPR/BDO are two parallel tracks of obligations:

• Packaging compliance - construction, substances, recyclate, technical documentation and declaration of conformity.
• EPR - producer registration, financing of waste management and reporting in the country where the packaging is to become waste. In Poland these obligations are currently handled, among other things, through the BDO database.

Importantly, PPWR itself already contains provisions on EPR, producer registration and the responsibility of online platforms. BDO is the national tool for fulfilling registration and reporting obligations, which must operate in line with PPWR - these are not two entirely separate worlds, but two tracks of the same system.

For direct online sales to consumers or professional end users in other EU countries, the store may be subject to EPR registration in the recipients' countries (e.g. LUCID in Germany, where platforms verify registration as a condition of sale). For sales to a foreign distributor the classification may look different - the EPR producer in its own country may then become that distributor.

Not sure whether you are the manufacturer? Check in 2 minutes

Before you count empty space and collect declarations from film suppliers, determine your role - the entire scope of obligations depends on it. The quiz asks the right questions about your model (own warehouse, dropshipping, marketplace, import) and indicates your role, EPR status and the most important deadlines.

Check your role under PPWR ->

2 minutes - free - instant result

After the quiz you can receive, to your business e-mail, a checklist of obligations matched to an e-commerce profile - all you need is an address and a company name.

How to prepare your packing operation for PPWR?

1. Inventory your packaging - all sizes of boxes, envelopes, films, tapes and fillers, their weight and material.
2. Calculate empty space for the 5-10 most frequently shipped products - you will catch boxes that are 1-2 sizes too large (useful ahead of the 2028/2030 deadlines).
3. Introduce right-sizing - match box formats to dimensions and reduce "cosmetic" fillers.
4. Collect documentation from suppliers - composition and recyclate declarations for films, tapes and envelopes.
5. Put your EPR/BDO in order - check registration and the completeness of reports, including for foreign markets.

As a guide, by time horizon: 2026 - PFAS, determining roles, documentation and compliance with the applicable requirements; 2028 - harmonised labelling and empty space in sales packaging; 2030+ - the 50% limit, recyclate, recyclability classes and minimisation requirements.

Do you have a large number of SKUs and many packaging suppliers? Plan Be Eco automates collecting data from suppliers, validating the applicable PPWR requirements (including Articles 5-12) and generating declarations of conformity and handling their signing workflow - with data entered once at component level, without Excel spreadsheets.

See how to manage PPWR across many products ->

FAQ - PPWR and e-commerce

Does PPWR apply to my online store?

Yes, if you ship products in packaging onto the EU market - regardless of company size. This applies to B2C stores, marketplace sellers, dropshippers and importers. PPWR uses a functional definition of packaging, so it also covers shipping boxes, envelopes, films and fillers.

When does the 50% empty-space limit in a parcel start to apply?

The 50% limit (Article 24 of PPWR) for e-commerce, grouped and transport packaging applies from 1 January 2030, or three years after the entry into force of the implementing act with the calculation method - whichever comes later (the method is to be ready by 12 February 2028). It does not apply from August 2026. The "40% from August 2026" you may come across is an incorrect simplification.

Does filler (bubble film, wood wool) count as product or empty space?

It counts as empty space - paper shreds, air pillows, bubble film, sponges, foams, wood wool and Styrofoam chips are treated as empty space, not product. Adding filler does not help you stay within the limit; what matters is choosing a smaller box. The future method is to take into account cases where additional space is necessary (protection, irregular shape, liquids, label) - the details will be set out in an implementing act.

I'm a dropshipper - am I responsible for the packaging if the supplier ships the parcel?

Not always. In dropshipping, responsibility depends on the cooperation model. What matters includes who packs the product, who commissions or defines the packaging specification, whose brand it bears, and which country it goes to. The store may be the EPR producer for direct sales to an end user, but the manufacturer of the packaging may remain the supplier or the entity handling the shipment.

Does PPWR replace BDO obligations?

No. Packaging compliance (PPWR) and EPR/BDO are two parallel tracks of obligations. PPWR itself contains provisions on EPR and producer registration, while BDO is the national tool for fulfilling registration and reporting obligations. For direct sales to other EU countries, EPR registration in the recipient country may be added (e.g. LUCID in Germany).

I sell food online - what does PPWR change for packaging?

From 12 August 2026 there is a ban on PFAS in food-contact packaging above set thresholds, plus heavy-metal limits. This applies to, among others, grease- and moisture-resistant containers, paper and board. Particular attention should be paid to packaging for which the supplier has not provided reliable test results or a declaration of conformity.

Update: June 2026. This article reflects the European Commission's guidance C(2026) 3702 final of 5 June 2026 on the application of Regulation (EU) 2025/40 (PPWR) and the dates of application of the individual obligations (2026-2030).

The above content is for educational and informational purposes only. It does not constitute legal advice or a legal opinion and may not be relied upon as the basis for decisions in an individual case. Classifying your role under PPWR depends on the specific facts - if in doubt, consult a legal adviser or a compliance specialist.

Plan Be Eco is a Polish SaaS platform for ESG and EU-regulation compliance, with a PPWR module that guides you through the full compliance path - from supplier data to a signed declaration of conformity.

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