Marcus ships phone accessories from a fulfilment partner in Poland. His best-selling item is a phone stand the size of a deck of cards, but it goes out in a 30x20x15cm box because that's the smallest carton his 3PL keeps in stock, padded out with air pillows so it doesn't rattle. When his freight forwarder mentioned "void space limits" becoming a compliance issue next year, Marcus assumed it was some customs footnote. It isn't. It's the Packaging and Packaging Waste Regulation, and it's going to change how his boxes look, not just how his goods clear the border.
What the Packaging and Packaging Waste Regulation actually changes
The Packaging and Packaging Waste Regulation — PPWR, Regulation (EU) 2025/40 — applies from 12 August 2026 and replaces the older Packaging and Packaging Waste Directive with something far more prescriptive. Unlike a directive, a regulation applies directly across all EU member states without needing separate national transposition, which is part of why it's landing on retailers so quickly.
For online retailers specifically, PPWR is one of the more operationally disruptive pieces of the EU's circular economy agenda, because it reaches directly into your packing station, not just your compliance folder.
The empty space limit for e-commerce packaging
This is the provision generating the most attention among online sellers. PPWR sets limits on the amount of empty space allowed in packaging used for e-commerce and other deliveries, with guidance pointing toward roughly 50% as the ceiling for unused volume in a parcel. In practice, that means the "big box, lots of air pillows" approach Marcus's 3PL was using becomes a compliance problem, not just a cost inefficiency. If you've ever received a single lipstick in a box that could hold a pair of boots, you've seen exactly the packaging pattern this rule targets.
Recyclability and "design for recycling"
Packaging placed on the EU market will need to meet recyclability criteria, assessed against design-for-recycling standards that the Commission is developing per packaging category. Multi-material packaging — think plastic-coated cardboard mailers, or boxes with non-removable plastic windows — is exactly the kind of format that tends to fail these criteria, because mixed materials are harder to sort and reprocess at scale.
Minimum recycled content
For certain packaging types, particularly plastic packaging, PPWR introduces minimum recycled-content requirements that increase over set periods. This mostly affects the manufacturers producing your boxes, mailers, and void fill — but if you buy custom-branded packaging, you'll need your supplier to confirm compliance, not just assume it.
Harmonised labelling
PPWR introduces a standardised labelling system so consumers and sorting facilities can identify what a piece of packaging is made of and how to dispose of it correctly. Expect labelling requirements to phase in gradually as the Commission finalizes the harmonised format through implementing acts.
Extended producer responsibility and eco-modulation
Under PPWR, extended producer responsibility (EPR) schemes get more sophisticated. Fees that producers and, in many national schemes, distance sellers pay into EPR systems will increasingly be "eco-modulated" — meaning packaging that's harder to recycle or contains less recycled content costs more to put on the market than packaging that meets the new design standards. This turns packaging choice into a direct cost lever, not just a sustainability preference.
PPWR requirements at a glance
| Requirement | What it means for you | Applies to |
|---|---|---|
| Empty space limit | Roughly 50% ceiling on unused parcel volume | E-commerce and other delivery packaging |
| Recyclability criteria | Packaging must meet design-for-recycling standards by category | All packaging placed on the EU market |
| Minimum recycled content | Increasing recycled-material thresholds, mainly for plastics | Packaging manufacturers, pass-through to brands |
| Harmonised labelling | Standardised material and disposal labelling | Consumer-facing packaging |
| EPR eco-modulation | Fees vary based on recyclability and recycled content | Producers and, per national scheme, distance sellers |
| Certain single-use plastics | Phased restrictions on specific single-use plastic formats | From 2030 onward |
Timeline: what applies when
PPWR applies from 12 August 2026 as a baseline, but not every provision lands on that exact date — several requirements, including some labelling and recycled-content thresholds, phase in through implementing and delegated acts over the following years. Restrictions on certain single-use plastic packaging formats are scheduled for 2030. Treat 12 August 2026 as the date the regulation starts biting, not the date every obligation is fully in force.
Auditing your own packaging before August 2026
Before you touch box specs, get a clear picture of what you're actually shipping today. Pull your last 90 days of orders and, for a representative sample, note:
- Parcel dimensions versus product dimensions (this exposes void space fast)
- Materials used: cardboard grade, plastic mailer type, tape, void fill
- Whether any packaging carries printed sustainability claims that would need substantiation
- Which suppliers manufacture your packaging, and whether they've mentioned PPWR proactively
If you're also reviewing broader EU obligations at the same time, our complete EU compliance checklist is a useful companion piece — packaging is one line item among many, and it's easy to lose track of it inside a bigger compliance project.
A practical packaging checklist for PrestaShop merchants
- [ ] Audit current parcel sizes against actual product dimensions for your top 20 SKUs by volume
- [ ] Ask your box and mailer supplier directly what their PPWR recyclability and recycled-content position is
- [ ] Introduce a second, smaller box size if your 3PL currently ships everything in one standard carton
- [ ] Replace non-recyclable void fill (loose plastic air pillows) with recyclable alternatives where feasible
- [ ] Review printed packaging claims for anything that needs substantiation
- [ ] Flag EPR fee structures with your compliance provider so eco-modulation doesn't surprise your margins
Where merchants get this wrong
The most common mistake is assuming this is a 3PL or warehouse problem to solve later. It's a product and packaging design decision that touches purchasing, fulfilment, and finance simultaneously — the earlier you involve all three, the less disruptive the transition. The second mistake is optimizing only for the empty-space rule while ignoring recyclability and recycled content, which are separate requirements with separate enforcement timelines. Right-sizing your boxes solves one problem, not all three.
If you haven't already, this is also a good moment to review our article on the EU sustainability rules affecting online retail more broadly, since packaging sits inside a wider regulatory shift rather than standing alone.
Start with the box audit above. It's a half-day exercise for most stores and it tells you, concretely, how close you are to compliant — or to exposed.
Frequently asked questions
What exactly counts as "empty space" under PPWR?
It refers to the unused volume inside a parcel once the product and any necessary protective packaging are accounted for. Oversized boxes padded mainly with air are the clearest example of what the limit targets.
Does PPWR apply to packaging I buy from outside the EU?
Yes. What matters is that the packaging is placed on the EU market as part of a product sold to EU customers, not where it was manufactured or printed.
Is my 3PL responsible for PPWR compliance instead of me?
Responsibility typically sits with the entity placing the product on the market, which is usually you as the retailer or brand owner, even if a third-party logistics provider handles the physical packing. Contractually clarify this with your 3PL rather than assuming it's covered.
Will PPWR increase my packaging costs?
Likely in the near term, as suppliers adjust materials and you may need multiple box sizes. Over time, eco-modulated EPR fees are designed to reward compliant packaging, which can offset some of the initial cost increase.
Do the single-use plastic restrictions affect e-commerce mailers?
Certain single-use plastic formats face phased restrictions starting in 2030, and standard plastic mailers are worth reviewing against that timeline now if you rely on them heavily.
Where can I find the official regulation text?
PPWR — Regulation (EU) 2025/40 — is published on EUR-Lex, the EU's official legal database, along with the European Commission's environment pages, which track implementing and delegated acts as they're adopted.
Related reading
- EU Sustainability Rules That Will Impact Online Retail
- Why Every Merchant Should Start Preparing for Circular Economy Laws
- Complete EU Compliance Checklist for Online Stores
- Upcoming EU eCommerce Laws Every Merchant Should Prepare for in 2027
- Future Payment Trends in Europe
