PPWR: what the EU packaging regulation changes for e-commerce businesses

The PPWR (Packaging and Packaging Waste Regulation) changes more for packaging than most of the French companies concerned realize, yet few have read it in detail. Unlike a directive, it applies directly in every Member State, with no transposing legislation. Here is what the regulation requires, by when, and exactly what it means for an e-commerce or logistics business.

Where the text comes from

Regulation (EU) 2025/40 of December 19, 2024 on packaging and packaging waste was adopted by the European Parliament and the Council, then published in the Official Journal of the European Union in early 2025. It entered into force on February 11, 2025 and replaces the former Directive 94/62/EC, in force since 1994.

Its scope is broad: it covers all packaging placed on the EU market, whatever the sector, with specific rules for transport, grouped and distance-sales packaging, which directly concern e-commerce.

The date that matters: August 12, 2026

The PPWR applies from August 12, 2026 in all Member States, directly, with no French decree or law needed to make it enforceable. This is the date to remember first.

From that date, several immediate obligations apply:

• an EU declaration of conformity must accompany every packaging placed on the market,
• the burden of proof for this conformity lies with the manufacturer, not with the enforcement authority,
• supporting documents must be kept for 5 years for single-use packaging, and 10 years for reusable packaging.

One point, however, needs checking before you finalize a product roadmap. Several specialist sources disagree on the date from which the general recyclable-by-design requirement becomes enforceable: some give August 12, 2026, others place it at January 1, 2030, when the lowest-performing recyclability classes are banned. Only the consolidated text on EUR-Lex, article by article, actually settles the question.

What specifically concerns e-commerce

Empty space capped at 50%

From 2030, empty space in grouped packaging, transport packaging and packaging intended for distance sales (that is, e-commerce) may not exceed 50% of the total packaging volume. A parcel oversized for its contents, a practice still common in e-commerce, then becomes non-compliant. This is a sizing obligation, independent of the reuse obligations.

Reuse targets for transport

Article 29 of the regulation sets reuse quotas by family of packaging used for transport between economic operators: pallets, pallet boxes, returnable crates, drums, pallet wrapping films and straps. According to available analyses, these quotas reach 40% in 2030, then 70% in 2040.

Before committing budget to this, one caveat is needed: the exact scope of these quotas for specifically “e-commerce” flows, as opposed to conventional B2B transport, is not confirmed consistently across the sources consulted, and the delegated acts meant to specify the reuse rate calculation methods have not all been adopted to date. The upward trajectory, however, is not in question: reusable transport packaging is becoming a compliance matter, not just an image choice. The calculation details that will apply to your business, on the other hand, remain to be clarified.

Exemptions already adopted

The European Commission has also decided to exclude certain films and straps used to secure palletized loads from an initial 100% reuse target that appeared in an earlier version of the text. This illustrates a useful point for an SME: the PPWR continues to be refined through delegated and implementing acts after its adoption. The final text is not fixed in every detail of its application.

What this means in practice for an e-commerce SME or mid-sized company

The most immediate point is not the obvious one. Documentation comes before the empty space ratio or transport reuse: the EU declaration of conformity and keeping supporting documents for 5 to 10 years become mandatory from August 2026, not in 2030. The rest follows later, at a slower pace.

The 50% maximum empty space rule only takes effect in 2030, but it requires adjusting packaging formats to the contents actually shipped: a logistics project as much as a regulatory one, and one that is hard to prepare in a rush. If your supply chain uses pallets, pallet boxes or returnable crates, the reuse trajectory (40% then 70%) should enter your discussions with service providers now, even if the calculation methods remain to be clarified. Finally, because the calculation methods and the harmonized labeling planned for 2028-2029 depend on texts that have not all been published, a twice-yearly check on their progress avoids unpleasant surprises.

Key dates

In June 2026, eight Member States reported implementation difficulties at the Environment Council, and the European Commission said it was working on publishing the necessary secondary legislation. This timeline therefore remains, in part, a moving one.

This article is for information only and does not replace legal advice. If in doubt about a date or threshold, refer to the consolidated text of Regulation (EU) 2025/40 on EUR-Lex and its forthcoming delegated acts.

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