PPWR explained: what the EU’s new packaging rules mean for eCommerce brands

PPWR is Regulation (EU) 2025/40, which entered into force in February 2025 and applied from 12 August 2026. It replaces the Packaging and Packaging Waste Directive that has governed EU packaging since 1994.

Its purpose is to reduce packaging waste across the EU, harmonise rules that had drifted apart between member states, and move packaging toward a circular model – less material, more recyclability, more reuse. It covers all packaging placed on the EU market, regardless of material or origin.

The shift from Directive to Regulation matters more than it sounds. A Directive sets an objective and each country writes its own law to achieve it, which is why packaging compliance has historically differed between Ireland, Germany, and France. A Regulation applies directly and identically everywhere. For brands selling across multiple EU markets, that is a genuine simplification – one rulebook instead of twenty-seven. For brands who had only ever dealt with Irish requirements, it means a broader set of obligations arriving at once.

Who it applies to. Anyone who places packaging on the EU market: manufacturers, importers, distributors, and – importantly for eCommerce – online sellers shipping to EU customers. There is no meaningful size threshold. A small Irish brand shipping a few hundred parcels a month into France is within scope.

When does PPWR come into force?

The regulation applies from 12 August 2026, but its individual requirements phase in over several years. This is the part worth getting straight, because planning against the wrong date leads either to unnecessary spending now or to a scramble later.

Two observations on that table.

First, the obligations landing this month are largely documentary. They require you to know what your packaging is made of, to be able to demonstrate it complies, and to have reduced it to what is functionally necessary. They do not require a new packaging range.

Second, the empty space cap is a 2030 requirement, not a 2026 one, and the figure is 50%. A number of summaries in circulation state a 40% cap taking effect in August 2026. That does not reflect the text of Article 24, which sets the ratio at 50% and ties it to 1 January 2030 or three years after the implementing acts. The Commission has until early 2028 to define how the ratio is even calculated – which is precisely why the binding cap sits at the end of the decade.

That distinction is worth holding onto, because it changes what a sensible response looks like. You have time to plan the packaging changes properly. You do not have time to postpone the paperwork.

What does PPWR mean for eCommerce businesses?

Six practical impacts, in roughly the order they will affect you.

1. Documentation becomes a legal requirement

From 12 August you need a Declaration of Conformity for each packaging type you place on the market, supported by Annex VII technical documentation describing the packaging, its materials, and the assessment demonstrating compliance.

This is the single biggest immediate change, and the one most often overlooked because it involves no visible change to the product. In practice, most of the underlying information sits with your packaging suppliers. The obligation to hold and produce it sits with you.

2. Packaging minimisation becomes enforceable

Packaging must be reduced to the minimum weight and volume necessary to protect the product, handle it safely, and transport it. There is no percentage attached to this at present – it is a principle, applied case by case, and it is enforceable from this month.

3. Marketing is no longer a valid justification for size

Under the previous framework, presentation and consumer expectation could justify larger packaging. Under PPWR they cannot. Perceived value, shelf presence, and unboxing experience are explicitly excluded as reasons for additional packaging. Protection, safety, and functional requirements remain valid.

For DTC brands that have invested in unboxing as part of the brand experience, this deserves a considered look. It does not prohibit attractive packaging. It removes aesthetics as a defence for excess packaging – a narrower point, but one that affects oversized rigid boxes with large void areas.

4. Void fill counts as empty space, not product

When the empty space ratio does apply, filler materials – bubble wrap, air cushions, paper shred, foam, wood wool – count toward empty space rather than toward the packaged product.

This is counterintuitive and commercially significant. It means the ratio cannot be met by adding more filler to an oversized box. The compliant response is a smaller box.

Worth noting even though the cap is years away, because it points the direction of travel and because right-sizing has an immediate commercial benefit independent of compliance. Smaller boxes reduce billable shipping weight, use less material, fit more units per pallet, and reduce damage in transit.

5. Design for recycling

All packaging must be designed for recycling from 12 August. Detailed technical criteria arrive later through delegated acts, with fuller definition expected by January 2028, but the obligation itself begins now.

6. Registration and producer responsibility

Registration thresholds fall to effectively zero for distance sellers. If you place packaging on the market in another member state, you are in scope regardless of volume, and may need an authorised representative in that country. In Ireland, producer responsibility obligations are generally met through Repak.

There are also new restrictions on PFAS in food-contact packaging, relevant to brands selling food, supplements, or cosmetics with food-contact components.

How should brands prepare? A sample timeline