The current EU Packaging Directive is set to be replaced by a new EU Packaging and Packaging Waste Regulation (PPWR). This new EU Packaging Regulation PPWR has come into force as Regulation (EU) 2025/40 in February 2025. Most of its provisions will not come into force until 18 months later, but it is already clear that the regulation will have significant consequences for online commerce within the EU. This is especially true for small businesses shipping to various European countries, but the regulation also impacts fulfillment service providers, marketplaces, and private households.
Sounds complicated? It is. But don’t worry. We explain the most important changes and show what needs to be considered, especially for e-commerce sellers in detail!
Key Aspects of the New EU Packaging Regulation PPWR for e-Commerce:
- What online sellers can expect
- Implementation of the EU Regulation in individual member states
- Implications for marketplaces, fulfillment service providers, and individuals
- Positive aspects of the regulation
- Criticisms from the e-commerce sector regarding the PPWR
- Optimal scenario for e-commerce sellers – Our proposal for adjustment
Background of the PPWR:
- What is the EU Packaging & Packaging Waste Regulation?
- Objectives and reasons for the regulation
- Milestones in EU legislation: What is the basis for the new Packaging Regulation and how did it come into force?
- What is the difference from the current EU Packaging Directive?
- When will the regulation come into force?
- FAQ: The most asked questions about the PPWR
Key aspects of the new EU Packaging Regulation PPWR for e-Commerce
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What online sellers can expect
Requirements for substances in packaging – Article 5
Packaging that enters the market must be produced to contain no or only a minimal amount of harmful substances. This applies not only to the packaging material itself, but also to all components it comprises, such as prints or writings.
It is important that these harmful substances are present in the smallest possible amount both in the packaging and in any waste generated during its disposal (such as recycled materials, ash, or other waste products). The aim is to minimize the environmental impact of these harmful substances at every stage of the packaging’s life cycle.
In online trade, shipping packaging is subject to stricter requirements and guidelines.
Recyclability of Packaging – Article 6
In line with the circular economy, all packaging put on the market must be recyclable. This goes hand in hand with Article 5 and minimizing hazardous substances.
In general, packaging is considered recyclable if it meets the following requirements:
a) It should be designed with recycling in mind. Characteristics include that the packaging components are separable for recycling and recyclable in their individual parts. In addition, established methods for collection, sorting, and recycling should be considered in the design of the packaging. It’s important that all parts of the packaging are recyclable with these methods.
b) When packaging must be disposed of, it can be collected separately and assigned to specific waste streams without impairing the recyclability of other waste streams.
So, components must be separable and ideally individually recyclable. If they must be disposed of, they should be assignable to existing waste streams without impairing the recycling of other waste.
The PPWR classifies packaging into recycling classes A, B, C and D. From 2030, only packaging up to level C (70% recyclable) may be placed on the market. Various criteria are taken into account for classification into a recycling class. These include, among others:
- What additives are used?
- Are labels or sleeves used? Are they easy to separate?
- What colors, adhesives and coatings are used?
- Can the packaging be easily emptied and dismantled?
Minimization of Packaging – Articles 10 and 24
According to the PPWR, future packaging should be as small and light as possible. This should already be standard for economic reasons, in order to limit material consumption. Packaging, for instance, that aims to increase the perceived size of the product with double walls, false bottoms, or unnecessary layers, should not be circulated.
For traders of electronic goods, regarding filler materials (according to Article 24), the following applies:
The void space ratio must not exceed 50%. Void space refers to the space in packaging filled with filler materials such as paper, air cushions, bubble wrap, foam, or similar. The void space ratio is the ratio between the total volume and the volume of the contained products.
Reusable Packaging – Article 11
Additionally, Article 11 describes what counts as reusable packaging: Namely, packaging that can be used multiple times, is integrated into a reuse system and can both comply with hygiene standards and be traced. This means that reusable packaging should be able to complete as many cycles as possible under normal conditions of use. The Commission will set guidelines for this in 2027.
Labeling Obligations – Article 12
Starting from August 2028, uniform EU-wide labeling with simple pictograms on the materials of packaging is planned. The Commission will define the details by August 2026.
In principle, packaging should provide information on how to dispose of it correctly. This will ensure correct recycling and reuse. Such labels already exist in many countries, for example in France with the Triman logo and in Italy. In the future, these symbols are to be standardized.
How do retailers or distributors ensure that the packaging they distribute complies with the respective regulations?
According to Article 16, suppliers of packaging or packaging materials must provide information and documents that certify conformity and provide information on ingredients, for example. You can therefore request these documents, check them and, if necessary, demand PPWR conformity.
Mandatory Representative and Extended Producer Responsibility – Article 45
The most important article for all traders who ship to multiple countries in Europe is Article 45.
“A manufacturer shall appoint, by written mandate, a designated representative for extended producer responsibility in each Member State where he first makes packaging available, except in the Member State where he is established.”
This means that every company or online seller that ships goods to a European country in which they do not have a branch, must have a representative for extended producer responsibility in each of these countries.
Why this paragraph is particularly critical will be explained later in this article (here).
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How the Implementation of the PPWR will look like in individual member states
Article 40 – The countries must designate appropriate authorities responsible for the implementation and enforcement of the obligations.
Article 45 – Manufacturer Register. The member states shall create a register that monitors compliance with the requirements resulting from the regulation. According to paragraph 2, manufacturers are obligated to register in this register. In Germany, this is already being implemented in the packaging register LUCID. In some other countries, there are already waste registers. In the future, online sellers will have to register in each EU member state.
In some countries, it is already mandatory to register!
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Implications for marketplaces, fulfillment service providers, and individuals
Fulfillment Service Providers:
The role of fulfillment service providers is described in Article 20. However, little to nothing has changed for them. They just need to ensure that the packaging they handle from their customers meets certain conditions during storage, packaging, addressing, and shipping, that do not impair the packaging. These conditions could change in the coming years as packaging materials may evolve.
Marketplaces:
According to Article 45 (4), marketplaces will be required to check whether the traders selling products, including packaging, are correctly registered in the respective countries. This means that online traders must inform the marketplaces of their registration numbers, and the marketplaces must request these during the registration process. Additionally, traders must assure the marketplaces with a self-certification, that they only offer packaging that complies with the respective environmental regulations and thus with EU directives.
Individuals:
The regulation also impacts private households and you as an individual. Especially for environmentally conscious consumers, the disposal of packaging will become easier and more feasible, as materials must be better labeled. Furthermore, there could be less packaging waste in private households overall, as packaging is to be minimized and fewer filler materials used.
Positive aspects of the regulation (EU) 2025/40
Circular Economy
Overall, the PPWR is a significant and important step towards sustainability and circular economy within the EU. The legal anchoring of these topics – particularly Extended Producer Responsibility (EPR) – is of great importance.
Deposit Systems
By January 1, 2029, deposit systems are to be established in every country. In Germany, this is already normal, but in many other countries, these structures do not yet exist.
Databases and increasing transparency
Another positive aspect is that public, harmonized databases on packaging and packaging waste volumes are to be set up in the EU member states. This could lead to greater transparency and comparability.
Criticisms from our point of view for the e-commerce sector
As previously described, we do not view the new EU Packaging Regulation exclusively positively:
In particular, Article 45 could create trade barriers. Appointing a representative in each member state poses a significant challenge, especially for small and medium-sized businesses. Implementation and taking care of this aspect needs a lot of time and money that many small companies can not afford. So they may have to stop shipping goods to various countries.
Our proposal for adjustment – What would be best for e-Commerce
In the best case, Article 45 (3) would be omitted.
Within the EU, reporting and registration should be uniformly regulated so that in the best-case scenario, one only has to join a single take-back system. Companies based outside the EU should then only have a single authorized representative for the entire EU.
Alternatively, exceptions for micro-businesses or smaller quantities should be included. Companies would then be required to register and appoint representatives in the respective countries depending on the quantities of sold packaging.
We have already published a press release on this: You can read it here.
Background on the EU Packaging Regulation PPWR
What is the EU Packaging & Packaging Waste Regulation?
The upcoming EU Packaging Regulation PPWR is designed to replace or expand the current directive, contributing to the harmonization of existing packaging laws.
Its primary goal is to counter the continuous increase in packaging waste. The main objective is to reduce packaging waste in the EU by at least 15% by 2040 compared to 2018.
The regulation focuses on improved recyclability of packaging, mandatory quotas for reusable packaging, and minimum recycled material content in packaging. Similar to the existing directive, the new regulation requires online retailers and other companies to take responsibility for the disposal and recycling of packaging waste, in line with extended producer responsibility.
Objectives and reasons for the new EU PPWR
When one thinks of packaging, they often directly imagine large piles of waste and garbage. And this is true – they are the first things to be disposed of and are usually just a means to an end. Yet this purpose is indispensable, as packaging protects products and enables their transport.
At the same time, the production of packaging is a significant economic sector in the EU. However, the varying concepts and regulations in the member states, especially in terms of labeling, recyclability, and reusability, create obstacles to the smooth functioning of the domestic market. These discrepancies create legal uncertainties, which in turn hinder investments in innovative and environmentally friendly packaging solutions.
Additionally, packaging represents a central environmental problem. It consumes large amounts of primary raw materials – 40% of the plastics and 50% of the paper used in the EU are for packaging. The increasing use of packaging has not only led to a rise in CO2 emissions in recent years but has also made recycling more difficult. Especially when packaging cannot be collected separately due to its design.
Between 2012 and 2020, the proportion of non-recyclable packaging has significantly increased, and many countries are struggling to meet the recycling targets set out in Article 6 of Directive 94/62/EC.
This situation emphasizes the urgent need for an EU-wide packaging regulation that not only strengthens the economy but also serves environmental protection.
Milestones in EU Legislation:
December 1994 – Directive 94/62/EC
Directive 94/62/EC sets out the EU’s rules for the management of packaging and packaging waste. It states that EU countries must adopt measures to minimize the amount of packaging waste and its environmental impacts. The goal of the directive is to harmonize national measures for the disposal of packaging waste and to improve environmental quality by reducing the impact of waste.
May 2018 – Amendment Directive (EU) 2018/852
This amendment complements and renews Directive 94/62/EC. It includes measures to prevent packaging waste and promote the reuse, recycling, and other forms of recovery of packaging waste. Here, the focus is placed on circular economy.
Where does the EU Packaging Regulation come from?
December 2020 – Based on conclusions of the Council, it was decided that by 2030 all packaging put on the market within the EU should be reusable or recyclable in an economically feasible manner.
February 2021 – With this background, a new action plan for the circular economy was decided, and a legislative proposal for it was demanded.
November 2022 – A proposal for a new regulation was made by the EU Parliament and the Council.
December 2023 – A legislative proposal from the European Council was published. This can be read in full here.
After final negotiations with the countries, the new Regulation (EU) 2025/40 has come into force from 2025 and will take effect 18 months later. Until then, the former directive and its amendments continue to apply.
What exactly is the difference to the current Packaging Directive?
The need for a packaging regulation as opposed to the previous packaging directive was already justified in the first draft of the new regulation 2022 by the European Commission:
“A regulation ensures that all 27 member states implement their obligations simultaneously and in the same way.”
A directive is binding for member states in terms of the goal but leaves the choice of form and means to the national authorities. A directive must first be transposed into national law, giving member states leeway in the exact design of the rules. This ultimately means that directives can be implemented differently in each country, as is currently the case with the packaging directive.
In contrast, a regulation is binding in all its parts and applies directly and equally in every EU member state. It does not need to be converted into national law, but has a direct effect. This ensures uniform rules throughout the EU.
This aligns the requirements for all market participants in the countries. It creates the necessary legal certainty, reduces distortions of competition within the EU, and sends signals to market participants outside the EU.
As disposal and recycling structures occur separately in each member state, the requirements for online retailers and sellers with international shipping to oversee everything remain high.
In our digital service, we continue to keep our customers informed about all EPR processes, or take over the Europe-wide EPR compliance management in our premium service.
When will the new EU Packaging Regulation come into force?
In 2024, the legislative text was officially adopted by the European Parliament and Council. The regulation was then published in the EU Official Journal on 22.01.2025 under the name Regulation (EU) 2025/40. It finally came into force 20 days later, on 11.02.2025. After a transitional period of 18 months, most provisions of the PPWR will take effect in August 2026. However, different deadlines are specified for certain provisions. For instance, the harmonization of recycling symbols for packaging in the EU will only come into force in August 2028.
We regularly inform about this in our newsletter and on our social media channels – and of course also about other relevant topics, such as the latest developments on textile EPR, country-specific updates (from e.g., Denmark, Sweden or Finland) or the battery regulation BATT2 and obligations in the EU.
If you have any other comments on the development or would like to discuss them, please feel free to send us a message. In case of questions or if you need support with your packaging EPR, our team of experts is always happy to assist!
Easily manage the PPWR across Europe with ecosistant
We offer a variety of services that allow you to prepare for the new packaging regulation today. Our Digital EPR-Consulting Service provides you with simple and personalized step-by-step instructions, helping you gain an overview of your EPR obligations for packaging and other waste streams across Europe, enabling you to comply on your own. Thanks to our practical subscription, we keep users constantly up-to-date on their countries, ensuring that all changes brought about by the PPWR will be incorporated into our guides. This is the simplest way to find appropriate take-back systems and Authorized Representatives for each country!
It gets even easier with our Premium EPR-Management Service. Here, you receive a personal key account manager, and we take over your EPR management across Europe for you. This way, you become compliant today and will remain so even after the new PPWR comes into effect.
FAQ: The most asked questions about the PPWR
The PPWR (Packaging & Packaging Waste Regulation) is the new EU packaging regulation that replaces the previous packaging directive. It introduces uniform rules for packaging across the EU, from production to disposal. Unlike the old directive, the regulation applies directly in all EU countries without having to be transposed into national law first. This means the same rules for everyone, but also stricter regulations for online retailers.
The PPWR came into force on February 11, 2025! After a transition period of 18 months, most of the provisions will apply from August 2026. However, some regulations have different deadlines. For example, uniform labeling with recycling symbols will not come into force until August 2028.
Virtually anyone who deals with packaging. Those particularly affected are:
- Online retailers and e-commerce companies (especially those involved in cross-border shipping)
- Manufacturers of packaging and packaged products (must create or commission technical documentation and declarations of conformity)
- Marketplaces (must verify their retailers’ registrations)
- Fulfillment service providers (must comply with certain storage conditions)
- Private individuals (benefit from better labeling and less packaging waste) weniger Verpackungsmüll)
The main goal is clear: 15% less packaging waste by 2040 (compared to 2018). To achieve this, the EU is focusing on several levers:
- Packaging should become more recyclable
- Harmful substances in packaging should be minimized
- Packaging should become smaller and lighter
- More reuse and recycled materials
- EU-wide harmonization of regulations
Yes, this is one of the most critical points of the PPWR. If you are an online retailer shipping to EU countries where you do not have your own branch, you need an authorized representative for extended producer responsibility in each of these countries. This can be a real challenge, especially for small businesses.
Your existing registrations in the various EU countries will remain valid. However, the PPWR will extend some of the requirements. You should check whether your current registrations comply with the new regulations and make any necessary adjustments.
The specific penalties are determined by the individual EU member states. As the regulation applies directly in all EU countries, potential fines are to be expected. You may face particularly high penalties for failure to register or for violations of the authorized representative obligation.
What does “recyclable” mean according to the PPWR?
The PPWR classifies packaging into recycling classes A to D. From 2030, only packaging up to class C (at least 70% recyclable) will be allowed on the market. Decisive factors include separable components, adhesives and inks used, and ease of allocation to existing waste streams.
No! The rule that packaging may have a maximum of 50% empty space applies specifically to outer packaging, transport packaging, and packaging for e-commerce. Empty space is the space filled with filling material such as air cushions or foam. In general, packaging should only be as large and heavy as is absolutely necessary for its function. A balance must therefore be found between product protection and environmental protection.
Starting in August 2028, there will be standardized pictograms for labeling throughout the EU to make disposal easier for consumers. You can use these to recognize PPWR-compliant packaging. In addition, the contact details of the packaging manufacturer must be found on the packaging, a QR code, or accompanying documents.
Packaging from non-EU countries must also comply with PPWR requirements if it is placed on the market in the EU. As an importer, you are responsible for ensuring that the packaging is PPWR-compliant and must keep appropriate records.
Yes: Micro-enterprises with fewer than 10 employees and an annual turnover ≤ €2 million OR a balance sheet total ≤ €2 million are not considered producers themselves under certain PPWR obligations – for example, they are not required to prepare technical documentation for packaging. Instead, these obligations are assumed by the EU-based supplier. There are also exemptions for micro-enterprises regarding reusable packaging and certain single-use packaging bans.
However, there is no exception for micro-enterprises regarding Extended Producer Responsibility (EPR). This means that they must still fulfill their producer obligations in every EU country they sell to, including appointing an authorised representative if they are not established in that country.
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