PPWR 2026 and EPR: EU Packaging Rules for Online Stores

From 12 August 2026, the EU’s new Packaging and Packaging Waste Regulation, or PPWR, applies across the European Union. It covers boxes, bags, film, food packaging, shipping cartons and other materials used to get products to customers.

For an online store, this comes down to three tasks: identify which countries you ship to, calculate the weight of packaging sent to each country and collect the paperwork from your packaging suppliers.

Two Questions: Who Is Responsible for the Box, and Who Pays to Recycle It?

PPWR separates responsibility into two areas.

The first is the packaging itself. There are requirements for its composition, recyclability and documentation.

The second is the waste left after a sale. This is where EPR, or Extended Producer Responsibility, comes in. Essentially, businesses contribute to the cost of collecting and recycling packaging in the country where it reaches the customer.

For example, a company based in Spain ships a ceramic mug to a customer in Germany. The mug goes into a branded box, then into a shipping carton. Because it is sold directly to a German customer, the shipment falls under Germany’s EPR system. Sales to France bring a separate French system into the picture.

The rule of thumb is simple: each country you sell to requires a separate check of its EPR rules. PPWR requires registration in each country where a company first supplies packaging or packaged goods to a local customer. The registration portal, reporting process and fees depend on the country.

Which Numbers Matter to a Small Store?

Fewer Than 10 Employees and Up to €2 Million

A microenterprise is a business with no more than nine employees and annual turnover or a balance sheet total of up to €2 million.

This status is particularly relevant to packaging documentation.

Take a Spanish candle brand:

• Five employees.
• Annual turnover of €700,000.
• Branded boxes ordered from a Spanish packaging manufacturer.

This brand qualifies as a microenterprise. If a supplier in the same EU country makes the packaging under the brand’s name, PPWR allows that supplier to be treated as the party responsible for the packaging’s technical documentation.

For the store owner, the next step is straightforward: ask the box manufacturer for the documents.

Less Than 10 Tonnes of Packaging a Year

The second important figure is 10 tonnes of packaging per calendar year in a single country.

Below this volume, PPWR provides for a simplified set of data in the annual report. An EU country may set a lower threshold for a particular year. Here is what those volumes look like for a typical online store. If the box, paper, bag and other packaging used for one order weigh an average of 250 grams:

• 3,000 orders = 750 kg of packaging.
• 20,000 orders = 5 tonnes.
• 40,000 orders = 10 tonnes.

Calculate the figures separately for each country.

Suppose a store ships the following amounts over a year:

• Germany: 3 tonnes of packaging.
• France: 1.5 tonnes.
• Italy: 700 kg.

That means three separate EPR markets, each with its own packaging volume.

What to Request from Your Packaging Supplier

Packaging requires an EU Declaration of Conformity.

This is a standard document in which the manufacturer identifies a specific type of packaging and confirms that it meets PPWR requirements. Alongside the declaration, there is technical documentation containing information about the packaging itself.

Write to your supplier and ask for:

• The EU Declaration of Conformity.
• The name or code identifying the specific packaging type.
• Information about its materials and composition.
• Technical documentation under PPWR.
• Contact details for the company responsible for the packaging.

For single-use packaging, the manufacturer keeps the documents for five years after the packaging is placed on the market. For reusable packaging, the period is 10 years.

For example, if you buy a standard mailing box from a large supplier, start by asking for the PPWR documents for that specific product code. This is simpler than investigating the chemical composition of the cardboard, glue and ink yourself.

Selling Food? Check PFAS

From 12 August 2026, PFAS limits apply to packaging that comes into contact with food. These substances can be found in grease-resistant coatings on paper and cardboard, including pizza boxes, fast-food wrappers, baking paper and other food packaging.

PPWR sets three thresholds:

• 25 ppb for an individual PFAS measured through targeted analysis.
• 250 ppb for the sum of PFAS measured through targeted analysis.
• 50 ppm for total PFAS content, including polymeric PFAS.

If you sell food, start with one request to your supplier:

“Please confirm that this packaging complies with the PFAS limits in Article 5(5) of PPWR and send the supporting documentation.”

Suppose a café delivers pizza in a cardboard box. The packaging to check is the box that touches the food.

A clothing store uses an ordinary mailing box. This particular food-contact requirement does not apply to that box.

Selling Across EU Borders? Check Whether You Need an EPR Representative

Under the current version of PPWR, a company based in one EU country that sells directly to end customers in another EU country must appoint an authorised EPR representative there.

An authorised representative is a local company or professional who handles your EPR obligations with that country’s authorities.

For example:

A Spanish online store ships products to customers in Germany. Germany becomes a separate EPR market, so the store needs to address the question of a German representative. If it starts selling to France, that adds a second market.

Meanwhile, the EU is considering amendment 2025/0395/COD. The European Commission has proposed suspending the requirement for EU-based companies to appoint such a representative until 1 January 2035. As of 2 September 2026, the legislative process is still ongoing. Before paying for a representative’s services, check the current status of procedure 2025/0395/COD and the rules in the relevant country. For businesses based outside the EU, the destination country may also require a local EPR representative.

From 2030, Box Size Will Matter

For online stores, PPWR introduces a maximum empty-space ratio of 50% in transport and e-commerce packaging. The earliest this rule can take effect is 1 January 2030. The exact timing also depends on the European Commission publishing the calculation methodology. Paper filler, air cushions, bubble wrap, foam and similar materials count as empty space.

For example:

A shipping carton has a volume of 10 litres. The product boxes inside occupy 6 litres.

• That leaves 4 litres of empty space.
• The empty-space ratio is 40%.
• The carton meets the future limit.

Now take the same 10-litre carton, with products occupying just 4 litres. The empty-space ratio is 60%.

That order will need a smaller carton. This is where PPWR starts to affect the everyday running of an online store: instead of using one oversized box for everything, you need to match the box size more closely to the order.

What to Do Now

For each country you sell to, record:

1. The number of orders per year.
2. The average packaging weight per order.
3. The total packaging weight per year.
4. The local EPR system.
5. The registration process.
6. Fees and reporting deadlines.
7. Suppliers of boxes, bags, jars and other packaging.
8. Whether you have the EU Declaration of Conformity.
9. Whether you have the technical documentation.
10. Whether your sales arrangements require an EPR representative.

A Spanish store selling only within Spain works with the Spanish EPR system and collects its packaging documents. If the same store starts shipping to Germany and France, it adds two countries to the spreadsheet. If it sends 800 kg of packaging a year to Germany, it checks the reporting rules for volumes below 10 tonnes. If it sells food, it asks its supplier for PFAS data.

By 2030, it checks shipping carton sizes and keeps empty space within 50%. In practical terms, PPWR for a small online store comes down to four things: countries served, kilograms of packaging, EPR and supplier documentation.

At Zaltsman Media, we develop online stores around the needs of your business and connect them to ERP and CRM systems. These systems can track the packaging used for each order, calculate its weight by material and destination country, and collect the data needed for reporting. If you want this tracking to run in the background as part of your store’s everyday operations, leaving you more time for the business and less for EU paperwork, we would be happy to discuss how to make that work for you.