PPWR for e-commerce – declarations, documentation and shipping packaging

PPWR for e-commerce – what does it mean for an online shop?

An online shop should view the PPWR not in terms of a single box, but as the entire packaging system used in sales. A product may have its own sales packaging, several items may be combined in grouped packaging, and the completed order may be sent to the customer in an additional shipping box.

Each of these elements may have a different function, a different role in the supply chain and a different set of requirements. Therefore, merely stating that “we use cardboard boxes” is not sufficient to determine the company’s obligations.

In practice, an e-commerce business should be able to answer at least several questions: what types of packaging it uses, who is their manufacturer within the meaning of the PPWR, who holds the technical documentation, whether the appropriate EU declaration of conformity exists, which supplier a given packaging variant comes from, and for which orders it is used.

What is e-commerce packaging under the PPWR?

The PPWR defines e-commerce packaging as transport packaging used to deliver products to an end user in the context of online sales or other forms of distance selling. The definition is set out in Article 3(1), point 8 of the Regulation.

A typical example is the box in which an online shop sends an order to a consumer. However, another shipping format may also serve this function if it is used to deliver a product purchased at a distance to an end user.

The function of the specific packaging is therefore important. The same type of box may be used in different logistics processes, so its classification should not be determined solely on the basis of the material or the trade name assigned by the supplier.

Sales, grouped, transport and e-commerce packaging – they are not the same

The PPWR distinguishes several levels of packaging. For an online shop, this has practical significance because some obligations are assigned specifically to a given category.

Older terminology often uses the terms primary, secondary and tertiary packaging. The PPWR primarily uses the categories of sales, grouped and transport packaging. It is advisable to use one consistent terminology in the company’s data system, as the scope of subsequent requirements may depend on the classification.

Manufacturer and producer are two different roles under the PPWR

One of the most important distinctions for e-commerce is the difference between a ‘manufacturer’ and a ‘producer’. Under the PPWR, these are not synonyms.

The manufacturer is primarily responsible for ensuring that packaging complies with the relevant sustainability and labelling requirements. This role is associated, among other things, with the conformity assessment procedure, technical documentation and the EU declaration of conformity.

‘Producer’, on the other hand, is a term used primarily in the context of extended producer responsibility. In its guidance of June 2026, the European Commission explicitly emphasised that the manufacturer and producer may be different economic operators.

This distinction is particularly important for cross-border sales. A company may have one specific role from the perspective of product compliance, while also having EPR-related producer obligations in the country to which sales are directed.

Who is responsible for the conformity of a shipping carton: the store or the supplier?

It cannot automatically be assumed that an online store becomes the manufacturer of every carton simply because it packs an order into it. It is necessary to analyse who manufactures the packaging, who commissions its design, who decides on the specification and under whose name or trade mark the packaging is placed on the market.

The Commission guidelines of 2026 indicate that, for transport packaging, the manufacturer is usually the undertaking manufacturing such packaging. However, where the packaging is designed or manufactured under the user’s name or trade mark, the situation may differ.

For example, purchasing a standard unbranded box from the manufacturer’s catalogue may lead to a different assessment than ordering a bespoke box designed specifically for the shop and bearing its brand.

PPWR also provides for a specific rule for microenterprises that commission packaging under their own name or trade mark, where the packaging supplier is established in the same Member State. Therefore, the role should not be determined on the basis of a single simplified model for all companies.

Does an online shop need a PPWR declaration of conformity for shipping packaging?

Packaging subject to PPWR requirements is subject to a conformity assessment system, technical documentation and an EU declaration of conformity, but the key issue is to determine who is the manufacturer of the given type of packaging.

Under Article 15 of the PPWR, before placing packaging on the market, the manufacturer carries out or has carried out the appropriate conformity assessment procedure and draws up technical documentation. Article 39 subsequently provides for the drawing up of an EU declaration of conformity after conformity has been demonstrated.

If a shop purchases ready-made packaging from an entity that is its manufacturer within the meaning of the PPWR, it should first obtain the relevant information and documents enabling it to confirm the status and conformity of that packaging.

If, on the other hand, the shop is the manufacturer within the meaning of the rules, it is responsible for the conformity assessment process and the declaration. A document received from a printer or cardboard manufacturer does not automatically transfer that responsibility.

It is also worth distinguishing a declaration of conformity from an arbitrary file called a “PPWR certificate”. The formal document provided for by the Regulation is the EU declaration of conformity, the structure of which is set out in Annex VIII.

PPWR technical documentation for shipping packaging – what should it cover?

A declaration of conformity should not exist without the evidence on the basis of which conformity has been demonstrated. Annex VII to the PPWR describes the structure of the conformity assessment procedure and technical documentation.

In the case of e-commerce packaging, the documentation should make it possible to determine unambiguously which type of packaging was assessed, what it is made of, its construction, which requirements apply and which standards, calculations, tests or other evidence the assessment is based on.

The more formats of shipping packaging a company uses, the more important it becomes to manage types and versions. A folder simply named “boxes” does not ensure the traceability of documentation.

What documents should you request from a supplier of boxes, envelopes and other packaging?

Article 16 of the PPWR requires suppliers of packaging or packaging materials to provide manufacturers with the information and documentation needed to demonstrate compliance.

In practice, for shipping packaging, it is worth obtaining in particular unambiguous product identification, an up-to-date technical specification, material composition data, construction information, relevant test results, references to the standards or specifications used, and information on the document version.

It is also useful to agree with the supplier on a mechanism for notification of changes. A change in the type of paper, grammage, adhesive, coating, plastic or construction may require a review of the previous assessment.

However, you should not automatically require every supplier to provide an identical “PPWR certificate package”. The scope of evidence should follow from the specific packaging and the requirements applicable to it.

50% empty space limit in e-commerce packaging – when does it apply?

Article 24 of the PPWR provides for a maximum empty space ratio of 50% for grouped packaging, transport packaging and e-commerce packaging filled by economic operators.

However, the date is very important. The provision does not mean that, from 12 August 2026, every parcel sent by a shop must already comply with the 50% limit.

The requirement is to apply from 1 January 2030 or three years after the entry into force of the implementing acts adopted pursuant to Article 24(2), whichever date is later.

This also has practical implications for how the result is documented. The Regulation provides for the adoption of a methodology for calculating the empty space ratio, so an undertaking should distinguish between preparing its processes now and declaring compliance according to a methodology whose final manner of application depends on the relevant implementing acts.

Does parcel filler reduce empty space under the PPWR?

No. For the purposes of Article 24, space occupied by filling materials is treated as empty space.

The provision lists, among other things, paper cuttings, air cushions, bubble wrap, foam and sponge fillers, wood wool and certain polystyrene fillers. Simply placing a greater amount of protective material in an oversized carton therefore does not solve the issue of the future limit.

From the perspective of an online shop, this means that optimisation should start with selecting the appropriate packaging format for the contents, rather than only with how the empty space is filled.

Minimising e-commerce packaging is more than the 50% limit

The minimisation requirement and the empty space limit are related, but they are not the same obligation.

Article 10 of the PPWR concerns minimising the weight and volume of packaging, taking account of the packaging’s functions. The essential requirement under Article 10(1) is linked to 1 January 2030.

At the same time, from 12 August 2026, Article 10(2), concerning packaging with features intended solely to increase the perceived volume of the product, such as certain double walls, false bottoms or unnecessary layers, is relevant.

For e-commerce, practical preparation for minimisation may involve analysing the number of carton formats used, matching dimensions to typical shopping baskets, assessing packaging weight and identifying cases where one small product is regularly placed in a much larger box.

The detailed method for demonstrating compliance with Article 10 should be described separately, as minimisation will have its own set of evidence and parameters in the technical documentation.

The recyclability of shipping packaging is also subject to the PPWR

The PPWR establishes a requirement that packaging placed on the market must be recyclable, but the detailed criteria, grades and thresholds are introduced in stages.

For this reason, the assessment of a carton should not be reduced to the statement that ‘cardboard is recyclable’. The outcome may be affected by the design, combination of materials, coatings, adhesives, labels, laminates and other elements of the specific packaging.

As further requirements enter into application, the technical documentation will have to reflect the current criteria. For companies with hundreds of packaging variants, this means managing changes and versions, rather than collecting documents on a one-off basis.

Labelling of e-commerce packaging – check the dates, not just the article number

Packaging for e-commerce is also of particular importance in the provisions on future harmonised labelling.

Article 12 provides for phased arrangements and makes the dates conditional also on the relevant implementing acts. Therefore, a company preparing a shipping carton design should not assume that all future labelling elements must already be present on the packaging today.

A good approach is to maintain a separate register of requirements together with their dates of application. This enables the design team to distinguish the legal situation currently in force from requirements that need to be taken into account during the next revision of the packaging design.

PPWR and cross-border sales – EPR is a separate area of compliance

A shop selling to other EU Member States should analyse not only the packaging declaration of conformity, but also its role as a producer for the purposes of extended producer responsibility.

The definition of producer in the PPWR takes account of distance sales. In its 2026 guidance, the Commission explained that, in online sales, offering a product directly to the end user in a given Member State may constitute making the product available on that market for the purpose of determining the producer’s role.

However, this should not be confused with the EU declaration of conformity. These are two separate streams of obligations:

• packaging compliance and declaration – primarily linked to the role of the manufacturer;
• EPR, registration and financing of waste management – linked to the role of the producer in the relevant market.

A company selling in multiple countries should therefore carry out an analysis market by market, rather than assuming that one legal status automatically applies across all its operations.

Fulfilment and 3PL do not automatically exempt an online shop from PPWR obligations

Outsourcing order packing to an external warehouse does not in itself answer the question of who is the manufacturer, producer or economic operator responsible for a specific obligation.

Under a fulfilment model, it is worth determining, among other things, who purchases the shipping packaging, who selects its specification, whether it is branded with the shop’s brand, who holds the supplier documentation and who monitors changes to the variant used.

If the logistics operator independently replaces one type of carton with another, the company should know that the change has occurred and which documents relate to the new variant. Without such a data flow, the technical documentation may describe packaging that has physically ceased to be used.

A change of carton, supplier or material may require an assessment update

PPWR documentation should correspond to the packaging version actually used. If a change to the design, material, properties or applied standard may affect compliance, its impact on the previous result must be assessed.

In e-commerce, changes are frequent: a company adds a new box size, changes supplier, replaces a plastic mailer with a paper one, reduces the grammage of cardboard, or opens a new fulfilment warehouse using a different range of packaging.

Each such change should be traceable. Otherwise, after several months, the company may hold correct documents that relate to an outdated product.

How do you build a register of shipping packaging for PPWR?

With a larger number of orders and packaging formats, clear identification of the packaging type is essential.

A well-structured register should make it possible to move from a specific packaging code to the supplier, material, specification version, source documents, applicable requirements, conformity assessment result and the relevant declaration.

A practical data relationship may look as follows:

supplier → packaging type → variant → material → source document → PPWR requirement → evidence → conformity assessment → declaration.

In e-commerce, it is also worth adding information on the channel and use, as the same product may be packed differently in a company’s own shop, on a marketplace, in B2B sales and through external fulfilment.

PPWR for e-commerce – practical implementation checklist

It is best to start not by issuing declarations, but by organising packaging data.

1. List all packaging formats used for order fulfilment.
2. Define the function of each packaging item: sales, grouped, transport or e-commerce packaging.
3. Assign a supplier and product code to each variant.
4. Determine who is the manufacturer of each packaging type within the meaning of the PPWR.
5. Separate the role of manufacturer from that of producer for EPR purposes.
6. Collect current specifications, material data, drawings and relevant reports.
7. Check whether the documents can be unambiguously assigned to the variant used.
8. Identify the PPWR requirements applicable now and those that will apply later.
9. Draw up technical documentation in accordance with Annex VII where you are responsible as the manufacturer.
10. Carry out or commission the appropriate conformity assessment.
11. After demonstrating conformity, draw up the EU declaration of conformity in accordance with Annex VIII.
12. Establish a procedure for reporting changes to the carton, material, supplier or design.
13. Prepare a system for subsequent monitoring of minimisation and the empty space ratio.
14. For cross-border sales, separately analyse producer and EPR obligations for the relevant countries.

PPWR for e-commerce – the key deadlines do not start on the same day

One of the greatest sources of error is presenting 12 August 2026 as the date for all PPWR requirements.

Therefore, a business should maintain an obligations calendar rather than apply one universal date to all documentation.

When is it worth automating PPWR documentation in e-commerce?

For a few packaging types, the register can be maintained manually. The problem starts when a shop uses many formats, several suppliers, multiple warehouses or a fulfilment system and regularly changes packaging.

The greatest value lies not in automatically generating a PDF itself, but in maintaining links between the packaging type, version, source documents, conformity assessment and declaration.

A PPWR management system can identify missing data, store evidence from suppliers, version packaging, assign documents to the correct types and prepare a declaration based on structured data.

For e-commerce, an additional benefit is the ability to distinguish product packaging from shipping packaging and retain information on which variant is used in a particular channel or warehouse.

The most common e-commerce mistakes when preparing for PPWR

• treating a shipping box as a logistics element not subject to PPWR;
• assuming that the shop is always the manufacturer of every packaging type used;
• confusing the manufacturer with the producer responsible for EPR;
• having a declaration without being able to link it to a specific packaging variant;
• storing documents without version control;
• regarding filler as a way to reduce void space within the meaning of Article 24;
• assuming that the 50% limit applies from 12 August 2026;
• having no information on packaging changes made by the fulfilment operator;
• confusing the declaration of conformity with EPR obligations;
• treating a “PPWR certificate” as a substitute for technical documentation and conformity assessment.

PPWR for e-commerce – from shipping box to declaration of conformity

For an online shop, PPWR is not merely a regulation concerning the material from which a box is made. It requires combining packaging classification, the correct role of the business, supplier documents, technical documentation, conformity assessment and – where the company is responsible as the manufacturer – the EU declaration of conformity.

Packaging for e-commerce is a clearly defined category in PPWR. For this category, the later requirements concerning the void space ratio will be particularly important, as well as phased requirements on minimisation, recyclability and labelling.

The safest starting point is therefore to create a register of the packaging actually used, assign suppliers and documents to it, and determine who is responsible for each type of packaging. Only on this basis can a reliable conformity declaration process be built.

FAQ – PPWR for e-commerce and shipping packaging

Sources

Legal basis: Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex

European Commission guidelines: Commission Notice C/2026/3084 – Guidelines on Regulation (EU) 2025/40

The article refers in particular to:

• Article 3 – definitions of packaging, manufacturer and producer,
• Article 10 – packaging minimisation,
• Article 12 – packaging labelling,
• Article 15 – obligations of manufacturers,
• Article 16 – obligations of suppliers,
• Article 17 – authorised representative of the manufacturer,
• Article 18 – obligations of importers,
• Article 21 – cases in which manufacturer obligations apply to importers and distributors,
• Article 24 – empty space ratio,
• Article 38 – conformity assessment procedure,
• Article 39 – EU declaration of conformity,
• Articles 44–45 – obligations relating to the producer and extended producer responsibility,
• Annex VII – conformity assessment procedure and technical documentation,
• Annex VIII – structure of the EU declaration of conformity.