The PPWR rule that will change most e-commerce packing benches is not aimed at box manufacturers. The 50 % empty-space limit for e-commerce packaging applies to the company that fills the box, which for most online sales means the brand or its fulfilment partner. A supplier can make a well-sized mailer, but if it is packed with a small product and a handful of paper fill, the filler carries the compliance risk.
This guide explains the provisions of Regulation (EU) 2025/40 that bear on PPWR e-commerce packaging, who they apply to, and how to prepare a mailer range for them. It is not legal advice: obligations depend on your role and should be confirmed with the competent authority or your compliance scheme. For the boxes themselves, see our main page on custom printed mailer boxes.
Which PPWR rules apply to e-commerce packaging?
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied generally since 12 August 2026. For e-commerce packaging, the main provisions are the empty-space limit (Article 24), packaging minimisation (Article 10), harmonised labelling (Article 12), recyclability grades (Article 6) and extended producer responsibility. Most of the design obligations take effect from 2030.
| Provision | What it requires | Timing | Usually falls on |
|---|---|---|---|
| Article 24 - empty space | Empty space ratio of no more than 50 % in grouped, transport and e-commerce packaging | 1 Jan 2030 or 3 years after the methodology act, whichever is later | The economic operator that fills the packaging |
| Article 10 - minimisation | Weight and volume reduced to the minimum necessary for function | From 2030 | The packaging manufacturer (which can be the brand owner) |
| Article 12 - labelling | Harmonised material sorting label, including on e-commerce packaging | 12 Aug 2028 or 24 months after an implementing act, whichever is later (implementing act not yet confirmed) | The manufacturer / those placing packaging on the market |
| Article 6 - recyclability | Packaging must be recyclable to performance grade A, B or C | From 1 Jan 2030 | The manufacturer |
| Article 29 - reuse targets | 40 % reusable transport packaging by 2030 | 2030 | Not applicable to cardboard boxes |
| EPR | Registration and fees in each Member State where packaging is made available | Already applies under national schemes | The producer in each country |
The general PPWR picture, including PFAS limits, plastic recycled content and the foodservice reuse rules, is covered in our PPWR explainer for packaging buyers.
Who is responsible for the 50 % empty space limit?
The empty-space obligation applies to the economic operator that fills grouped, transport or e-commerce packaging. In practice that is the online seller packing its own orders, or the fulfilment or logistics provider packing on its behalf, depending on how the regulation and contracts allocate the filling role. The box manufacturer is not responsible for what is put in the box.
That matters for contracts. If a third-party fulfilment provider packs your orders, agree in writing who chooses box sizes per order, who records the data, and who carries the obligation once the rule applies.
How is the empty space ratio calculated?
The empty space ratio compares the volume of the e-commerce packaging with the volume of what it contains. Empty space is the difference between the two, and filling materials such as paper fill, air cushions, bubble wrap and foam chips count as empty space, not as product. The detailed calculation method is to be set by a Commission implementing act, so measurement rules (for example how irregular products are treated) are still pending.
An illustration, using internal box volume and the volume of the product in its own sales packaging:
| Item | Box A (current) | Box B (resized) |
|---|---|---|
| Internal box dimensions | 300 x 220 x 100 mm | 240 x 170 x 90 mm |
| Internal box volume | 6.60 litres | 3.67 litres |
| Product in sales packaging | 200 x 150 x 80 mm = 2.40 litres | 2.40 litres |
| Empty space | 4.20 litres | 1.27 litres |
| Empty space ratio | about 64 % | about 35 % |
Box A, typical of a "one size fits most" mailer, would exceed the limit even before fill is added. Box B passes; how a fitted insert is counted should be checked against the final methodology. The example is illustrative only; the official methodology may define volumes differently.
The regulation also contains specific provisions and exemptions, including how sales packaging that itself serves as the shipping packaging is treated. Check the text and the methodology act for how your products are classified rather than assuming one rule fits every order.
What does packaging minimisation mean for mailers?
From 2030, Article 10 requires packaging to be designed so that its weight and volume are reduced to the minimum necessary for its function, assessed against performance criteria set out in the regulation. The text specifically targets features whose purpose is to increase the perceived volume of a product, such as double walls, false bottoms and unnecessary layers, unless they serve a function.
For a mailer range this points to a few practical design decisions:
- Board grade should match the protection needed. Over-specified double wall for light goods is harder to defend than E flute matched to the load.
- Decorative elements that add material without function, such as a printed outer sleeve over a printed mailer, deserve a second look.
- Inserts that protect and locate a product are functional; layers of tissue, ribbon and loose fill used only for presentation are harder to justify.
- Technical documentation will need to show why the packaging is as it is, so keep test results and design rationale.
Under the PPWR, the "manufacturer" is whoever has packaging designed or manufactured under its own name or trademark. A brand that orders custom printed mailers bearing its brand may therefore carry manufacturer obligations for that packaging, including technical documentation and the EU declaration of conformity. How this applies to empty printed packaging is not settled in every case, so confirm your position with your compliance adviser.
Labelling, recyclability and reuse
Labelling. Article 12 introduces a harmonised material sorting label, and it explicitly covers e-commerce packaging. The application date is 12 August 2028 or 24 months after the implementing act, whichever is later. The implementing act had not been confirmed at the time of writing, so plan artwork space but avoid committing to a final label design yet.
Recyclability. From 1 January 2030, packaging must meet recyclability grade A, B or C, with grades also used to modulate EPR fees. Mono-material corrugated board with water-based inks starts from a strong position, although the grades themselves depend on design-for-recycling criteria due in 2028. Plastic film lamination, foil, plastic windows and foam inserts are the elements to review.
Reuse. Article 29 sets a 40 % reuse target for transport packaging by 2030, but cardboard boxes are exempt. A corrugated mailer is therefore not pushed into a reuse system by that target, although some Member States and retailers may encourage reusable shipping options separately.
EPR registration for online sellers in Germany and other Member States
EPR is the part of packaging law already in force for online sellers. Each Member State requires the producer of packaging made available there to register and pay fees, and non-established producers selling directly to end users must appoint an EPR authorised representative.
In Germany, the VerpackDG replaced the VerpackG from 12 August 2026. Online sellers shipping to German consumers must register in the LUCID register (operated by the ZSVR) and participate in a dual system for their shipping packaging before placing it on the market; registration cannot be delegated, and foreign sellers supplying end users directly need an authorised representative with a German establishment. Austria requires foreign distance sellers to appoint an Austrian authorised representative and license packaging through a collection system. Both countries are covered in packaging compliance in Germany and Austria.
A preparation plan for mailer ranges
The 2030 dates leave time, but box ranges, dies and fulfilment systems take time to change. A practical sequence:
- Measure current empty space on a sample of real orders, including fill, using your best estimate of the methodology.
- Identify order profiles that exceed 50 % and whether a smaller box, a different size step or an insert would fix them.
- Rebuild the size range around order data; see mailer box sizes and letterbox dimensions.
- Replace loose fill with fitted inserts where products move.
- Check whether fulfilment software can select the box size per order automatically.
- Review board grades and decoration against minimisation and recyclability.
- Collect material and weight data per box for EPR reporting and technical documentation.
- Keep design rationale and test results on file.
Right-sizing usually reduces postage and dimensional weight at the same time, so much of this work pays for itself before 2030. For the protection side of the trade-off, see mailer box vs shipping box vs poly mailer.
When you are ready to rework a range, send current box sizes, order profiles and target markets through the custom printed mailer boxes page. Ask for material composition and weight data per box as part of the quotation, so it can be delivered with the order and used in your EPR reporting.