As of August 12, 2026, the new EU Packaging Regulation (PPWR) applies directly in all member states—with no exceptions based on company size. However, the most frequently cited rule does not yet apply: The 50% empty space limit for shipping packaging will not take effect until January 1, 2030. What has actually been in effect since the effective date, what’s coming in 2028 and 2030—and how retailers can make the most of the transition period.
At a Glance
- Regulation (EU) 2025/40 (PPWR) has been directly applicable in all EU member states since August 12, 2026 —it replaces the Packaging Directive 94/62/EC (Art. 70, 71 PPWR).
- The 50% empty space rule does not yet apply: It will take effect only as of January 1, 2030 —or later, if the EU’s calculation method is delayed (Art. 24(1) PPWR).
- As of the effective date, PFAS limits apply to food-contact packaging (Art. 5(5) PPWR)—relevant for anyone who packages or ships food.
- Registration (LUCID) and participation in the system under the German Packaging Act remain in effect as before —for EU-wide shipments, the obligations of the destination countries also apply.
- Harmonized labeling will take effect no earlier than August 12, 2028; recyclability, recycled content requirements, and format prohibitions will take effect on January 1, 2030.
What actually applies as of August 12, 2026?
First, the basics: The PPWR is an EU regulation, not a directive—it applies directly in every member state, without the need for national implementing legislation and without exceptions based on company size. The previous Packaging Directive 94/62/EC was repealed as of the effective date (with transitional provisions for certain provisions). Specifically, as of August 12, 2026, the general obligations of economic operators take effect: Packaging manufacturers and importers must demonstrate the conformity and provide technical documentation for their packaging—retailers should request this documentation from their packaging suppliers in the future. One material-related rule is immediately noticeable: Packaging that comes into contact with food may no longer be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) in amounts exceeding the limits set by the regulation. Anyone who ships food or packages it themselves should now obtain written confirmation of PFAS compliance from their suppliers.
How much empty space is allowed in shipping packaging—and when does this rule take effect?
A maximum of 50%—but not until January 1, 2030. Article 24(1) of the PPWR requires economic operators who fill outer packaging, transport packaging, or e-commerce packaging to a void space ratio of no more than 50%—effective as of January 1, 2030, or three years after the entry into force of the relevant implementing acts, whichever is later. The European Commission must not specify the calculation method until February 12, 2028. Anyone who currently reads that the quota applies “immediately” is reading false information—the text of the regulation explicitly states the date. In terms of substance, however, the rule is clear: Filling material counts as empty space. Article 24(3) explicitly lists paper, air cushions, bubble wrap, foam, wood wool, and polystyrene chips—so the requirement can only be met by using appropriately sized cartons, not by adding more padding. A first, more lenient phase takes effect earlier: By February 12, 2028, fillers of sales packaging must reduce empty space to the minimum necessary for the packaging’s function (Art. 24, Para. 4).
Does the PPWR also apply to small online shops?
Yes. The regulation does not establish a de minimis threshold based on company size—it also applies to a one-person shop shipping ten packages per week. Exemptions for micro-enterprises are limited to specific, detailed requirements, not the underlying principle. The difference lies in the timeline: Because the stringent design requirements (empty space, recyclability, recycled materials) do not take effect until 2030, smaller shippers in particular now have the opportunity to transition their packaging procurement without time pressure—rather than rushing to comply in 2029.
What has changed compared to the Packaging Act?
For German retailers, for now: nothing that already exists is being eliminated. The Packaging Act (VerpackG), including registration in the LUCID registry and participation in recycling systems, remains in effect unchanged—the PPWR does not replace it, but rather establishes uniform EU-wide product and design requirements on top of it. What’s new is the nature of the rules: a directive that each member state implemented differently is being replaced by a directly applicable regulation with measurable requirements. For retailers who ship to multiple EU countries, this simplifies matters in the long run—a single set of rules instead of 27 variations. In the short term, this means having to pay close attention to both: National obligations (registration, licensing) remain in place, while the new EU requirements are being phased in; a German law adapting to the VerpackG is still pending.
Who is considered a “manufacturer”—and what does that mean in the context of EU distance selling?
The PPWR explicitly defines the term “producer” as independent of the sales channel—“including through distance sales contracts” (Art. 3 No. 15 PPWR). Any retailer who fills shipping packaging and makes it available for the first time bears extended producer responsibility for that packaging—not the cardboard supplier. This also applies across borders: Anyone who delivers directly to end customers in other EU countries must fulfill the manufacturer’s obligations in the respective destination country, i.e., be registered there or participate in the local systems—if necessary, through an authorized representative. Those who are already licensed for every country of delivery are structurally prepared; those who are registered only in Germany but ship throughout the EU should review this now.
What obligations will take effect in 2028 and 2030?
The PPWR is deliberately structured in stages—the most important milestones for mail-order companies:
| Date | Requirement |
|---|---|
| Effective August 12, 2026 | The PPWR takes effect immediately; PFAS limit values for food-contact packaging (Art. 5, para. 5); heavy metal limit value of 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium (Art. 5, para. 4); Conformity and documentation obligations for economic operators; Directive 94/62/EC repealed (Art. 70, 71). |
| by February 12, 2027 | Member States shall determine the penalties for infringements; in the case of infringements of Articles 24–29 (including empty packaging and reuse), these must include fines (Art. 68). |
| by February 12, 2028 | Minimization of void space in sales packaging (Art. 24(4)); the European Commission shall establish the calculation method for the void space ratio (Art. 24(2)). |
| Effective August 12, 2028 | Harmonized labeling with pictograms indicating material composition—at the earliest; the deadline will be postponed if the implementing acts are adopted later (Art. 12). |
| Effective February 12, 2029 | Ban on polystyrene and other plastic filler chips used to protect goods during transport: They will be added to the list of prohibited items under the EU Single-Use Plastics Directive (Art. 67(5) in conjunction with Art. 71). Also new on the list: shrink wrap for luggage at airports and train stations, as well as plastic rings used to bundle multiple items. |
| Effective January 1, 2030 | 50% void space limit for packaging used for repackaging, transport, and e-commerce (Art. 24(1), possibly later depending on the implementing act); a general obligation to minimize weight and volume, including a ban on double walls, false bottoms, and unnecessary layers (Art. 10); minimum recyclability requirements; recycled content in plastic packaging; bans on certain single-use formats. |
| Thereafter | Further phases (including 2035 and 2038) with stricter recycling and design requirements. |
For planning purposes, this means: Don’t rush into anything—but keep procurement cycles in mind. Anyone purchasing new packaging now should already be considering recyclability and appropriate size ranges, so that a second redesign won’t be necessary in 2030.
What should retailers do now?
The shipping peak in November and December is the wrong time for process changes—so now, with clear priority:
- Review food packaging (immediately): Obtain written confirmation from suppliers that all food-contact packaging complies with PFAS regulations—these limits are already in effect.
- Check EU shipping (immediately): Verify registrations and system memberships in all destination countries—manufacturer liability for distance selling applies on a per-destination-country basis.
- Prepare the cardboard box lineup (medium term): Measure the empty space in common product-box combinations and add any missing intermediate sizes. Legally required only starting in 2030—but smaller packages already save on packing material and shipping costs today.
- Switch to new packing materials (by 2029): Anyone using polystyrene or plastic chips as protective packaging should plan to switch to paper, honeycomb, or molded cushioning—this packaging material may no longer be placed on the market as of February 12, 2029.
- Do not rush to order labeling: The harmonized EU pictograms have not yet been finalized—wait to print new labels until the implementing acts have been adopted.
- Involve suppliers: Request proof of compliance and PPWR-compliant, recyclable alternatives.
Calculating shipping costs benefits directly from using the right box sizes: less volume, less packing material, and often a lower shipping rate. The “Shipping & Delivery” guide shows you how to manage shipping methods and costs in the XONIC Shop System; for information on how to correctly communicate shipping costs to customers, take a look at our article “Postage vs. Shipping Costs.”
Note: This article does not constitute legal advice (as of the editorial deadline). Binding information regarding packaging compliance for your specific product range is provided by specialized law firms and the Chambers of Commerce and Industry.
Frequently Asked Questions About the EU Packaging Regulation
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Stephan Dunger
Stephan Dunger is one of the brains behind the XONIC store system. He has been developing the platform together with the team since 2012 - from the database to the interfaces to the checkout.
A passionate programmer, technical mind and consultant at the same time: with his in-depth knowledge of store systems and e-commerce, Stephan combines the depth of a developer with an eye for the big picture. Together with the XONIC team, he shapes the technical direction, consistently thinks about functions from the retailer's perspective and advises on customized solutions.
The result is software with a face: customers don't get an anonymous provider, but a direct line to the people who develop XONIC. Pragmatic, fast and at eye level.
