PPWR: what shippers need to know from August 2026
· by Editorial team
The PPWR (Regulation (EU) 2025/40) has applied directly in all EU member states since 12 August 2026. For you as a shipper, this means specifically: your packaging will in future require a declaration of conformity from the manufacturer, must be recyclable and may contain no more than 50 % empty space from 2030. Many obligations take effect in stages, but you should set the course now.
Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) has been applicable. Unlike a directive, it does not first have to be transposed into national law: it applies directly. If you ship goods, this affects you immediately. This guide explains factually what needs to be done now and which requirements only come into force later.
What is the PPWR and since when has it applied?
The PPWR is the new EU packaging regulation. It entered into force on 11 February 2025 and, after an 18-month transition period, has been applicable since 12 August 2026. Its aim: less packaging waste, greater circularity and uniform rules in the single market.
The regulation is relevant for you as a shipper because it does not only address packaging manufacturers, but the entire chain, right down to the box that arrives at your customers. Fines are regulated nationally (in Germany via the German Packaging Implementation Act (VerpackDG), up to 200,000 euros); according to the current status, active enforcement begins on 12 February 2027. The substantive obligations themselves, however, already exist now.
Which obligations apply immediately, and which from 2030?
Immediately upon applicability: for every item of packaging, manufacturers must hold a declaration of conformity together with technical documentation (Annex VIII, Art. 39–40). As a shipper, your first practical step is to request these documents from your packaging supplier. Substance limits are also already applicable, such as 100 mg/kg for heavy metals and restrictions on PFAS. The labelling obligation under Art. 12 is phased in: in 2026, initially the manufacturer identification and QR code; from 12 August 2028, information on material composition; from 2030, on substances of very high concern.
A second block takes effect from 1 January 2030:
- Packaging minimisation (Art. 10, Annex IV): Weight and volume must be limited to the functionally necessary minimum. Unnecessary outer packaging, double walls or false bottoms will then be impermissible, though necessary product protection remains a recognised criterion.
- Recyclability (Art. 6): From 2030, all packaging must be recyclable (at least grade C or 70 %); from 2038, only grades A/B.
- Recycled content (Art. 7): Minimum quotas apply to plastic packaging, for other plastic packaging around 35 % from 2030 and 65 % from 2040.
- Reuse (Art. 29): For transport packaging, 40 % from 2030 and 70 % from 2040, with exceptions including cardboard; within a company's own logistics, 100 % from 2030 (with exceptions such as pallet wrapping and strapping).
The bans in Annex V from 2030 primarily affect single-use plastic outer packaging in retail and catering, not conventional B2B shipping cushioning.
What does the 50 % empty space rule mean in practice?
The point that surprises most shippers is in Art. 24: from 1 January 2030, a maximum empty space ratio of 50 % applies to grouped, transport and e-commerce packaging. Empty space is the difference between the packaging volume and the volume of the products or sales packaging contained.
Crucially, and often misunderstood: void fill counts as empty space. Paper cushions, air cushions, bubble wrap, foam or packing chips do fill the box, but they do not reduce the ratio. Changing the cushioning material alone therefore does not solve the problem.
The effective first lever is therefore the precisely fitting box. With made-to-measure corrugated boxes, for example via a variable box height, you reduce the empty volume directly at the root. The cushioning comes afterwards: it should take up as little volume as possible and primarily hold the product in place. An official calculation method for the empty space ratio is expected by 12 February 2028.
Which packaging meets the requirements?
To be honest, first of all: there is no blanket "PPWR-compliant" stamp for an individual product; compliance always depends on the specific package. There are, however, approaches that contribute to meeting the requirements and support you in doing so:
- Precisely fitting boxes first: The biggest lever against empty space is the box itself. In addition to standard shipping boxes, FUCHSPACK also offers made-to-measure boxes, cut precisely to your product and, on request, produced on demand in the required height. This shrinks the empty volume before cushioning even comes into play.
- Fill the remaining void: What then remains is filled by air cushion systems with air instead of bulky stock; solutions that hold the product tightly in place, such as airbag and UNIQBAG packaging, require hardly any additional volume.
- Recyclability: Mono-material solutions have the advantage. Paper cushions stay in the paper recycling stream; single-grade PE air cushions can be recovered separately as a plastic mono-material.
- Product protection with a sense of proportion: Foam cushions make sense where product protection strictly requires them, and protection is explicitly a permissible criterion under Annex IV.
In mail order in particular, it is worth looking at coordinated e-commerce packaging solutions that consider empty space, returns protection and material use together.
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How do you get started? A short checklist
- Request documentation: Ask your suppliers for the declarations of conformity and technical documents for your current packaging.
- Take stock: Record your common packages: box sizes, fill levels, cushioning materials.
- Measure empty space: Roughly check how much air is in your standard boxes and identify the biggest "air shippers".
- Optimise the box before the cushioning: Start with the box size first, then the cushioning volume.
- Evaluate materials: Sort by recyclability and mono-material, and keep the necessary product protection in mind.
Frequently asked questions about the PPWR
Since exactly when has the PPWR applied?
It entered into force on 11 February 2025 and has been directly applicable since 12 August 2026.
Do I have to change all my packaging immediately?
No. Some obligations (documentation, substance limits, initial labelling) already apply; many others, such as the empty space ratio, recyclability and minimisation, take effect from 1 January 2030. You should use the transition period to switch step by step.
Does a different cushioning material solve the 50 % empty space rule?
No. Void fill itself counts as empty space. The most effective lever is the precisely fitting box; after that, the cushioning should take up as little volume as possible.
What happens in the event of non-compliance?
Sanctions are regulated nationally, in Germany via the VerpackDG with fines of up to 200,000 euros. According to the current status, active enforcement begins on 12 February 2027.
Transparency note: This article was created with AI assistance and reviewed by our editorial team. The article image is AI-generated.