Why is the PPWR coming?

The European Union has a problem: The amount of packaging waste has been rising for years. In Germany alone, about 230 kilograms of packaging waste per person ends up in the trash each year —and the trend is on the rise, mainly due to the booming online retail sector.

The previous Packaging Directive from 1994 did little to change this situation, as it was implemented differently by each EU member state. The result was a patchwork of national regulations. The new Regulation (EU) 2025/40 —better known as the PPWR (Packaging and Packaging Waste Regulation)—replaces this directive with a uniform, directly applicable set of rules for all 27 member states.

The goals are clear:

Per capita packaging waste is to be reduced by 5% by 2030, by 10% by 2035, and by 15% by 2040 (compared to the reference year 2018).
All packaging should be recyclable by 2030.
The circular economy should become a reality—not just a political buzzword.

The regulation took effect on February 11, 2025. Following an 18-month transition period, most of the requirements will take effect on August 12, 2026. Additional provisions will be phased in gradually through 2040.

Important: Federal Environment Minister Carsten Schneider has lobbied the European Commission for a postponement until January 2027. It remains to be seen whether this will happen. Companies should nevertheless begin preparing now.

Who is affected? The division of roles between retailers and fulfillment providers

The PPWR defines various roles along the supply chain—each with its own responsibilities. For our customers, the distinction between retailers and fulfillment service providers is particularly important.

The PPWR does not apply only to shipments to D2C (B2C) customers. It also applies in full to B2B packaging, including transport, industrial, and commercial packaging. This is one of the biggest changes compared to the previous system.

Your Role as an Online Retailer: The Person Legally Responsible

As a retailer, you are considered the “distributor.” This means that you bear economic responsibility for the packaging in which your goods reach the end customer—regardless of whether you package the goods yourself or hire a fulfillment service provider.

Specifically, this means:

You must be registered in the LUCID packaging registry.
You must enter into a system participation agreement with a dual system.
You must report your packaging quantities accurately.
You must ensure that your packaging meets the new compliance requirements.

These obligations cannot be delegated —not even to your fulfillment service provider.

Our Role as a Fulfillment Service Provider: The Gatekeeper

As a fulfillment service provider, the PPWR explicitly holds us accountable as a business entity (Art. 3, para. 1, no. 12). We are not merely an executing body, but rather serve as a true gatekeeper:

We need to verify whether our customers are registered in the LUCID packaging registry and are complying with their system participation obligations.
If a customer is not registered, we are not permitted to ship goods to them. A statutory distribution ban applies.
We must provide our customers with the quantities of packaging used, broken down by material type, so that they can fulfill their reporting obligations.

This testing requirement has been in effect since July 2022 under the German Packaging Act and is being established and expanded throughout Europe by the PPWR.

What specific changes will take effect starting in August 2026?

1. The empty space ratio: No more air in the box

A key aspect of the PPWR concerns what is known as packaging minimization. Effective January 1, 2030, the following will apply: The empty space in shipping, transport, and e-commerce packaging may not exceed 50% of the total volume. Some industry sources even anticipate that the long-term goal will be 40%.

What counts as empty space: not just air, but also filler material such as air cushions, paper padding, or packing chips. A small product in an oversized box filled with padding material is the classic counterexample.

What this means in practice:

The days of “one standard box for everything” are over.
You need a range of cardboard box sizes that suits your products.
As a fulfillment service provider, we are already optimizing our packing processes to use the right box sizes for your products.

2. Recyclability: “Design for Recycling” Becomes Mandatory

Starting in 2030, all packaging must be verifiably recyclable. To this end, the PPWR is introducing a rating system ranging from A to E:

Starting in 2030, only packaging up to Class C (at least 70% recyclable) may be placed on the market.
Class E packaging (less than 70%) will be banned.
The threshold will continue to be raised through 2038.

Key factors include separable components, the adhesives and inks used, and how the packaging fits into existing waste streams. Even though the strict recycling requirements won’t take effect until 2030, preparations must begin now, because packaging design and supply chains cannot be changed overnight.

3. Bans on Certain Types of Packaging

Starting in 2030, the PPWR will ban certain types of single-use packaging, including:

Unnecessary outer packaging that serves only to make the product appear larger (double walls, false bottoms, unnecessary layers).
Single-use, single-serving packaging in the hospitality industry (mini shampoos, soaps, etc.).
Single-use plastic packaging for condiments and coffee creamer in the hospitality industry.
Small packages for fresh fruits and vegetables weighing less than 1.5 kg.

For typical online retail, the regulations regarding unnecessary outer packaging and oversized shipping boxes are particularly relevant.

4. Labeling Requirements: Standardized Symbols and QR Codes

Starting in August 2028 (or 24 months after the adoption of the relevant implementing acts), packaging throughout the EU must bear harmonized symbols that make it easier for consumers to dispose of it properly. In addition, digital information will be provided via QR codes, offering details on material composition and recyclability.

5. Substance Restrictions: PFAS Limits Effective August 2026

Starting August 12, 2026, new limit values for so-called PFAS (per- and polyfluoroalkyl substances) in food packaging will take effect. The maximum limit is 25 ppb per individual substance and 250 ppb in total. This is directly relevant to the mail-order food industry.

Reporting Requirements and Documentation: Who Is Required to Provide What?

The PPWR introduces new documentation requirements that call for close cooperation between retailers and fulfillment service providers.

What we, as a fulfillment provider, need from you:

Proof of LUCID registration – we cannot ship your order without a valid registration.
Proof of participation in a dual system.
Starting in August 2026: Declarations of conformity for your packaging, demonstrating that it meets the requirements of the PPWR.

What we provide:

A detailed breakdown of the packaging quantities by material type (cardboard, plastic, packing material, etc.) that we used to ship your goods.
You will need this data for your volume reporting to LUCID and the Dual System.

What happens if you don’t register?

The consequences are clear: Without a valid LUCID registration and participation in the system, we, as a fulfillment service provider, are not permitted to ship your goods. An immediate sales ban will take effect. In addition, fines of up to 200,000 euros per individual case may be imposed—and since the LUCID registry is publicly accessible, competitors can also identify violations and issue cease-and-desist letters.

Checklist: 5 Steps You Should Take Now as an Online Retailer

1. Check and Update Your LUCID Registration. Are you already registered? Are all brand names, packaging types, and contact details up to date? If not, please update your information immediately at lucid.verpackungsregister.org. Registration is free and takes about 15–20 minutes.

2. Analyze Your Packaging Portfolio: Compile an inventory of all the packaging you use or place on the market. What materials, sizes, and quantities do you use? Where is there room for improvement in terms of empty space and material usage?

3. Understanding Compliance Requirements Starting in August 2026, you must be able to provide technical documentation and an EU Declaration of Conformity for each type of packaging. Check with your packaging suppliers to see if their products meet the new requirements.

4. Verify System Participation: Make sure your contract with a dual system is up to date and that the quantities you’ve reported match the actual figures. The same quantities must also be on file with LUCID.

5. Develop a Packaging Strategy for 2030. The recyclability and void space requirements taking effect in 2030 require advance planning. Start now by optimizing your box sizes, switching to recyclable materials, and exploring reusable options.

Conclusion: Navigating the Regulatory Jungle Together

The EU Packaging Regulation is complex—there’s no question about that. But it also offers opportunities: Businesses that take action now can reduce shipping costs by optimizing package sizes, build customer loyalty through sustainable packaging solutions, and minimize legal risks by ensuring compliance.

As your fulfillment partner , we take our role as gatekeeper seriously. We are already working to adapt our processes to the new requirements—from optimized box sizes and transparent quantity reports to verifying your registrations.

Do you have any questions about the PPWR and what it means for your business? Please contact us. Together, we’ll ensure that your shipping operations continue to run smoothly even after August 12, 2026.

About Subke GmbH: As a fulfillment service provider based in Hamburg, we support online retailers with warehousing, packaging, and shipping—both domestically and internationally. Learn more at Subke Fulfillment.

Updates:

Update from August 13, 2026: Shortly before the deadline, the European Commission clarifies who qualifies as a “producer”

The PPWR has been in effect since August 12, 2026—the postponement to January 2027 that some in the industry had hoped for did not materialize. Shortly before the deadline, however, the European Commission updated and significantly expanded its FAQ document on the PPWR.

To provide some context: The Commission has published two practical guides on the regulation—detailed guidelines and a separate collection of frequently asked questions (FAQs). Neither is legally binding; the text of Regulation (EU) 2025/40 remains authoritative.

However, the FAQ shows how the Commission wants the regulation to be interpreted—and is used as a reference by authorities and associations accordingly.

In the August update, a provision was reinterpreted that is of significant importance for online retail and for working with us as a fulfillment service provider: the distinction between the producer and the manufacturer of packaging.

What Has Changed

To date, many online retailers have, as a precaution, classified themselves as producers—with all the associated obligations. The updated FAQ now distinguishes between the roles more clearly:

A producer is someone who develops packaging under their own name or brand.
A manufacturer is any entity that first places packaging or packaged products on the market in an EU member state.

In practice, this means that for standard, plain shipping boxes, the box manufacturer is generally considered the producer— not you, the retailer.

Simply unfolding a cardboard box or affixing a shipping label to it does not make you a manufacturer.

The situation is different for custom-made or custom-designed packaging:

Anyone who has custom cardboard packaging designed or printed with their own brand remains the manufacturer and bears the corresponding responsibilities.

Important: No general relief

Niklas Stanislawski, head of the EHI’s Logistics + Packaging Research Division, characterizes the new framework as a “more precise allocation of responsibility”—and explicitly not as a general reduction in the burden on retailers. The obligations do not disappear; they are simply shifted, in part, to other points in the supply chain.

What You, as a Retailer, Should Do Now

You do not need to dismantle PPWR processes that have already been set up. Instead, it makes sense to perform a targeted adjustment:

Avoid duplicate procedures: Check which types of packaging actually require you to fulfill your own registration, volume reporting, EPR, or compliance obligations—and for which the packaging supplier is responsible.
Sorting packaging: Divide your portfolio into standard, generic packaging (manufacturer = supplier) and custom-designed or custom-made packaging (manufacturer = you).
Revise your supplier contracts: Robust purchasing terms, packaging specifications, and documentation requirements for your packaging suppliers are becoming increasingly important. Ensure that your suppliers provide contractual assurances of compliance.
Assess the economic impact: Those who have previously assumed EPR responsibility for standard transport packaging can save costs as a result of this clarification.

Outlook: Moratorium or Transitional Arrangement?

The German E-Commerce and Mail-Order Trade Association (BEVH) has called for a moratorium to ensure legal certainty and planning security. Stanislawski considers a “transitional or penalty provision” to be a viable alternative, one that would grant companies a reasonable transition period to adapt. Neither option has been decided yet—the obligations remain unchanged.

Sources: EHI interview on the PPWR, stores+shops, August 12, 2026; European Commission guidelines and FAQs on Regulation (EU) 2025/40.

Our assessment for Subke customers: This clarification does not change our role as gatekeeper. Your LUCID registration and participation in the system remain prerequisites for us to be able to ship on your behalf. What has changed is the question of who is responsible for demonstrating the compliance of individual packaging items. Please contact us—we’ll review your packaging portfolio together and clarify which documentation is your responsibility and which is your suppliers’.

This article is intended for general informational purposes only and does not constitute legal advice. The text of Regulation (EU) 2025/40 is authoritative. As of March 2026.

Updated on 13.08.26
Author: Jens Schmidt

About the author: Over the last few years, Mr Schmidt has become increasingly involved in logistics at Subke GmbH. Previously, he implemented online shops, marketing and SEO strategies himself. He knows the requirements and challenges that an online business brings for retailers.