The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, is now applicable. Since 12 August 2026, businesses placing packaging on the EU market must work within the new EU-wide packaging framework.
For online sellers, Amazon businesses, Shopify brands, manufacturers, importers and distributors, this raises practical questions: Do I need a PPWR Declaration of Conformity? Does PPWR replace EPR? What documentation do I actually need? Which requirements apply now, and which only start later?
This guide walks through the requirements that matter for online sellers right now, with practical next steps.
PPWR in 2026: What Has Changed?
Regulation (EU) 2025/40 entered into force on 11 February 2025. Its general date of application is 12 August 2026. So PPWR is not a regulation that suddenly appeared in August 2026 — businesses have had a preparation period, and different obligations have different application dates.
| Date | What happens |
|---|---|
| 11 Feb 2025 | PPWR enters into force |
| 12 Aug 2026 | PPWR generally becomes applicable; new PFAS restrictions for certain food-contact packaging apply |
| 12 Feb 2028 | Commission deadline for the methodology to calculate e-commerce/transport/grouped packaging empty-space ratio |
| 2030 | Major minimisation, recyclability and empty-space requirements become applicable per the specific provisions |
| 2030 onward | Additional recycled-content and reuse requirements phase in |
The exact date for an individual requirement should always be checked against the relevant PPWR Article, since transition periods differ.
Why Was the PPWR Introduced?
According to Eurostat, the EU generated 79.7 million tonnes of packaging waste in 2023 — 177.8 kg per inhabitant, up 21.2 kg per person since 2013 despite an 8.7 kg drop compared with 2022.
| Material | Share of packaging waste (2023) |
|---|---|
| Paper and cardboard | 40.4% |
| Plastic | 19.8% |
| Glass | 18.8% |
| Wood | 15.8% |
| Metal | 4.9% |
| Other | 0.2% |
Plastic packaging alone accounted for 35.3 kg per person in 2023, of which 14.8 kg was recycled. These figures help explain why the EU is moving beyond collection and recycling targets toward requirements covering the entire packaging lifecycle.
Who Needs to Pay Attention to PPWR?
PPWR can affect manufacturers, importers, distributors, brand owners, online and marketplace sellers, e-commerce businesses, fulfilment businesses, and any company placing packaged products on the EU market. However, the obligations are not identical for all of them.
The first question should not be “I sell on Amazon, what PPWR document do I need?” The better question is: “What is my legal role in relation to the packaging and the packaged product?” That distinction determines which obligations actually apply.
Does Every Online Seller Need a PPWR Declaration of Conformity?
No. This is one of the most important points for online sellers to understand.
Under Article 38, conformity assessment concerns packaging requirements laid down in Articles 5–12. Article 39 states that the EU Declaration of Conformity confirms that the relevant requirements have been demonstrated to be fulfilled, following the model structure in Annex VIII and the elements in Annex VII. The manufacturer assumes responsibility for the packaging’s conformity by drawing up the declaration.
An online seller should not automatically create a Declaration of Conformity for every product simply because it sells into the EU. First determine your role and the specific obligations that apply to it — see our walkthrough on who actually needs an EU Declaration of Conformity.
What Is an EU Declaration of Conformity Under PPWR?
The EU Declaration of Conformity is a formal document stating that the applicable PPWR requirements have been demonstrated to be fulfilled. Under Article 39, it must:
- follow the model structure in Annex VIII;
- contain the elements specified in the applicable conformity-assessment module in Annex VII;
- be continuously updated;
- be drawn up in, or translated into, the language(s) required by the relevant Member State.
This makes it different from a general marketing certificate or a supplier statement — it is part of the manufacturer’s formal conformity documentation.
Do You Need 27 PPWR Declarations for 27 EU Countries?
Not necessarily. Article 39 does not simply require every business to prepare 27 separate declarations — it requires the declaration to be drawn up in, or translated into, the language(s) required by the Member State where the packaging is placed or made available on the market. For businesses selling throughout the EU, managing multilingual documentation can nevertheless become a significant administrative task.
What Information Belongs in the Technical Documentation?
The Declaration of Conformity is supported by technical documentation under Annex VII. Depending on the applicable requirements and conformity-assessment procedure, this can include: a general description of the packaging, intended use, design, drawings, materials and components, relevant technical specifications, applicable standards, calculations, assessments, test reports and supporting evidence. Collecting this packaging data is itself an important part of PPWR compliance.
How Long Should PPWR Documentation Be Kept?
For single-use packaging, the EU Declaration of Conformity and technical documentation must be kept available for 5 years from the date the packaging was placed on the market. For reusable packaging, the period is 10 years.
PPWR vs EPR: What Is the Difference?
This is one of the most common sources of confusion for e-commerce sellers. PPWR and EPR are connected, but they are not the same thing.
| PPWR | EPR |
|---|---|
| EU packaging requirements | Producer responsibility |
| Packaging design & minimisation | Waste management |
| Recyclability | Registration (e.g. LUCID in Germany) |
| Conformity assessment | Reporting & financing waste management |
| EU Declaration of Conformity | National producer registers |
The simple rule: EPR registration does not automatically prove PPWR compliance, and a PPWR Declaration of Conformity does not automatically fulfil national EPR obligations. Businesses may need to manage both — for Germany specifically, see our page on the authorised representative and EPR requirements.
What Does PPWR Mean for E-Commerce Packaging?
Article 24 introduces a maximum 50% empty-space ratio for certain grouped, transport and e-commerce packaging. This is not a general 2026 requirement — it applies from 1 January 2030, or three years after the relevant implementing acts enter into force, whichever is later. The Commission must establish the calculation methodology by 12 February 2028.
Empty space is the difference between the packaging’s total volume and the volume of the products inside it. Materials such as paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool and polystyrene chips count as empty space for the calculation. This does not mean bubble wrap is prohibited — it means filling an oversized box with protective material will not necessarily reduce the calculated ratio.
Businesses can already start reviewing packaging: Is the box significantly larger than the product? How much protective material is required? Are standard box sizes creating unnecessary empty space? Are dimensions driven by logistics rather than the product?
What About Packaging Recyclability?
The European Commission describes PPWR as aiming to ensure that packaging on the EU market becomes recyclable in an economically viable way by 2030. Businesses should begin reviewing materials, material combinations, coatings, adhesives, labels, closures, components, recycled content, weight and volume — a design that works well logistically today may need modification as later requirements apply.
What About PFAS?
PFAS restrictions already apply, from 12 August 2026. Article 5(5) restricts certain PFAS concentrations in food-contact packaging: 25 ppb for any single targeted PFAS substance, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric PFAS under the conditions set out in the Regulation. For businesses using food-contact packaging, this is an area that should not be postponed — a supplier self-declaration is generally not sufficient; an accredited lab’s Certificate of Analysis is. We walk through this in detail in a real PFAS case with glass and plastic packaging.
PPWR Compliance Checklist for Online Sellers
- Map your packaging — primary, sales, grouped, transport, e-commerce packaging, labels, closures, protective materials.
- Identify your legal role — manufacturer, importer, distributor, producer, or another economic operator.
- Identify the packaging manufacturer — if it isn’t you, ask your supplier what documentation exists.
- Record packaging data — material, weight, dimensions, supplier, function, intended use for each component.
- Review EPR obligations — check registration and reporting in each relevant market.
- Determine whether a Declaration of Conformity is required — don’t assume every seller needs one.
- Check the language requirements for each market where the declaration is needed.
- Review future requirements — recyclability, minimisation, empty space, recycled content, reuse.
How to Create a PPWR Declaration of Conformity
Filling it in for the first time? Our step-by-step guide through all 8 points of Annex VIII explains every field with examples.
If your role and the applicable requirements mean an EU Declaration of Conformity is required, it must follow Article 39 and the applicable requirements of Annex VII and Annex VIII. For businesses managing multiple products and multiple EU markets, preparing these manually becomes repetitive and hard to keep consistent.
Our PPWR Declaration of Conformity Generator is built for exactly this: it currently supports all 27 EU Member States in 27 interface languages, with each declaration printed in the destination country’s official language, structured on the Annex VIII framework.
Important: a document generator does not replace the manufacturer’s responsibility to establish actual conformity or maintain the underlying technical documentation and evidence.
PPWR Compliance Is Becoming a Data Exercise
For many online sellers, the hard part of compliance won’t be understanding one regulation — it will be maintaining accurate information across many products: what each component is made from, how much it weighs, who supplied it, where the product is sold, which documentation exists, which EPR systems and conformity requirements apply, and which languages are required. For 10 SKUs this is manageable by hand; for 500 or 1,000+ SKUs, structured data becomes essential. Packaging compliance is turning from a one-time registration into an ongoing data-management process — the same shift we cover for individual products in our PPWR label generator and sorting-pictogram tools.
What Happens Next?
The application of PPWR on 12 August 2026 is not the final step — it is the start of a longer implementation process. The European Commission has continued updating its PPWR FAQ and guidance to address practical questions, and further implementing and delegated acts will add technical detail. Packaging changes, suppliers change, products change, markets change, and requirements develop — your compliance documentation needs to stay current.
Frequently Asked Questions About PPWR
What is PPWR?
PPWR is the Packaging and Packaging Waste Regulation (EU) 2025/40. It establishes an EU-wide regulatory framework for packaging and packaging waste, including requirements relating to packaging design, minimisation, recyclability, substances, labelling, reuse and producer responsibility.
When did PPWR start to apply?
The general application date is 12 August 2026. The Regulation itself entered into force on 11 February 2025.
Does PPWR replace EPR?
No. PPWR and EPR address different aspects of packaging compliance. Businesses may have both PPWR obligations and national EPR obligations.
Does every Amazon seller need a PPWR Declaration of Conformity?
No. The need for an EU Declaration of Conformity depends on the applicable PPWR conformity requirements and the business's role in the supply chain.
What is the PPWR Declaration of Conformity?
It is the EU declaration stating that the applicable requirements under Articles 5-12 have been demonstrated to be fulfilled. Article 39 specifies its structure, content and language requirements.
Do I need 27 declarations for 27 EU countries?
Not automatically. Article 39 requires the declaration to be drawn up in or translated into the language or languages required by the relevant Member State.
Is the 50% empty-space rule already applicable?
No. Article 24 sets the maximum empty-space ratio for certain e-commerce, transport and grouped packaging from 2030, or three years after the relevant implementing acts enter into force, whichever is later.
Does bubble wrap count as empty space?
For the Article 24 calculation, yes. The Regulation expressly includes bubble wrap and several other filling materials in the definition of empty space.
Does this mean bubble wrap is banned?
No. The provision concerns the calculation of empty space; it does not constitute a general ban on bubble wrap.
How long must PPWR documentation be kept?
The relevant EU Declaration of Conformity and technical documentation must generally be kept for 5 years for single-use packaging and 10 years for reusable packaging.
This article provides general information about Regulation (EU) 2025/40 and is not a substitute for legal advice or a product-specific conformity assessment. Businesses should assess their obligations based on their role, products, packaging and the Member States in which they operate.
Official Sources
- Regulation (EU) 2025/40 — EUR-Lex
- European Commission — Packaging and Packaging Waste
- European Commission — PPWR FAQ
- Eurostat — Packaging waste statistics