PPWR for online shops — e-commerce obligations
If you run an online shop, PPWR affects you in two distinct ways: through the packaging of the products you sell, and through the shipping packaging (boxes, mailers, void fill) you add yourself. The same shop can be in several roles at once, and what you need to have ready depends on which.
Which role(s) you're in
The role is not a choice. It follows from what you do with the packaging:
- Producer (EPR). When you make packaging available on a country's market for the first time (including the transport / e-commerce packaging you use to ship parcels), you are a "producer" under extended producer responsibility: you register and pay contributions (Articles 44–45).
- Distributor. When you resell goods you neither made nor imported, you verify that the producer is registered and that the packaging carries the required markings and information.
- Manufacturer. If you place packaging on the market under your own name or brand (branded boxes, mailers) or modify it, you are considered the manufacturer and draw up the EU Declaration of Conformity for it (Articles 15 and 21).
- Importer. If you bring packaging or packaged goods in from outside the EU, see the importer obligations.
The most common case: a shop that buys plain boxes and ships its own products is a producer (EPR) on that transport packaging and a distributor on the sales packaging of the goods it resells. It becomes a manufacturer only for packaging it orders under its own brand or modifies.
Empty space and labelling: only 2028/2030
The two rules most often associated with e-commerce do not apply from 12 August 2026:
- Empty space of no more than 50% in grouped, transport and e-commerce packaging (Article 24) applies from 1 January 2030; the calculation methodology only arrives by 12 February 2028. Void fill (paper, air cushions, film) counts as empty space. Anyone shipping a product in its own sales packaging (no extra outer box) is exempt from the 50% rule.
- The sorting label on packaging (Article 12) is mandatory from 12 August 2028. Notably, e-commerce packaging is an exception here: it must carry the label, even though ordinary transport packaging does not.
What applies to an online shop from 12 August 2026
From the application date, an online shop genuinely faces:
- Substance restrictions (Article 5) on the packaging you place on the market: heavy metals ≤ 100 mg/kg and PFAS in food packaging;
- The EU Declaration of Conformity for packaging for which you are the manufacturer;
- Verification duties as importer and distributor (that the declaration and markings exist).
Empty space, minimisation and labelling are not 2026 obligations. The date-by-date breakdown is in What applies from 12 August 2026.
Selling into other EU member states
Extended producer responsibility is per country. If you ship to consumers in other member states (e.g. Slovenia, Germany), you need to be registered as a producer in each such country, and for distance sales into another member state the regulation also requires an authorised representative for extended producer responsibility there (Article 45). Exactly how the PPWR register and the existing Croatian scheme overlap depends on national implementation. Check before entering a new market.
If you are an online marketplace hosting third-party sellers (rather than a single-brand shop), you have additional duties: verifying that sellers are registered for EPR and have provided the required statement (Article 45).
For the full picture see the guide to Regulation (EU) 2025/40. We're preparing a free EU Declaration of Conformity template. Leave your email and we'll send it the moment it's ready.
This guide is informational, helps you prepare documentation, and is not legal advice. For an assessment of your online shop, consult a professional.