If you pack and ship orders to consumers in the EU, the PPWR (Regulation (EU) 2025/40) has applied to your packaging since 12 August 2026. In practice, an online shop needs four things in order: producer registration in every country where it sells, supplier documents for each packaging item, packaging sized to the product, and a plan for the 2028 and 2030 dates. This checklist walks through each one.
Almost certainly, if you ship to consumers in the EU. The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies to all packaging placed on the EU market, including the mailing bags and boxes an online shop uses to send orders. It has applied since 12 August 2026, and as a regulation it is the same text in every Member State.
There was a lot of talk about a postponement before August. The application date did not move. What does change over time are individual requirements, which arrive in stages until 2030 and beyond. Our overview of the PPWR explains the whole regulation; this page is the practical version for e-commerce.
| # | Check | Who does it | When |
|---|---|---|---|
| 1 | Find out in which countries you are the "producer" | You | Now |
| 2 | Register with the producer register in each of those countries | You | Before you ship there |
| 3 | Check whether you need an authorised representative abroad | You | Now, and watch the Council proposal |
| 4 | Collect the Declaration of Conformity for each packaging item | Supplier → you | Now |
| 5 | Confirm substance limits (and PFAS for food packaging) | Supplier | Now |
| 6 | Size your packaging to the product | You | Now; 50% empty space limit from 2030 at the earliest |
| 7 | Prepare for harmonised sorting labels | You and supplier | From August 2028 at the earliest |
| 8 | Plan recycled content for plastic packaging | Supplier | From 2030 |
| 9 | Keep your records together | You | Ongoing |
For extended producer responsibility (EPR), the PPWR defines the producer by who first makes packaging available in a country, whatever the selling technique, including distance sales. If your shop is in one Member State and ships orders directly to consumers in another, you are normally the producer in the customer's country for the packaging you send there.
So the first step is a simple list: every country where you have end customers. For each one, note roughly how much packaging, by material, you ship there per year. You will need the same figures for registration and reporting.
Each Member State keeps a producer register, and the PPWR requires producers to register before they first make packaging available there. National systems you may already know continue: for example LUCID in Germany or the Registro de Productores de Producto in Spain. Marketplaces and online platforms are required to check producer registration before they let sellers use their services, so missing numbers can stop your listings.
Practical points:
Under the regulation as published, a producer selling directly to end users in another Member State has to appoint an authorised representative for EPR in each of those countries. For small shops that sell a few parcels a year into many countries, this is the most burdensome part of the rules.
EU institutions are working on relief. On 21 October 2026 the Council agreed its negotiating position: EU-established producers would not need an authorised representative in a country where they make available less than one tonne of packaging per calendar year, with a safeguard for producers who breach their obligations. This still has to be negotiated with the European Parliament and adopted. At the time of writing it is not law, so plan on the current rule and check again before you decide.
Under the PPWR, the packaging manufacturer has to make sure the packaging conforms, keep technical documentation and draw up an EU Declaration of Conformity. You do not write these yourself for a bag you buy, but you should hold them. For each item, ask for:
If you sell under your own brand on packaging, or change packaging in a way that affects compliance, you can take on the manufacturer's obligations yourself. Private-label mailing bags are the common case; discuss it with your supplier before you print.
The PPWR requires packaging weight and volume to be kept to the minimum needed for safety and function. For grouped, transport and e-commerce packaging, the empty space ratio may not exceed 50%, from 1 January 2030 or three years after the related implementing act, whichever is later.
A box that is twice the size of the product is the obvious problem. A mailing bag takes the shape of what is inside, which keeps empty space low for soft goods such as clothing and textiles. Good practice now:
Keep one folder per packaging item: the specification, the supplier's Declaration of Conformity and supporting information, recycled content evidence, and the annual weights you shipped to each country. The same folder answers your EPR scheme, a marketplace request and a customer question.
We manufacture co-ex mailing bags in our own factory in Istanbul. Our co-ex mailers, virgin and 70% recycled, printed and unprinted, are covered by a PPWR Declaration of Conformity. Sizes, thickness and print are made to order, so the bag can match your products rather than the other way round. See our mailing bag sizes and specifications or request the free sample kit together with the documents.
This checklist is general information at the time of writing (November 2026), not legal advice. Check your obligations with the competent national authority or your compliance scheme.
Yes. The regulation applies to all packaging placed on the EU market, whatever the size of the business. Some reporting duties differ by volume, and EU institutions are discussing relief for very small producers, but registration and conformity duties apply today.
No. Regulation (EU) 2025/40 has applied since 12 August 2026. Several individual requirements, such as harmonised labels, recycled content and the empty space ratio, apply from later dates set in the regulation.
Under the regulation as published, a producer selling directly to end users in another Member State must appoint an authorised representative for extended producer responsibility there. In October 2026 the Council agreed a position to exempt sales below one tonne of packaging per year per country. At the time of writing that is a negotiating position, not law.
An EU Declaration of Conformity under Regulation (EU) 2025/40, confirmation of the heavy metal limit, the recycled content (and how much is post-consumer), and the material composition you need for your EPR reports.
The 2030 minimum for plastic packaging that is not contact-sensitive, such as most mailing bags, is 35% post-consumer recycled content. A bag with 70% post-consumer recycled content is above that level; ask for the documentation that supports the figure.
This guide is general information based on published sources at the time of writing. It is not legal or tax advice.
Our co-ex mailing bags, virgin and 70% recycled, printed or plain, are covered by a PPWR Declaration of Conformity. Request the free sample kit and the documents together.