Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) is beginning to apply in the EU, at least in part, almost two years after its approval. As of this August 12, European companies will have to adopt the necessary measures to comply with a regulation that comes to govern one of the areas to which we usually devote fewer headlines but without which, quite simply, commerce as we know it would cease to exist.
As you might imagine, this is a fairly lengthy text (71 articles) with multiple implications, so we will focus on the area in which we usually operate, and which we believe is the one that interests you most: eCommerce.
This new legal text focuses on two concepts: sustainability and labeling, with the aim of creating a new framework that is more respectful of our environment and, at the same time, more efficient from the standpoint of managing its entire life cycle, from production to waste. In doing so, the EU aims to avoid unnecessary packaging and promote reuse, refilling, and recycling, with the idea of “contributing to the circular economy and climate neutrality by 2050.”
In fact, in addition to obligations for companies, it also sets a target for member states: achieving a 70% recycling rate by 2030, with specific targets for different materials. That said, all packaging must be recyclable, and to achieve this it must be designed with material recycling in mind. In addition, it must facilitate collection, sorting, and large-scale recycling when it becomes waste.
That said, these requirements do not all apply starting in August 2026: the timeline provides for progressive implementation, with numerous milestones between 2028 and 2035, meaning companies will have several years to adapt design, labeling, logistics, and reuse systems.
Another of the regulation’s most relevant aspects, especially for eCommerce companies, addresses a reality that all of us have faced at some point as consumers when receiving an order: the mismatch between the size of the packaging and the size of the product inside it. The legal text therefore specifies that “packaging shall be designed so as to minimize its weight and volume while maintaining its functionality” and clarifies that “consumer acceptance shall not justify additional packaging weight or volume.”
With 2030 as the deadline, grouped packaging, transport packaging, and packaging for products purchased through eCommerce may not exceed 50% empty space. The idea is that packaging intended for sale should minimize empty space, “while maintaining functionality.” And no, in case you were wondering, it is not enough to fill the extra space in the box with filler materials (paper shreds, air pillows, bubble wrap, etc.). All of that will be considered empty space.
In addition, packaging that uses double walls or false bottoms to increase the perceived volume of the product is prohibited, unless it is protected by design rights or trademarks.
The EU also wants end users to have more information about reusability, the availability of reuse systems, and the location of collection channels. To this end, reusable packaging will have to include specific information about its reuse and, when this obligation starts to apply, a QR code or another digital medium will make it possible to consult data such as the availability of the reuse system, collection points, and the number of rotations.
One interesting thing lawmakers have done is specify different obligations for different members of the supply chain, taking into account how each of them can contribute to achieving the intended objectives. For example:
Beyond what may most directly affect the eCommerce space, it is interesting to see how the new regulation seeks to govern even the smallest aspects of the packaging world.
There are, therefore, some striking elements in the text that will clearly impact our consumption habits. For example, the new rules introduce restrictions on single-use plastic packaging, such as single-use wrapping used to group products at the point of sale in order to encourage consumers to buy more than one product, or packaging for prepacked fruit and vegetables weighing less than 1.5 kg. Packaging for individual portions of condiments, sauces, coffee milk, and sugar will also not be allowed, nor will small, single-use cosmetic and toiletry products used in hotels.
And yes, in case you were wondering, the new regulation also takes aim at most very lightweight plastic bags, which will be banned unless they are used for hygiene purposes or to prevent food waste.
Image: ChatGPT
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