What is e-commerce packaging and do I need to declare it for EPR?

Yes, you must declare e-commerce packaging for Extended Producer Responsibility (EPR) if your business is the first to place these shipping materials on a specific national market (Packaging and Packaging Waste Regulation (EU) 2025/40). From 1 January 2030, e-commerce packaging must not exceed a 50% empty space ratio inside the outer container.

E-commerce packaging is the final physical barrier that stands between a retail product and its end destination. For online retailers and marketplace merchants, these boxes, mailers, and protective inserts represent a massive portion of their material footprint. The rapid expansion of digital commerce has forced environmental regulators to implement strict monitoring and waste management frameworks.

Under Extended Producer Responsibility (EPR) rules, this packaging carries an inescapable operational cost. Governments across Europe and North America hold businesses directly accountable for the entire lifecycle of the shipping waste they generate. Online sellers must accurately measure, categorise, and declare every piece of cardboard, plastic, and paper they place on the market. Non-compliance results in severe financial penalties, operational blocks on major digital platforms, and the immediate loss of European market access.

What e-commerce packaging actually means

Under Article 3(1) of the Packaging and Packaging Waste Regulation (PPWR), e-commerce packaging is defined as transport packaging used to deliver products in the context of sale online or through other means of distance sales to the end user. While traditional transport packaging is used to ship goods in bulk between warehouses, e-commerce packaging is specifically designed to facilitate the final leg of the journey directly to the consumer's doorstep.

This legal distinction is critical. Transport packaging going to commercial warehouses is treated as commercial waste, whereas e-commerce packaging enters the household waste stream. Because of this, regulators classify e-commerce boxes and mailers as residential waste, triggering full compliance obligations. Additionally, the definition includes any auxiliary protective materials added to the container to prevent movement or damage during transit, such as wrapping film, corner protectors, and various types of void fill.

E-commerce packaging represents the protective outermost layer added to facilitate the direct shipment of goods to an end user via online or distance sales channels.

This means that when a merchant purchases standard cardboard boxes or bubble mailers to fulfil orders, those materials are obligated packaging units that require administrative tracking. If your business fills the box or adds the shipping label, you are legally responsible for the end-of-life management of those materials under most national EPR regimes.

Does this apply to me?

If you run an online storefront, sell on a digital marketplace, or manage a fulfilment warehouse that dispatches goods to end users, the answer is yes. Under Article 44 of the PPWR, all producers of packaging must register with a national EPR registry, report their annual packaging volumes, and pay modulated waste management fees. The regulation defines the producer of e-commerce packaging as the economic operator established in a Member State who makes transport packaging available for the first time.

This applies regardless of whether you sell through your own site or utilise a third-party marketplace. European regulations impose joint obligations on online platforms. Under Article 45(2) of the PPWR, platforms allowing consumers to conclude distance contracts with third-party sellers must verify that those sellers are registered with the national authorities and have paid their EPR contributions before allowing them to use platform services.

If you are established outside the European Union but sell directly to European consumers via distance contracts, you are still obligated. You must appoint an authorised representative for EPR in each Member State where your customers are located to fulfil your reporting obligations.

Which quantitative thresholds and empty-space limits apply to e-commerce packaging?

The PPWR and national laws apply specific quantitative thresholds, limits, and material targets to e-commerce packaging. In particular, the PPWR introduces a strict limit on the empty space inside shipping boxes.

The table below consolidates the legal thresholds, ratios, and deadlines applicable to e-commerce packaging under the PPWR and other major national laws.

Under Article 24(3) of the PPWR, the empty space ratio is calculated as the difference between the total volume of e-commerce packaging and the volume of sales packaging contained inside, divided by the total volume of the e-commerce packaging. The law is clear: any space filled by filling materials - including paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, or polystyrene chips - is legally counted as empty space when calculating this 50% ratio. This design constraint forces companies to choose boxes matching actual dimensions.

Under Article 24(5), economic operators using original sales packaging as e-commerce packaging, without adding any further outer shipping layer, are exempt from the 50% empty space ratio. However, this exemption only applies if the primary sales packaging itself complies with the packaging minimisation requirements under Article 10, meaning its weight and volume have been reduced to the minimum functional level.

Common misconceptions about e-commerce packaging

“E-commerce packaging is considered transport packaging and is exempt from household recycling contributions”

E-commerce packaging is destined directly for the end user and will inevitably become waste in the consumer's home. Therefore, it is subject to the same residential EPR contributions and reporting requirements as primary sales packaging. It is incorrect to assume that because shipping boxes protect goods in transit, they are exempt from household EPR fees.

“Void fill materials like paper or bio-based packing peanuts do not count toward empty space”

Many brands assume that using compostable or paper-based filling materials helps them comply with empty space restrictions. However, the PPWR explicitly states that all filling materials - regardless of material composition - are considered empty space for the purpose of the 50% limit. You must reduce the physical box size.

“If a fulfilment provider handles shipping, the online merchant is exempt from reporting”

There is a common belief that outsourcing logistics shifts producer responsibility to the third-party warehouse. In reality, the brand owner is considered the manufacturer and producer if the goods carry their name or brand. Fulfilment providers are only considered producers if they place goods from non-EU sellers without an established representative onto the market.

“Cardboard shipping boxes must comply with future reusable packaging targets”

Some businesses worry that cardboard shipping cartons will eventually be banned under the EU's ambitious re-use targets. However, Article 29(4)(d) of the PPWR explicitly exempts transport and sales packaging in the form of cardboard boxes from the mandatory re-use targets. Regulators recognise that paper fibres have a low number of rotations.

5 examples of e-commerce packaging

Corrugated cardboard cartons

The standard multi-layered shipping box is the most common format of e-commerce packaging. These boxes must be declared by weight under the paper and cardboard material category, and they are subject to Swedish registration with the Environmental Protection Agency (Naturvårdsverket) or French reporting to Citeo.

Padded paper mailer bags

Padded envelopes made of kraft paper with integrated cushioning are used to ship flat items. If the bag contains multiple non-separable materials, it is treated as composite packaging under the PPWR and reported under its majority material, provided it accounts for more than 50% of the total mass.

Polyethylene shipping envelopes

Coextruded plastic mailer bags made of low-density polyethylene (LDPE) are commonly used for clothing. Under the PPWR, plastic flexible formats must contain post-consumer recycled content by 2030 and must meet strict recyclability performance grades to avoid heavy eco-modulated fee surcharges.

Plastic air cushions and bubble wrap

Lightweight plastic void fill used to fill empty spaces within cardboard cartons. Although these materials are exceptionally light, their entire weight must be recorded and declared as plastic packaging waste under EPR reporting schedules, and their volume counts as empty space under the 50% rule.

Cardboard edge and corner protectors

Rigid paperboard reinforcements placed inside boxes to protect product corners from transport damage. These associated components must be reported under the boxboard or paper packaging categories.

Terms related to e-commerce packaging

Developing a cohesive compliance strategy requires a solid understanding of related packaging terms. The table below outlines how e-commerce shipping materials connect to neighbouring legal definitions.

Frequently asked questions

Do I need to report the weight of e-commerce void fill?

Yes, all protective elements used inside a shipping carton, including paper cuttings, bubble wrap, and air cushions, must be declared by weight under their respective material categories. You must report these volumes to your registered PRO alongside the weight of the outer boxes.

What is the penalty for shipping products to France without registering?

Failing to register with ADEME and obtain a Unique Identifier Number (UIN) is a serious compliance breach in France. Under French law, companies can face administrative fines of up to €30,000 for failing to hold a valid UIN, or penalties of up to €7,500 per tonne.

Are micro-businesses exempt from e-commerce packaging rules?

While micro-businesses enjoy exemptions from packaging re-use targets under Article 29(4) of the PPWR, they are still subject to core producer registration and reporting obligations. France and Sweden have no de minimis thresholds, meaning even the smallest online sellers must register and pay packaging contributions.

Does using paper instead of plastic void fill help with the 2030 empty space limit?

No. Under Article 24 of the PPWR, all void-fill materials are legally counted as empty space when calculating the 50% empty space ratio, regardless of whether they are made of paper, cardboard, or biodegradable plastic. The limit is designed to restrict oversized packaging, meaning you must reduce the size of the box.

Who is considered the producer if I use a third-party logistics company?

If your products carry your own registered name or trademark, your business is legally considered the producer of the packaging. Fulfilment centres and logistics providers are only held responsible if they place products from non-EU sellers without an established representative in the Union onto the market.

Do I need to declare the adhesive tape used to seal my boxes?

Under component thresholds in some national guidelines (such as MMSM in Canada), if an ancillary component like adhesive tape represents less than 5% of the total packaging unit weight, it can be reported under the predominant material category, which is cardboard.

Sources:

• Packaging and Packaging Waste Regulation (EU) 2025/40
• Everything you need to know about the PPWR - Verpact
• Extended producer responsibility for packaging: who is affected and what to do
• Packaging waste: prepare for extended producer responsibility - Daera
• My membership - Citeo.com
• Producer responsibility for packaging - NPA