PPWR Compliance Checklist for E-Commerce 2026

Why Every E-Commerce Seller Needs a PPWR Compliance Checklist Now

The EU Packaging and Packaging Waste Regulation -- officially Regulation (EU) 2025/40, commonly known as the PPWR -- enters into force on August 12, 2026. If you sell physical products into the EU, whether you are based in Berlin or Baltimore, this regulation applies to you.

Unlike older directives that each Member State transposed differently, the PPWR is a regulation. It applies directly and uniformly across all 27 EU countries. There is no waiting for national implementation. One set of rules, one deadline.

This ppwr compliance checklist walks you through every requirement that matters for small and mid-sized e-commerce sellers -- businesses that typically ship 5 to 15 packaging types rather than hundreds. No enterprise jargon, just clear steps you can start today.

Key PPWR Deadlines at a Glance

Milestone	Date	What Happens
Regulation published	January 2025	Regulation (EU) 2025/40 in the Official Journal
Entry into force	August 12, 2025	18-month countdown begins
General compliance deadline	August 12, 2026	Articles 5--12 apply in full
PFAS restriction applies	August 12, 2026	No intentionally added PFAS in food-contact packaging
Empty space cap (e-commerce)	January 1, 2030	Max 50% empty space in shipping packages (Article 24)
Recycled content targets	2030 onwards	Minimum recycled plastic percentages phase in
Reuse targets	2030 onwards	Reuse and refill quotas for specific sectors

The August 2026 deadline is the one that hits hardest for DTC and e-commerce sellers. Everything in this checklist targets that date.

Step 1: Inventory Every Packaging Component

Before you can comply, you need to know exactly what you ship. Make a list of every packaging element you use:

• Primary packaging -- the box, pouch, bottle, or wrapper that directly contains your product
• Secondary packaging -- any outer box or sleeve used for grouping or branding
• Tertiary/transport packaging -- shipping boxes, mailers, padded envelopes
• Ancillary components -- tape, labels, cushioning inserts, void fill, tissue paper

Most e-commerce sellers undercount. That branded tissue paper, the thank-you card sleeve, the sticker sealing your box -- they all count as packaging under the PPWR.

Action item

Create a spreadsheet with columns for: component name, material, weight, supplier, and function (primary / secondary / transport / ancillary). This becomes the foundation for every step that follows.

Step 2: Eliminate Substances of Concern (Article 5)

Article 5 of Regulation (EU) 2025/40 restricts hazardous substances in packaging. Two restrictions hit immediately in August 2026:

PFAS ban in food-contact packaging

Per- and polyfluoroalkyl substances (PFAS) -- the so-called "forever chemicals" -- are banned when intentionally added to food-contact packaging. If you sell food, supplements, or anything consumed, check with your packaging supplier whether the material contains intentionally added PFAS. Common culprits: grease-resistant paper bags, moulded fibre bowls, and coated cardboard.

Heavy metals limit: 100 ppm

The sum of lead, cadmium, mercury, and hexavalent chromium in packaging must not exceed 100 parts per million (ppm). This is not new -- it carried over from the old Packaging Directive -- but it is now enforceable uniformly. If you use printed packaging with coloured inks, request a test certificate from your supplier confirming heavy metals compliance.

Action item

Contact every packaging supplier and request written confirmation of (a) no intentionally added PFAS for food-contact items, and (b) heavy metals below 100 ppm. Keep these certificates on file.

Step 3: Design for Recyclability (Articles 6 and 7)

The PPWR requires all packaging placed on the EU market to be designed for recycling. From August 2026, packaging must meet Design for Recycling (DfR) criteria established by the Commission.

What this means in practice for e-commerce sellers:

• Avoid material combinations that cannot be separated. A cardboard mailer with a glued-in plastic window is harder to recycle than a fully cardboard one.
• Minimise different material types. An all-corrugated shipping box with paper tape is better than corrugated box + plastic tape + foam inserts + a poly bag inside.
• Check labels and adhesives. Labels should be made of the same material as the packaging, or use wash-off adhesives.

Action item

Review your packaging inventory from Step 1. Flag any multi-material components. Ask your supplier if mono-material alternatives exist. Prioritise changes for your highest-volume packaging types first.

Step 4: Meet Minimum Recycled Content (Article 7)

Article 7 sets mandatory recycled content targets for plastic packaging. The first binding targets kick in from 2030, but the regulation already requires you to declare your recycled content from 2026.

For now, the practical step is:

• Ask your suppliers what percentage of post-consumer recycled content is in each plastic packaging component
• Document it in your packaging inventory
• Start conversations about increasing recycled content to meet the 2030 thresholds (which range from 10% for contact-sensitive packaging to 35% for other plastic packaging)

Step 5: Comply with the E-Commerce Empty Space Rule (Article 24)

This is the rule that affects online sellers most directly. Article 24 of the PPWR states that for e-commerce, transport, and grouped packaging, the empty space ratio must not exceed 50% from 1 January 2030.

Empty space is calculated as the ratio of empty space to the total volume of the package. A box that is 50% product and 50% air is right at the limit. A box that is more than half empty fails.

Note: while the specific 50% cap takes effect on 1 January 2030 under Article 24(1), the general packaging minimisation principles in Article 10 already apply from August 2026. You should start right-sizing now to meet Article 10 and be ready for the hard cap in 2030.

Why this matters for DTC sellers

Many e-commerce businesses use a small number of box sizes for all orders. It is common to put a small product into a large box and fill the void with paper or air pillows. Under the PPWR, this approach needs to change.

How to comply

1. Right-size your boxes. Use box sizes matched to your products. If you have 10 different product sizes, you may need 4--5 box sizes rather than 2.
2. Void fill counts as empty space. Air pillows, crumpled paper, and packing peanuts do not reduce the empty space calculation -- they are considered void, not product.
3. Use adjustable packaging. Mailers and boxes with variable height or width allow a tighter fit.

Action item

Measure your top-selling product shipments. Calculate the empty space ratio for each. If any exceed 50%, source alternative packaging sizes or switch to adjustable formats.

Step 6: Apply Correct Labelling and Marking (Article 12)

All packaging placed on the EU market must carry specific markings from August 2026:

• Material identification -- what the packaging is made from, using established coding
• Recycling/sorting instructions -- a harmonised label telling consumers how to dispose of the packaging (the Commission will publish the exact format via delegated acts)
• QR code or digital carrier -- linking to detailed information about the packaging's composition and proper disposal

The labelling rules will become more specific as delegated acts are published during 2025--2026. However, you should prepare by:

1. Identifying which packaging components currently carry no material labelling
2. Reserving print space on your packaging for the new harmonised labels
3. Discussing timeline with your packaging printer or supplier

Action item

Audit your current packaging labels against the known requirements. Plan a print update cycle that aligns with the August 2026 deadline. Do not order excessive stock of current packaging designs.

Step 7: Prepare Your Declaration of Conformity (Articles 38--39)

Articles 38 and 39 require economic operators to draw up a Declaration of Conformity (DoC) for each packaging unit placed on the EU market. This is a formal document stating that your packaging meets the requirements of Articles 5 through 12.

The DoC must include:

• Identification of the packaging (type, material, dimensions)
• Reference to Regulation (EU) 2025/40 and the specific articles you are declaring conformity with
• Name, address, and contact details of the responsible economic operator
• A statement that the declaration is issued under the sole responsibility of the operator

You must keep the DoC available for 10 years after the packaging is placed on the market, and present it to market surveillance authorities on request.

Action item

Create a DoC template now. For each packaging component in your inventory, fill in the relevant details. Update it whenever you change a packaging component.

Step 8: Set Up Ongoing Compliance Monitoring

PPWR compliance is not a one-time project. New delegated acts, recycled content thresholds, and reuse obligations phase in through 2030 and beyond. Build these habits:

• Quarterly packaging review -- check if any components have changed or if new products added new packaging types
• Supplier communication cadence -- request updated certificates and test reports annually
• Regulatory monitoring -- track Commission delegated acts that will specify labelling formats, DfR criteria, and recycled content calculation methods

Common Mistakes to Avoid

1. Assuming your supplier handles compliance. The regulation places obligations on the entity placing packaging on the EU market. If that is you, it is your responsibility regardless of where the packaging is made.
2. Ignoring ancillary components. Tape, labels, and inserts all count as packaging.
3. Stockpiling old packaging. Non-compliant packaging placed on the market after August 12, 2026 is a violation, even if it was manufactured before that date.
4. Waiting for delegated acts. Some implementing details are still coming, but the core requirements in Articles 5--12 are already final. Start now.

What Happens If You Do Not Comply

Market surveillance authorities in each EU Member State will enforce the PPWR. Non-compliance can lead to:

• Products being held at customs or removed from marketplaces
• Fines determined by national enforcement frameworks
• Loss of access to the EU market

For sellers on platforms like Amazon EU, compliance may also become a marketplace requirement -- platforms are increasingly asked to verify seller compliance with EU product regulations.

Start Your PPWR Compliance Today

The August 12, 2026 deadline leaves limited time to audit, source, redesign, and certify your packaging. The earlier you start, the more options you have with suppliers and the less you risk disruption to your operations.

Complydex helps small e-commerce sellers generate their Declaration of Conformity and verify compliance step by step. Create your free account and start your compliance check now.