If you're a UK company sending online orders to customers across the EU, a major piece of legislation is about to change how you package and document every parcel you send. The EU Packaging and Packaging Waste Regulation — known as the PPWR — applies from 12 August 2026, and being based outside the EU does not exempt you. In several respects, it actually makes your obligations more complicated.
This guide breaks down, in plain English, what the PPWR is, why it applies to UK businesses, exactly what you need to do, and how to get ahead of the deadline.
What is the PPWR?
The PPWR is Regulation (EU) 2025/40. It replaces the old Packaging and Packaging Waste Directive and, crucially, it is a regulation rather than a directive — which means it applies directly and identically across all 27 EU Member States, without each country writing its own version. One set of rules, applied everywhere you ship. (If you'd prefer a plain-English overview to the full legal text, the EU's own summary of the regulation is a good starting point.)
It covers the full life cycle of packaging, from design and materials through to labelling, reuse, recycling and waste. And it defines "packaging" very broadly — including the boxes, mailers, void fill and protective materials around the goods you send.
The headline date is 12 August 2026, when the regulation starts to apply. But the timeline is staggered in both directions: some duties (like registering with national EPR schemes) are already live today, while others — the hard 40% empty-space cap, harmonised labelling, recycled-content targets — phase in between 2028 and 2030 and beyond. This guide flags the dates that matter as it goes.
Why does it apply to a UK company?
This is the most common misunderstanding we hear. The PPWR applies to all businesses placing packaging on the EU market — EU and non-EU alike. Brexit does not put you outside its scope. The moment your parcel and its packaging land with an EU customer, you have placed packaging on the EU market, and the regulation applies.
In fact, being a UK business adds a layer of complexity, because a number of the regulation's mechanisms assume you have an establishment inside the EU — and you don't. That has real consequences for how you handle Extended Producer Responsibility, which we'll come to below.
It's also worth being clear that this is separate from the UK's own packaging EPR scheme (UK pEPR). If you sell both domestically and into the EU, you are potentially in scope for both regimes at once. One does not cover the other, and you shouldn't assume your UK reporting satisfies your EU obligations. The UK government's Department for Business and Trade guidance for UK exporters is a useful official reference on what PPWR means for UK businesses specifically.
What UK sellers actually need to do
Here's what the PPWR puts on your plate as a UK company shipping parcels into the EU.
1. Extended Producer Responsibility (EPR) — country by country
This is the largest recurring burden, and the place where your UK location matters most. It's also one many sellers misunderstand as starting in August 2026 — in fact, national packaging EPR schemes already exist and operate now (Germany's LUCID/VerpackG, France's CITEO/AGEC, Italy's CONAI, Spain's ECOEMBES), so registration is a live obligation today, not a future one. What PPWR adds from 2026 is a more harmonised framework on top of these national systems.
Under EPR, producers must register in each Member State where they make packaging available for the first time — and pay fees based on the volume and material of packaging they put into that market. Because you are not established in any EU Member State, you will typically need to appoint an Authorised Representative in each country you ship to in order to handle these obligations on your behalf.
In practice, that means if you ship to eight EU countries, you may face registration in eight markets and the appointment of one or more Authorised Representatives. You'll need to track the weight and material of the packaging you send into each market and report it on an ongoing basis. This is not a one-off task; it's a continuing compliance process. Because fees are calculated on the weight and material you put on the market, the packaging you choose directly affects what you pay — lighter, mono-material, easily recyclable formats (the kind covered by our EPR-friendly packaging range) tend to attract lower fees. Note that the PPWR-specific modulated fee structures (where greener packaging pays less) phase in later — certain EPR fees commence from 1 January 2030 — but the underlying duty to register and report in each market applies now.
One point to pre-empt, because it's easy to half-hear and misread: in December 2025 the European Commission proposed suspending the Authorised Representative requirement until 2035 — but only for producers established in the EU. Non-EU sellers, including UK businesses, are explicitly excluded, so this proposed relief does not change your position. (It also remains only a proposal, pending the European Parliament and Council, as of mid-2026.)
2. Hold the conformity documentation
You must be able to demonstrate that the packaging you use complies with the regulation. That means holding an EU Declaration of Conformity (the model for which is set out in Annex VIII of the regulation) and the supporting technical documentation for your packaging — and being able to produce it on request.
This matters more than it sounds: authorities can request this documentation, and importers are required to respond within 10 days. If your packaging supplier can't give you this paperwork in a clean, ready form, you'll be assembling it yourself against the clock.
3. Sort out who counts as the "importer"
This is a genuinely confusing area for UK sellers, and it's worth getting clear advice on. Depending on your shipping terms (for example, DDP versus DAP), whether you sell through a marketplace, and how your logistics are structured, the "importer" role can land on you, on a logistics partner, or even on your customer. If you ship delivered-duties-paid directly to consumers, you are often effectively carrying importer-type duties — including holding the Declaration of Conformity and ensuring your importer details are identifiable (see the labelling section below for how that can be done).
4. Labelling — what actually has to go on the box, and when
"Labelling" under the PPWR is two separate things, and they're often conflated in a way that causes needless panic about relabelling every box for August 2026. Here's the distinction.
Operator identification (live from 2026). The manufacturer's — and, where applicable, the importer's — name, registered trade name or trademark, and contact address must be identifiable. One important clarification, because it trips people up: under the PPWR "manufacturer" is a legal role meaning the party that places the packaging on the market under its own name or trademark — i.e. the brand owner — not the factory or supplier that physically produced it. For any given packaging item there is exactly one such manufacturer EU-wide. So this requirement never forces you to disclose who actually makes your boxes: the name that appears is the brand owner's (you, if you brand the packaging; your customer, if they ship their own products under their brand). Your upstream supplier sits in a separate "supplier" role and is not named to the end customer. Importantly, this information also does not have to be printed on every parcel: it can appear on the packaging, on a data carrier such as a QR code, or in accompanying documents. So as a UK seller carrying importer-type duties, you have some flexibility in how your details are presented rather than being forced to print them on each box. (The precise rules and the one narrow micro-enterprise exception sit in the regulation's operator-obligation articles and are worth confirming against the text or an adviser for your exact set-up.)
The harmonised material/sorting label (from 2028, not 2026). This is the pictogram showing what the packaging is made of and how the consumer should sort it for recycling. This one does go on the packaging — but it is not an August 2026 requirement. It applies from the later of 12 August 2028 or 24 months after the relevant implementing acts, and the exact pictogram design hasn't even been published yet. There's also a generous transition: packaging made or imported before the requirement bites can continue to be used for three years afterwards.
The reassuring part for most of our customers: if you ship in plain, single-material cardboard, this label is straightforward — it's essentially "paper/board." The packaging-artwork overhaul that gets the headlines is a problem for complex multi-material consumer packaging, not for someone shipping in a recyclable carton. There is also likely to be a QR-code / digital-identifier layer arriving around 2027–2028, but its exact scope and timing for packaging are still being set through delegated acts, so treat it as "coming, keep an eye on it" rather than a fixed rule for now.
5. Minimise empty space (and prepare for the 40% e-commerce cap)
This one affects how you pack every single order, and the dates are widely misreported, so it's worth being precise. There are two distinct obligations:
From 12 August 2026, a general packaging minimisation duty applies: packaging volume and weight must be reduced to the minimum needed for functionality, safety, hygiene and consumer acceptance. Marketing or perceived value do not justify extra packaging. From 1 January 2030, a hard empty-space cap takes effect — 40% for e-commerce parcels (and grouped and transport packaging).
The catch is that you can't safely ignore the 40% figure until 2030. Market surveillance authorities are expected to use the 2030 ratio as a forward-looking benchmark when assessing the general minimisation duty in 2026 and beyond — so a parcel that is mostly air is unlikely to satisfy the 2026 test even before the hard cap formally bites.
Two technical points worth knowing, because they shape the right solution. The calculation is volumetric, not weight-based. And void fill counts as empty space, not as product volume — paper, air pillows, bubble wrap, foam and packing peanuts all count against you. That means switching to a more "sustainable" filler doesn't solve the problem; only reducing the actual empty volume does.
The practical answer is right-sized packaging: choosing or making boxes that match the actual dimensions of what you're sending, rather than padding out an oversized box. This is exactly where size-adjustable packaging earns its place — one box that changes to fit the order removes empty space at source and cuts the void fill that would otherwise count against you. (The European Commission published a guidance document and an FAQ in March 2026 that bear on how empty space is measured — worth checking before you make any firm "compliant" claims in your own marketing.)
6. Check PFAS and substances of concern — if you ship food-contact packaging
If any of your packaging is food-contact, the PPWR restricts PFAS ("forever chemicals") above set limits, and more broadly requires that substances of concern be minimised. You'll need evidence — typically test results — that your packaging meets these limits. If this applies to you, your packaging supplier should be able to provide that evidence.
A simple way to think about it
Almost everything above splits into two buckets:
Things only you can do — registering for EPR in each market, appointing Authorised Representatives, determining your importer status, and deciding how you pack each order. These are yours to own, ideally with proper professional advice.
Things that depend on packaging data — the Declaration of Conformity, the technical file, the material-and-weight breakdown that EPR reporting needs, PFAS evidence, and proof that your packaging meets the minimisation and empty-space requirements. This information originates with whoever supplies your packaging — so the right supplier can take a large amount of this work off your hands.
How to prepare before August 2026
A sensible order of priorities for a UK seller:
- Map your markets. List every EU country you ship to and treat each as a potential EPR registration.
- Resolve your importer status. Get clear advice on who the importer is under your shipping arrangements, because several duties hang off the answer.
- Line up Authorised Representatives for the markets where you'll need them.
- Gather your conformity documentation — make sure you can obtain a Declaration of Conformity and technical file for the packaging you use.
- Audit your packaging sizes against the minimisation duty (live from August 2026) and the 40% empty-space benchmark (the hard cap applies from 2030, but expect it to be used as the yardstick sooner), and identify where you're shipping too much air.
- Set up packaging data tracking — material and weight per item, per market — so EPR reporting isn't a scramble.
Frequently asked questions
Is there a minimum number of parcels before the PPWR applies?
No. There is no EU-wide minimum volume that exempts you. The regulation is triggered by the act of placing packaging on a national market — not by hitting a parcel count — so even a handful of orders into a country can, in principle, create an obligation there. There is no general small-business or SME exemption from EPR registration and fees.
There are two limited points of relief, and it's important not to overstate them. First, a microenterprise exemption exists, but it only applies to manufacturer duties (such as drawing up the technical documentation) — not to EPR registration and fees. As a UK seller you are typically the producer/importer rather than the manufacturer, so this carve-out usually doesn't help you. Second, reporting is lighter below roughly 10 tonnes of packaging placed on the market — but that's a simpler report, not an exemption. You still have to register.
A genuine nuance: the thresholds that do exist are set country by country, not at EU level. A few Member States apply their own minimum turnover or volume thresholds, so whether a very low volume crosses the line is a per-country question worth checking for each market you ship into.
What if I only have one customer in each of several EU countries?
Consider a realistic example: a single customer each in Germany, France, the Netherlands, Sweden, Greece and Spain places an order. On paper, you have placed packaging on six different national markets — and because there's no volume exemption, each is potentially its own registration. As a UK business not established in any of them, that points toward appointing an Authorised Representative in each country: six markets, six schemes, potentially six representatives.
That is clearly disproportionate for six orders, so here's how this works in practice rather than just on paper. The national schemes don't all behave identically — some markets (France's CITEO and Germany's system, for example) effectively require registration from the first unit, while others have small-quantity tolerances. If you sell through a marketplace such as Amazon or Etsy rather than your own checkout, the marketplace is increasingly treated as a responsible actor and may handle or simplify parts of the EPR burden. And your reporting sits at the lightest tier given the tiny volume.
What small sellers realistically do is one of: sell through a marketplace that absorbs the burden; use a single pan-EU EPR compliance provider that acts as Authorised Representative across multiple countries in one contract (far cheaper than arranging each separately); or focus registration on the markets they sell into regularly and reconsider one-off orders to harder markets. The honest takeaway is that the compliance overhead is largely a fixed cost that doesn't scale down to match low volume — which is exactly why getting a quote from a multi-country EPR provider is usually the most efficient first step.
I'm based in the UK and just export to those countries — does it still apply?
Yes — and being outside the EU makes it more burdensome, not less. The PPWR applies to all businesses placing packaging on the EU market, EU and non-EU alike. The trigger is where the packaging lands, not where you're based: the moment your parcel reaches a customer in an EU country, you've placed packaging on that market, regardless of your UK location.
Being in the UK doesn't remove the obligation — it removes the easier route to meeting it. An EU-based seller can sometimes register directly; you can't, because you have no legal entity inside those countries. That absence is precisely what triggers the Authorised Representative requirement. In short, a UK seller shipping into the EU gets the obligations without the simpler compliance path.
The one important "it depends" is how you ship. If you sell through a marketplace, or ship on terms where someone else is the importer of record (for example, the customer or a logistics partner clears the goods rather than you shipping delivered-duties-paid), the producer/importer role — and the registration duty — can sit with them instead of you. So the practical question isn't only "am I in scope" (you are), but "given how I actually ship, who is the producer for each consignment?" — and that's worth pinning down before registering anywhere.
What happens if I don't comply and just keep shipping?
It's worth being realistic here rather than alarmist. The penalties on paper are large: the PPWR leaves them to each Member State, requiring fines that are "effective, proportionate and dissuasive," and several countries have real numbers attached — France, for example, imposes fines for failing to register under an EPR scheme, and EU-wide penalties for reporting violations commonly fall in the tens of thousands of euros, reaching into six figures for serious cases. Some guidance even references fines of up to 4% of turnover at the severe end. But these headline figures are aimed primarily at companies of meaningful size, and the chance of a national authority pursuing a UK micro-seller over a handful of parcels with a five-figure fine is, in practice, low. Enforcement resources go to volume sellers first.
The risk that actually matters at small scale isn't the fine — it's losing the ability to trade. Market access, not financial penalty, is the primary enforcement mechanism. That shows up in two ways that don't depend on anyone choosing to investigate you:
- Customs holds. Customs and national authorities can block non-compliant shipments at the border. If a parcel is held, your customer doesn't receive their order, and you're left managing the refund, the complaint, and potentially the cost of returned or destroyed goods.
- Marketplace de-listing. This is the most likely consequence for most small online sellers. Several Member States already require marketplaces to verify that third-party sellers are EPR-registered — or to take on the obligation themselves if the seller isn't — and marketplaces increasingly suspend sellers who can't provide an EPR registration number. This is a blanket platform policy, not a targeted investigation, so it can hit you regardless of volume.
The honest summary: this is not "comply or face certain ruin," and anyone telling a six-parcel seller they'll definitely be fined €200,000 is overstating it. But it isn't safely ignorable either, because the most probable consequences — a held parcel or a suspended marketplace listing — happen automatically rather than requiring an enforcement officer to come after you. Ignoring it also doesn't make the cost disappear; it defers it, and the day low volume becomes regular volume you'll have a backdated non-compliance history rather than a clean start. For most small sellers, the marketplace's EPR-number requirement is the deadline that forces the issue well before any government does.
Does the 40% empty-space limit apply from August 2026?
No — and this is one of the most commonly misreported dates, so it's worth getting right. The hard cap of 40% empty space for e-commerce parcels applies from 1 January 2030, not from August 2026. What applies from 12 August 2026 is a broader minimisation duty: packaging must be reduced to the minimum volume and weight needed for functionality, safety, hygiene and consumer acceptance.
In practice, though, you shouldn't treat 2030 as a free pass until then. Market surveillance authorities are expected to use the 2030 ratio as a yardstick when assessing the general minimisation duty from 2026 onward, so a parcel that's mostly air is unlikely to pass even before the hard cap formally applies. Two technical details matter when you calculate it: the measurement is volumetric (not by weight), and void fill — paper, air pillows, bubble wrap, foam, packing peanuts — counts as empty space rather than product volume. That's why switching filler material doesn't fix the problem; only reducing the actual empty volume, through right-sized packaging, does.
Do I have to put a label on every box for August 2026?
Not in the way most people fear. It helps to separate two things. Your operator identification — your name and contact details as importer — must be identifiable from 2026, but it can sit on the packaging, in a QR code, or in accompanying documents, so you're not forced to print it on every parcel. The harmonised material-and-sorting pictogram (the symbol telling consumers what the packaging is made of and how to recycle it) does go on the packaging, but that requirement applies from 2028, not 2026 — and the official pictogram design hasn't even been published yet, with a three-year sell-through period for existing stock once it does.
So nothing about August 2026 forces you to redesign or relabel your boxes overnight. And if you ship in plain single-material cardboard, the eventual 2028 label is simple — essentially "paper/board." The packaging-artwork overhaul you may have read about is aimed at complex multi-material consumer packaging, not recyclable shipping cartons.
How we can help
We supply the packaging — which means a lot of the information the PPWR requires you to hold actually originates with us. We can provide the EU Declaration of Conformity and technical documentation for the packaging you buy from us, give you a clean per-item breakdown of material and weight structured for EPR reporting, and offer size-adjustable packaging that helps you meet the minimisation duty now and the 40% empty-space cap that lands in 2030, with documentation to support it.
It's also worth knowing that cardboard boxes are explicitly exempt from the PPWR's reusable-transport-packaging targets that apply from 2030 — so a right-sizing strategy built around recyclable, fibre-based packaging keeps you clear of the reuse-system obligations that affect some other formats.
We can't register you for EPR or act as your Authorised Representative — those sit with you and your advisers — but we can make sure the packaging side is one less thing to worry about. If you'd like to talk through how this applies to your business, get in touch and we'll walk you through it — or request a packaging quote to get started.
Official sources
- Regulation (EU) 2025/40 — full legal text (EUR-Lex)
- Plain-English summary of the regulation (EUR-Lex)
- European Commission — packaging waste topic page
- Commission guidance document on the PPWR (March 2026)
- Commission FAQ on the PPWR (March 2026)
- UK Department for Business and Trade — PPWR guidance for UK exporters
This article is for general information and is not legal advice. PPWR obligations — particularly around EPR registration, Authorised Representatives and importer status — depend on your specific circumstances, and you should seek professional advice before acting.
PPWR for UK Sellers: What the New EU Packaging Rules Mean If You Ship Parcels to the EU