How to adapt your e-commerce business to the PPWR? The 50% limit on empty space in parcels

PPWR e-commerce represents a new approach to packaging online orders: the parcel must protect the product, but must not be unnecessarily oversized. One of the most important requirements for online shops is a limit of 50% on empty space in bulk, transport and e-commerce packaging. The European Parliament states that, to reduce unnecessary packaging, the maximum proportion of empty space in such packaging must be 50%, and manufacturers and importers will have to minimise the weight and volume of packaging.

For an online shop, this means having to analyse cardboard boxes, envelopes, packing materials, automated packaging systems, order fulfilment processes and packaging data. The problem will not be the use of cardboard itself. The problem will be sending a small product in a box that is too large, filled with air, paper, bubble wrap or air cushions.

PPWR e-commerce – what’s changing for online shops?

The PPWR, or Packaging and Packaging Waste Regulation, is an EU regulation concerning packaging and packaging waste. The European Commission states that the new rules are intended to reduce waste, increase the recyclability of packaging, promote the use of recycled materials and eliminate unnecessary packaging.

PPWR is particularly important for e-commerce, as online sales very often generate additional shipping packaging. The product already has its own unit packaging, and the shop adds a box, an envelope, plastic film, tape, a label and packing material. It is precisely this additional layer of packaging that will come under increasing scrutiny in terms of empty space, weight, volume and recyclability.

The PPWR does not prohibit packaging for postal delivery, but requires that the packaging be proportionate to the product and its protective function.

If an online shop wants to prepare for the new rules, it should start by reviewing its packaging process, rather than simply replacing the boxes. It may be helpful to e-commerce audit, which enables you to check whether your sales, packaging and dispatch model gives rise to environmental obligations and packaging-related risks.

What does the 50% limit on empty space in a parcel mean?

The 50% limit on empty space means that, in bulk, transport and e-commerce packaging, the ratio of empty space to the total volume of the packaging should not exceed 50%. In practice, at least half of the parcel’s volume should be genuinely accounted for by the product and its retail packaging, rather than by air or filler material.

The EUR-Lex summary of the PPWR states that, by 2030, economic operators filling bulk, transport and e-commerce packaging must ensure that the empty space does not exceed 50%.

The simplest example:

The shop dispatches the cosmetic product in individual 1-litre containers. If it uses a 4-litre cardboard box, a significant portion of the parcel is empty. Even if the space is filled with paper or air cushions, from a PPWR perspective this does not solve the problem, as the filler material can also be treated as empty space.

The 50% requirement for empty space is not aimed at protecting the product, but at preventing „air” from being shipped in excessively large parcels.

Do fillers count as empty space?

Yes. In the context of the PPWR, it cannot be assumed that filling empty space with paper, bubble wrap, foam or air cushions automatically improves compliance. The text of the regulation states that the space occupied by filling materials, such as paper cuttings, air cushions, bubble wrap, sponges, foam, wood wool, polystyrene or polystyrene chips, is treated as empty space.

This is very important for e-commerce warehouses. Until now, some shops have solved the problem of poorly-fitting boxes by adding more packing material. PPWR changes this approach: the parcel should be well-suited to the product right from the stage of selecting the packaging format.

In practice, this means that optimisation is not about asking „what should we use to fill the empty space?”, but „how can we choose packaging that minimises empty space?”.

Since when has the limit on empty space been a factor in e-commerce?

The PPWR entered into force on 11 February 2025 and will, in principle, apply from 12 August 2026. The European Commission confirms these dates for Regulation (EU) 2025/40.

The 50% limit on empty space for bulk, transport and e-commerce packaging is a milestone that shops should plan for with a view to 2030. However, this does not mean that action can be postponed until the end of 2029. Changing the packaging process requires testing, data collection, ordering new carton formats, warehouse staff training and, in many cases, modifications to the WMS or ERP system.

For e-commerce, 2030 is the compliance deadline, but the years 2026–2029 should be a period of restructuring the packaging process.

How do you calculate the empty space in a parcel?

In practice, the shop should compare the total volume of the shipping package with the volume of the product or retail packaging contained within it. The PPWR defines empty space as the difference between the total volume of the collective, transport or e-commerce packaging and the volume of the retail packaging contained within it.

A simple operational formula:

Empty space = volume of the shipping packaging – volume of the product or retail packaging

Proportion of empty space = empty space / total volume of the shipping package × 100%

Example:

The box has a volume of 10 litres. The products, together with their individual packaging, take up 4 litres. The empty space amounts to 6 litres, which is 60% of the parcel’s volume. Such a parcel exceeds the 50% limit.

Second example:

The box has a volume of 10 litres. The products take up 6 litres. The empty space is 4 litres, or 40%. This level is below the limit of 50%, provided the packaging still protects the product adequately.

In practice, shops should not count each parcel by hand. A better solution is to create a matrix: product categories, typical order combinations, assigned box sizes and the maximum permissible fill level.

Why is the 50% limit on empty space an operational issue, rather than just a legal one?

For many online shops, the biggest challenge will not be understanding the regulation, but adapting their day-to-day warehouse operations. Packing is carried out under time pressure, particularly during peak sales periods. Staff often choose the box closest to their workstation, rather than the one that best suits the product.

The PPWR requires several areas to be brought into order:

– the number of available carton sizes,
– guidelines for selecting packaging for an order,
– how products are measured,
– data in the warehouse management system,
– order fulfilment procedures,
– types of fillers,
– training for packing staff,
– working with courier companies and fulfilment providers.

The biggest mistake is to treat PPWR as a task for the legal department. In e-commerce, it is primarily a matter for the warehouse, procurement, logistics and product data teams.

How can the packaging process be adapted to the PPWR?

The process of bringing e-commerce into line with the PPWR should be carried out in stages. A haphazard changeover of packaging can increase costs and disrupt warehouse operations. A data-driven analysis yields better results.

1. Carry out an audit of the parcels sent by the shop

The first step is to check what the actual parcels look like as they leave the warehouse. A list of the boxes being purchased isn’t enough. You need to see which products go into which boxes and how much empty space is left in practice.

It is worth considering:

– the 20–50 most frequently dispatched products,
– standard shopping trolleys,
– seasonal orders,
– fragile products and those requiring cushioning,
– products that are light but bulky,
– multi-product orders,
– returns and reuse of packaging.

If a shop sells products in several markets, the audit should also cover cross-border obligations. EKOPRO explains that in e-commerce, BDO most commonly applies to companies that pack orders into boxes, envelopes, cling film, tape, labels or packing materials and dispatch the packaged product to the customer.

2. Limit the number of „all-purpose” cardboard boxes

Standard-size cardboard boxes are convenient for the warehouse, but they often leave too much empty space. The shop uses a single box size for many orders, as this simplifies order picking, the purchase of packaging and the organisation of the packing area. The problem arises when small items are regularly packed into large boxes.

A better solution is a range of a few well-chosen packaging sizes. There’s no need for dozens of them. Often, 5–8 sizes of boxes and envelopes are enough to cover most orders without leaving too much empty space.

3. Assign a packaging format to a product or shopping basket

The shop should establish packaging rules. Recommended packaging can be assigned to individual products. For shopping baskets containing multiple products, it is worth establishing rules for combining products into a single parcel.

Example:

– a small cosmetic item: a cardboard envelope or a small cardboard box,
– textiles: packaging tailored to the volume, without excess filler material,
– glass: a smaller box with a controlled cushioning zone,
– electronics: packaging tailored to protection and warranty requirements,
– promotional sets: a separate standard packaging unit, rather than just a larger box chosen at random.

Packing rules should be visible to warehouse staff and integrated with the order management system if the company uses a WMS, ERP or fulfilment tool.

4. Measure the products, not just the boxes

Many shops provide information on a product’s weight, but not on its dimensions. With PPWR, weight alone is not enough. Two products may weigh the same, but take up completely different volumes.

The minimum product data required for e-commerce is:

– length,
– width,
– height,
– weight,
– type of unit packaging,
– susceptibility to damage,
– the option to combine with other products,
– requirements relating to the transport position.

Without product dimensions, the shop is unable to automatically select packaging in accordance with the PPWR.

5. Limit the use of fillers to their protective function

Filler material should protect the product, not mask an unsuitable box. If a parcel requires a large amount of paper, film or air cushions, the problem is usually the size of the packaging.

In practice, it is worth distinguishing between two types of fillers:

– shock-absorbing fillers, required to protect the product,
– bulk fillers, used mainly to prevent the product from „rattling about” in a box that is too large.

PPWR is particularly effective in the latter case.

6. Test the packaging before making any changes

Reducing the size of the package must not result in an increase in damage. The packaging should be smaller, but still functional. Therefore, before introducing new formats, it is necessary to test the packaging’s resistance to crushing, drops, product movement and transport conditions.

Good tests include:

– trial packaging,
– shake test,
– drop test,
– stacking test,
– analysis of complaints,
– an analysis of damaged returns,
– a comparison of transport costs before and after the change.

7. Collect data for BDO, EPR and PPWR in parallel

An online shop should link the issue of empty space to its packaging records. If a company changes its cardboard boxes, the weight of its packaging or the types of materials used, this also affects the data required for environmental reporting.

In Poland, BDO is relevant, whilst for cross-border sales, the EPR/ROP systems in other countries are also relevant. The EKOPRO guide on ROP/EPR for e-commerce states that in Germany, any commercial entity distributing packaged goods must register with LUCID, whilst importers and online/mail-order companies may be treated as „producers”.

Therefore, optimising packaging should go hand in hand with an analysis of the requirements in EU markets. In this regard, it is helpful to compliance with packaging requirements in EU markets and LUCID audit for companies shipping products to Germany.

What should you avoid when adapting your e-commerce site to the PPWR?

The worst measures are those that make the process look better on paper but do not change the actual parcel.

The first mistake is to replace the plastic filler with paper without reducing the size of the box. Such a change may look better from a marketing perspective, but it does not solve the problem of empty space.

The second mistake is to buy one smaller box and leave the rest of the process unchanged. If the warehouse staff do not have clear guidelines, they will continue to choose packaging at random.

The third mistake is failing to take fragile products into account. The limit on empty space does not remove the obligation to protect the product. If restricting the amount of filler material leads to damage, the shop will see an increase in waste due to returns, complaints and reshipments.

The fourth mistake is the lack of dimensional data in the system. Without product and packaging dimensions, the company cannot calculate the empty space in a repeatable manner.

The fifth mistake is separating the PPWR from the BDO and EPR. A shop may be able to optimise its packaging, but may still have outstanding registration, reporting or accounting obligations.

How to pack in accordance with the PPWR? A practical checklist for online shops

An online shop should draw up a packing checklist in accordance with the PPWR. Ideally, it should be used by the purchasing, warehouse and logistics departments, as well as those responsible for compliance.

PPWR checklist for e-commerce

Do we know the dimensions and weight of our best-selling products?
Do we have a list of all our shipping packaging materials: boxes, envelopes, cling film, tape, labels and packing materials?
Can we assign a packaging format to a product or order type?
Do we know which parcels exceed 50% of empty space?
Does the filler serve a protective purpose, or does it simply fill out a box that’s too big?
Do we have documentation from our packaging suppliers?
Do we know the weights of the packaging required for BDO or foreign systems?
Have sales to Germany, France, the Czech Republic or other EU countries been checked for EPR compliance?
Do warehouse staff have guidelines on how to choose packaging?
Have we tested the new formats for defects and complaints?

If the answer „no” appears for several points, the shop should carry out PPWR audit or combine it with environmental audit, in order to check not only the parcels themselves, but also the documentation, responsibilities and data flow.

Example: a beauty shop before and after PPWR optimisation

The beauty shop ships creams, serums, gift sets and accessories. Before optimisation, it uses three different box sizes. The smallest box is often too big for individual products, so the warehouse adds paper padding.

After analysis, it turns out that 60% orders consist of small items that can be dispatched in cardboard envelopes or smaller boxes. The shop is introducing two additional packaging formats, analysing the 100 best-selling SKUs and creating packaging rules.

Result:

– less empty space,
– fewer fillers,
– lighter packaging,
– simpler stock records,
– a lower risk of exceeding the PPWR limit,
– a better customer experience,
– potentially lower transport costs.

The key takeaway: the shop did not need to change its entire business model. It simply had to organise its data, packaging formats and stock management decisions.

PPWR, fulfilment and marketplaces – who is responsible for the parcel?

In e-commerce, responsibility for packaging often depends on the sales model. The situation is different for a shop with its own warehouse, for a company using a fulfilment service, and for a seller operating via a marketplace.

The key questions are:

– who buys shipping packaging,
– who physically packs the product,
– who decides on the parcel size,
– whoever places the product in its packaging on the market,
– who has data on the weights of the packaging,
– who is responsible for BDO or EPR settlements.

If a shop uses a fulfilment provider, it should check the contract and the actual flow of data. The provider may pack orders, but this does not always mean that it assumes all the seller’s environmental responsibilities.

In practice, it is worth checking whether the fulfilment provider supplies reports on packaging used, its weight, the type of material and the number of parcels. Without this data, the shop may have difficulty demonstrating compliance.

PPWR and BDO in e-commerce

BDO and PPWR are different systems, but in e-commerce they both relate to the same area: packaging. PPWR focuses on design, empty space, recyclability and minimising packaging. BDO covers, amongst other things, registration, record-keeping, reporting and obligations relating to the placing on the market of packaging or products in packaging.

An online shop should verify the BDO if:

– packs goods into shipping boxes,
– uses envelopes, cling film, tape and packing materials,
– imports products in packaging,
– sells under its own brand,
– adds its own packaging to the product,
– handles exports.

The guide provides further details on this area BDO in e-commerce and online shops. If a shop sells its own-brand products or imports goods, it is also worth looking into the topic BDO for importers and private label e-commerce.

PPWR and sales to Germany and LUCID

For online shops selling to Germany, simply preparing a parcel in accordance with the PPWR is not enough. Germany has its own VerpackG/LUCID system, which requires registration and participation in the scheme for certain types of packaging.

If a shop ships goods to German customers, it should check:

– is it required to register with LUCID,
– whether he has entered into a contract with the dual system,
– does it report the correct weights of the packaging,
– does it include shipping packaging,
– whether the marketplace imposes any additional requirements.

In this area, it’s worth making use of the guide Registration in the German LUCID system and LUCID audit.

Are smaller parcels always better?

Not always. PPWR does not require the package to be the smallest possible at all costs. It requires the packaging to be proportionate and functional. The product must be protected against damage, moisture, crushing, shifting and transport conditions.

A parcel that is too small may lead to an increase in the number of complaints. A damaged product is not only a financial loss, but also generates additional waste: returns, new packaging, re-dispatch and the disposal of damaged goods.

Packaging in accordance with the PPWR strikes a balance between minimising packaging and ensuring product safety.

A good optimisation process should therefore combine:

– an analysis of empty space,
– protective tests,
– information on complaints,
– transport costs,
– BDO/EPR requirements,
– the recyclability of materials,
– the warehouse’s actual operational capacity.

How can EKOPRO help online shops?

Bringing an e-commerce business into line with the PPWR requires a combination of legal, environmental and operational expertise. The online shop must review not only the content of the regulations, but also the actual packaging process, the choice of packaging, billing data and obligations in EU markets.

EKOPRO can support your company by, amongst other things:

– an analysis of PPWR obligations for e-commerce,
– a review of the packaging process,
– an assessment of the empty space in parcels,
– checking dispatch packaging,
– an analysis of BDO’s responsibilities,
– support for EPR/ROP systems in the EU,
– LUCID audit for sales to Germany,
– environmental audits and technical consultancy.

A good place to start is e-commerce audit or PPWR audit. If a company needs more comprehensive support, it is worth making use of comprehensive environmental advice, which enables PPWR, BDO, EPR, LUCID and the packaging strategy to be combined into a single action plan.

Frequently asked questions

Does the PPWR apply to online shops?

Yes. The PPWR applies to e-commerce if a shop uses shipping packaging such as cardboard boxes, envelopes, plastic film, tape, labels and packing materials. Of particular importance are the limits on empty space in parcels and the requirements regarding the minimisation of packaging.

What does the 50% limit on empty space in a parcel mean?

The limit means that, in e-commerce, transport and bulk packaging, the void space should not exceed 50% of the total volume of the package. The space occupied by fillers may also be treated as void space.

Does paper filler solve the PPWR problem?

Not always. If the paper filler simply takes up space in a box that is too large, it does not solve the problem of empty space. A better solution is to choose a smaller box for the product.

When does an e-commerce business need to start preparing for the empty space limit?

The PPWR will generally come into force on 12 August 2026, and the 50% limit on empty space is a key milestone planned for 2030. Online retailers should use the period 2026–2029 to adapt their packaging processes.

How can an online shop check whether it is packaging its goods in accordance with the PPWR?

It’s best to start by auditing your parcels: check the dimensions of the products, the sizes of the boxes, the amount of packing material, typical shopping baskets and packaging details. Next, it’s worth creating rules for selecting packaging for specific products or order categories.

Does PPWR replace BDO or LUCID?

No. PPWR does not replace BDO or foreign EPR schemes, such as LUCID in Germany. An online shop should analyse PPWR in parallel with its registration, reporting and settlement obligations in Poland and on foreign markets.

Optimise your packaging processes with EKOPRO

The 50% limit on empty space in parcels is not just a change in the regulations. It is a signal that e-commerce must move away from quick, intuitive packing towards a process based on data, documentation and environmental compliance.

If you want to check whether your online shop is packaging its goods in accordance with the PPWR guidelines, please use e-commerce audit or PPWR audit. You can also choose EKOPRO environmental consultancy and draw up a comprehensive strategy for packaging, BDO, EPR and overseas sales.

Go to the tab Contact Eko-Pro and describe what your current packing process is like.