Yes. The EU’s Packaging and Packaging Waste Regulation (PPWR) covers e-commerce and shipping packaging placed on the EU market, including packaging manufactured in China. The branded product box, protective insert, outer carton or mailer, and protective filling can all fall within its scope.

Regulation (EU) 2025/40 has generally applied since 12 August 2026, but its empty-space limit and reuse targets have separate dates and exceptions. For a brand selling online, the useful starting point is the complete packed order: how its layers protect and present the product, where each layer is added, and which business carries the relevant responsibility.

Which parts of an online order are covered?

Consider a skincare gift set assembled in China for an EU online customer. The jars sit in a fitted insert inside a branded box, with an outer carton and cushioning for delivery. The jars themselves are packaging, and so are the surrounding layers that contain, protect, handle, deliver or present the products.

These categories follow function. A logo alone does not turn a courier carton into sales packaging; a product box can, however, be designed to perform both sales and delivery functions. That distinction matters because some later requirements treat those uses differently.

At CMIC, we can review the product box, insert and shipper together, including materials added by a fulfilment partner. This helps establish where the product needs support and where packaging layers duplicate one another. It also brings the arrival experience into the design: which surfaces may show normal handling, and which need to remain presentable when the customer opens the parcel.

Who is responsible for the packaging?

PPWR assigns different duties to different supply-chain roles. Its terms manufacturer and producer describe different responsibilities, and one business can hold more than one role.

• Packaging conformity: the legal manufacturer assesses the applicable requirements, prepares technical documentation and draws up an EU declaration of conformity. A brand commissioning packaging or packaged products under its own name generally holds this role, even when a separate factory makes the packaging. Specific micro-enterprise provisions can assign manufacturer duties to an EU-based supplier. EU importers have their own conformity and documentation checks.
• Packaging waste: the producer has extended producer responsibility (EPR) obligations concerning packaging waste, with registration and reporting arrangements in the relevant Member State. Producer status follows rules on first supply, distance sales and certain unpacking activities.
• Filling and handling: Article 24 places its empty-space obligation on the operator filling the packaging. Fulfilment providers must also ensure that warehousing, packing and dispatch do not jeopardise packaging conformity.

Direct shipping from China to an EU customer

Take a seller established outside the EU that first supplies a packaged order directly to an end user in France, with the parcel packed and dispatched from China. That seller falls within the producer definition in France under the distance-sales rules. The manufacturer role and any EU importer’s role must be identified separately. Manufacturing origin, the seller’s place of establishment and the delivery destination are three distinct facts; the Chinese factory’s address alone cannot settle them.

Dispatch through an EU fulfilment centre

The same seller could send stock in bulk to a French fulfilment centre. The centre might remove master cartons, retain the product boxes and add new shipping cartons and filling. Each packaging stream remains relevant, including packaging that becomes waste at the warehouse. An EU business unpacking goods without being the end user may be the producer for the removed packaging where no other business qualifies under the preceding producer-definition rules.

For the outgoing parcel, the supplier that first makes transport packaging available domestically may be its EPR producer, while the fulfilment centre is the operator filling it. Deliveries into another Member State require a further check of the destination’s arrangements. A useful agreement with the fulfilment partner therefore identifies who supplies each packaging type, who provides its material and weight data, and who handles the relevant reporting.

What applies now, and what comes later?

As of September 2026, the general application date has passed. Packaging newly placed on the EU market needs conformity work against the requirements already applicable to it, including relevant substance requirements, supported by the manufacturer’s technical documentation and declaration. Relevant national EPR arrangements also need attention now. The later deadlines below concern specific packaging requirements.

The new harmonised material-composition labels have a separate 2028-or-later timetable under Article 12, linked to implementing acts. E-commerce packaging is expressly included even though other transport packaging is generally exempt from that particular labelling obligation. A consumer’s delivery carton and a bulk warehouse carton therefore need separate labelling decisions.

What the 50% empty-space rule means for a parcel

Article 24 defines empty space by comparing the total volume of the outer packaging with the volume of the sales packaging contained inside it. For a parcel containing retail boxes, the basic relationship is:

Empty-space ratio = (outer-pack volume − volume of sales packaging inside) ÷ outer-pack volume × 100.

Paper cuttings, air cushions, bubble wrap and foam filling all count as empty space. Replacing plastic filling with paper may change the material choice, but it does not improve this ratio. Reducing the gap around the contained sales packs changes the geometry.

For an early design illustration using rectangular volumes, take a sales box measuring 200 × 150 × 80 mm: it occupies 2.40 litres. A shipping cavity measuring 250 × 200 × 130 mm holds 6.50 litres, giving approximately 63% empty space in this simplified comparison. Reducing the cavity to 230 × 180 × 110 mm brings that figure to approximately 47%. These internal dimensions illustrate the geometry; the regulatory calculation must follow the applicable implementing methodology.

That change also reduces clearance around a centred sales box from 25 mm to 15 mm on each face. The cushioning must work within the smaller gap. For a fragile product, the lower percentage is useful only if the complete packed order still provides adequate protection.

The regulation requires the Commission’s calculation methodology to account for circumstances including irregular shapes, mixed orders, liquids, fragile products and shipping-label space. It sets 12 February 2028 as the deadline for adopting that methodology. Both packaging levels also deserve attention: a closely fitted shipper can still contain an unnecessarily large product box, which has its own minimisation requirements.

Do shipping boxes have to become reusable?

Article 29(1) sets a 40% reuse target from 1 January 2030 for listed transport-packaging formats used within the EU, including for e-commerce, subject to exemptions. Cardboard boxes are expressly exempt from Article 29(1)–(3). An ordinary corrugated shipping box therefore does not need to be replaced with a returnable box solely because of those targets. Its other applicable requirements remain.

This exception is specific to cardboard boxes. Other formats, such as plastic transit crates and pallets, need their own assessment, including the operator and route. Stricter reuse provisions apply to certain movements between business sites and deliveries between businesses within the same Member State, subject to the relevant exemptions.

Article 24 separately exempts reusable packaging within a reuse system from the 50% empty-space cap. That requires an operating arrangement for repeated packaging use, including collection and appropriate reconditioning. A customer keeping a gift box for storage does not establish such a system. A returnable shipping pack needs its return route, inspection and next use developed alongside its physical construction.

Choose the shipping format around protection and presentation

Use the product box as the shipper where the design supports it

Article 24(5) exempts sales packaging used as e-commerce packaging from the 50% cap. Sales-packaging minimisation requirements still matter, including Article 10. The design opportunity is a single box that presents the product and provides the protection and closure needed for delivery.

A printed corrugated box with a secure closure and fitted insert can be a useful route for suitable compact products. Consider where the shipping label goes, how the exterior will look after handling and how the customer opens it. For a gift set, scuffs on an outer shipping carton may be acceptable; scuffs across the wrapped lid of its presentation box may spoil the intended first impression. A closely fitting protective outer can earn its place when that presentation needs to survive the journey.

Match outer cartons to real orders

Where two layers serve useful functions, size them together. Frequent single-item orders, multi-item orders and gift bundles may need different formats. We can develop product-box and insert dimensions alongside the shipper, checking whether a small change in the retail pack would force the whole order into a larger carton.

For EU fulfilment, the packing site needs the approved arrangement and a clear way to select among available boxes. Agreeing alternatives for stockouts and unusual combinations helps keep everyday dispatch consistent with the sampled design. This is where a carefully developed pack becomes a repeatable delivery format.

Establish how the smaller pack protects the product

An insert should restrain the product at suitable points and keep separate pieces from colliding. Compare complete packed samples for fit, closure, movement and appearance, then arrange appropriate drop, vibration or compression testing for the intended distribution route. Annex IV recognises product protection and logistics in the minimisation assessment, and calls for the reasons preventing further reduction to be documented.

Material changes belong in the same review. Paperboard, moulded pulp and foam behave differently under a product’s weight, and a replacement insert may need different clearances. Labels, coatings, adhesives and attached components also influence recycling assessments. The material review should describe the finished construction, including those details.

CMIC can coordinate structural development, sampling and project-specific testing, and help assemble the agreed dimensions, materials, component weights and supporting records. Those details give the business handling conformity assessment a defined packaging version to work with. They also give the fulfilment team a pack it can reproduce; a later change of insert, mailer or filling should remain visible in that specification.

For an EU e-commerce project, our EU packaging solutions can start with your product details, typical order combinations and the direct-shipping or EU-fulfilment route. From there, we can compare packaging options that preserve the intended presentation, provide the necessary protection and make efficient use of material and space across the whole order.