Webshops are the group the PPWR hits hardest and that is least prepared for it. Not because the rules are stricter, but because a webshop usually places three kinds of packaging on the market at once — product packaging, shipping packaging and void fill — and plays a different role for each of the three.
Four questions determine what applies to you.
1. Are you the producer?
If you sell a product in your own product packaging, then you are the producer. All PPWR obligations lie with you: substance standards, traceability, declaration of conformity, registration with Verpact.
If you sell via a marketplace such as Bol.com or Amazon, that changes nothing. The marketplace does not take over your producer role. See roles under the PPWR.
Is your logo on the box? Then you are also the manufacturer of that box, even if someone else prints it.
From 12 August 2026 it also applies that whoever produces shipping, e-commerce or service packaging is its manufacturer — and, on sale in the Netherlands, thereby also the producer. Declaration for the period from 12 August, after the end of the calendar year.
2. Who is the producer in fulfilment?
This is where the grey area arises.
A fulfilment service provider can itself be designated as the producer — namely when no other party fills that role. This comes into play with sellers from outside the EU who supply European customers directly without an importer in the EU.
You are deemed to be the producer if you handle at least two of these services: storage, unpacking, repackaging, addressing, shipping.
If you sell via fulfilment by the marketplace, you remain responsible for the packaging around your product itself. The shipping box is theirs.
What happens if your product sits too loosely in their standard box and the empty-space ratio is exceeded has not been crystallised. The regulation designates no party for that case. Count on marketplaces tightening their own compliance requirements before the legislator provides clarity — and on you simply being told those requirements, without being able to negotiate over them.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
3. What must be arranged by 12 August 2026?
Declaration of conformity for every packaging type you place on the market under your own name.
Name, postal address and means of contact on the packaging or via QR, plus a type, batch or serial number. For a webshop with forty SKUs this is the work you spend the most time on.
PFAS ban if you sell food. Pizza boxes, baking paper, grease-resistant coatings. If you import from a third country, you must be able to show a test report — a “PFAS-free” declaration from your supplier without an underlying report is not proof. See PFAS in packaging.
Heavy metals below 100 mg/kg.
Registration with Verpact. And if you ship to German consumers, then LUCID — from the first shipment, with no threshold. See Netherlands and Germany.
Minimisation principle: the packaging is designed for minimum weight and volume for its function. Double walls and false bottoms are banned.
4. What is coming in 2030?
The empty-space ratio of 50%. For e-commerce packaging this is the toughest requirement, and the surprise is in the definition: void fill counts as empty space. Kraft paper, air cushions, foam chips. They fill the box, but not in the sense of the regulation.
The only solution is a smaller box. See empty-space ratio.
Reusable e-commerce packaging. The target is around 40% in 2030 and 70% in 2040. The precise percentages and the question of which shipping packaging falls under it are rendered differently across sources, and implementation runs via delegated acts that do not yet exist. What is settled is the direction.
Important exception: cardboard transport packaging is exempt from the transport reuse target. The paper-fibre recycling route remains permitted. For most webshops that is the escape — provided you use cardboard and not plastic shipping bags.
Recycled-content shares on your plastic packaging, including shipping bags and film: 35% for other plastic. See recycled-content shares.
What you can do now
The order that yields the most per day spent:
- Measure your empty-space ratio. Take your twenty most-shipped orders. Box volume minus product volume. You know within an hour where you stand, and with the outcome you probably lower your shipping costs before the law forces anything.
- Expand your range of box sizes. More formats, less air. This is the only PPWR measure that pays for itself.
- Inventory your packaging types — not your SKUs. Determine per type who the manufacturer is.
- Send your suppliers a request with a deadline: material composition, total fluorine at food contact, recyclate content, the standard on which their recyclability claim rests.
- Check your registration. Does your Verpact declaration still match your role after 12 August? Do you ship to Germany?
- Reserve space on your packaging design for the manufacturer details and the identification number, and later for the harmonised label. See labelling.