Packaging regulation and online sales: the obligations of those who ship
Under Regulation (EU) 2025/40, the box used to ship the product is packaging with its own definition, and whoever places it on the market under its own name answers for it as manufacturer. The documentary obligations apply from 12 August 2026; the format restrictions arrive from 2030.
- Legal reference
- Arts. 24 and 12
- Last updated
- Official text
- Regulation (EU) 2025/40
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The scope
Article 3 defines e-commerce packaging as "transport packaging used for the delivery of products to the end user in the context of online sales or other distance-selling channels".
The census must cover the box, the tape, the filler material and the label. Each has materials and substances that must be documented.
What is already owed
The qualification of the role. Whoever places packaging on the market under its own name or trademark is considered a manufacturer under Article 21, even when the box is bought from a third party and shipping is entrusted to a logistics operator.
Technical documentation and the EU declaration of conformity, for each type of packaging, under Annexes VII and VIII.
The substance limits: sum of lead, cadmium, mercury and hexavalent chromium not exceeding 100 mg/kg, and PFAS limits when the packaging is intended for contact with food.
What comes later
| Date | Requirement | Reference |
|---|---|---|
| 12 August 2028, or 24 months after the implementing acts if later | Harmonised labelling of materials. The exemption for transport packaging does not apply to e-commerce packaging | Art. 12(1) |
| 1 January 2030, or 3 years after the implementing act if later | The proportion of empty space does not exceed 50% in grouped, transport and e-commerce packaging | Art. 24 |
| 1 January 2030 | At least 40% of transport packaging used in the Union, including e-commerce packaging, is reusable within a reuse system | Art. 29(1) |
| 1 January 2040 | Operators work towards bringing that same share to 70% | Art. 29(1) |
The methodology for calculating empty space will be set out in an implementing act, for which the regulation gives the Commission a deadline of 12 February 2028. It will need to account for irregularly shaped products, easily damaged contents, liquids, and the minimum space needed for shipping labels.
What is worth measuring now
The ratio between the volume of the product and the volume of the box, format by format. That figure shows how many formats will need revising once the methodology is published, and it is the same analysis Article 10 requires for minimisation, whose compliance is demonstrated in the technical documentation.
References
Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, in OJ L of 22 January 2025.
- Art. 3 · Definition of e-commerce packaging
- Art. 10 · Minimisation of packaging
- Art. 12 · Labelling of packaging
- Art. 21 · Manufacturer obligations applied to importers and distributors
- Art. 24 · Obligation on excessive packaging
- Art. 29 · Reuse targets
- Annexes VII and VIII · Technical documentation and EU declaration of conformity
Official text: http://data.europa.eu/eli/reg/2025/40/oj