EU Regulation 2025/40, the Packaging and Packaging Waste Regulation, becomes mandatory on August 12, 2026. Four requirements are directly relevant to ecommerce brands: an Authorised Representative per member state, a 40% maximum empty space rule for parcels, PFAS restrictions in food-contact packaging, and declared conformity documentation. Online marketplaces handling fulfilment or logistics on behalf of third-party sellers are explicitly named as responsible actors under the regulation.

The Authorised Representative requirement applies to every non-EU brand placing packaging on the EU market. This is a mandatory legal structure, not an optional step, and it must be in place per member state for packaging types. The 40% empty space rule is particularly significant for ecommerce fulfilment: paper fill, bubble wrap, air pillows and void fill all count toward that limit. Standard US over-boxing practices, which often exceed 40% void space, will not pass from August 12.

For food-adjacent products, supplements, and anything in food-safe containers, the PFAS restriction in food-contact packaging above 25 parts per billion applies from the same date. A confirmation from marketplace operators: online platforms handling logistics on behalf of third-party sellers are confirmed responsible actors under PPWR, meaning platforms like Amazon DE have their own compliance verification obligations. Non-compliant sellers face suspension risk, not just fines. From 2027, all packaging must carry QR codes linking to structured environmental data on material composition and recyclability.

• Authorised Representative required per EU member state for non-EU brands placing packaging on the EU market. Mandatory, not optional.
• 40% maximum empty space in ecommerce parcels from August 12. Void fill and over-boxing practices must be reviewed.
• PFAS above 25ppb prohibited in food-contact packaging from August 12. Affects supplements, food products, and food-safe packaging.
• Online marketplaces confirmed as responsible actors where they handle fulfilment. Non-compliant sellers face suspension risk.

PPWR compliance is part of the EU market entry setup Expandly coordinates, alongside VAT registration, EPR registration, and product compliance, so brands arrive at launch with all packaging obligations in place.