PPWR and Fulfilment: These obligations apply to online retailers and their logistics partners

As at 13 August 2026 – this article is updated on an ongoing basis, as the design of PPWRs is still evolving.

The EU Packaging Regulation (PPWR) has been in force since 12 August 2026. What many online retailers are not yet aware of is that, without a valid registration in the LUCID packaging register, your fulfilment service provider will no longer be permitted to dispatch your goods. An immediate ban on sales will apply – and fines of up to 200,000 euros per individual case are possible. Anyone operating in the mail-order sector across Europe should therefore be fully aware of which obligations lie with them and which with their fulfilment partner.

What is the PPWR?

The Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) replaces the old EU Packaging Directive from 1994. The key difference is that, as a regulation, it applies directly and uniformly across all 27 Member States – rather than as a patchwork of national implementations. It entered into force on 11 February 2025 and, following an 18-month transition period, has been binding since 12 August 2026. The aim is to reduce packaging waste across the EU and to ensure that all packaging is recyclable by 2030.

You can find detailed background information on the PPWR’s objectives and timetable at the European Commission website.

Who is responsible for what? Retailers vs. fulfilment service providers

The PPWR allocates responsibility along the supply chain – and this is precisely where most misunderstandings arise in practice.

Your role as an online retailer: the distributor

As a retailer, you are financially responsible for the packaging in which your goods are delivered to the end customer – regardless of whether you pack them yourself or use a fulfilment service provider. In practical terms, this means:

Registration with the LUCID Packaging Register
System Participation Agreement with a dual system
Accurate reporting of your packaging volumes
Evidence that your packaging meets the PPWR compliance requirements

These obligations cannot be delegated – not even to your fulfilment partner.

The role of the fulfilment service provider: the gatekeeper

Fulfillment service providers are expressly recognised by the PPWR as independent economic operators. This means:

Fulfillment service providers must check whether customers are registered in the LUCID packaging register and are complying with their obligation to participate in the scheme.
If a customer is not registered, the fulfilment provider is not permitted to dispatch goods to them – a statutory ban on distribution applies.

This testing requirement has been enshrined in Germany’s Packaging Act since 2022 and is now being made mandatory across the EU under the PPWR.

New: Clarification regarding producers vs. manufacturers (13 August 2026)

Shortly after the deadline, the European Commission clarified its FAQ document and defined the roles between Producer and Manufacturer more clearly separated within a single package:

Producer is someone who designs packaging under their own name or brand.
Manufacturer is the person who first makes packaging or packaged products available in an EU Member State.

In practice, this means that, in the case of standard, plain shipping boxes, the box manufacturer is generally regarded as the producer – not the retailer. Simply unfolding a box or sticking a dispatch label on it does not make you the producer. The situation is different for customised or brand-specific packaging: in these cases, you, as the retailer, remain the producer and are subject to the corresponding obligations.

Important: This is not a blanket exemption. The obligations do not disappear; in some cases, they are simply shifted to another point in the supply chain. You should therefore check specifically which packaging items in your portfolio you are responsible for – and which ones your supplier is responsible for.

Registration by country: No EU-wide centralised solution

One point often gets overlooked in the discussion about deadlines and fines: the PPWR does not establish a central, EU-wide registration system. If you dispatch goods to several EU countries, you must still register separately in each individual country with the relevant authority or Producer Responsibility Organisation (PRO) – and also report your packaging volumes there and pay the annual recycling fees. The amount of these fees varies considerably from country to country, as do the relevant registers and number formats (e.g. LUCID in Germany, SYDEREP in France, and the RPP register in Spain).

Another point concerns traders who do not have their own branch in the country in question: anyone who places packaging on the market in an EU country in which they do not have their registered office must appoint a Authorised Representative . As the exact procedures for this have not yet been standardised across the EU, it is worth liaising with the relevant PRO or a specialist service partner at an early stage – particularly as administrative lead times for new registrations can take several weeks.

Specific changes from August 2026

Void ratio: No more air in the box

From 1 January 2030, the void space in consolidation, transport and e-commerce packaging must not exceed 50 % of the total volume (Article 10 PPWR). Empty space includes not only air but also filling materials such as air cushions or paper padding. Even though the deadline is not until 2030, a tiered range of box sizes cannot be established overnight. Those who start optimising now will also reduce their postage costs.

PFAS limit values: already in force

New limit values for PFAS in food packaging have been in force since 12 August 2026: a maximum of 25 ppb per individual substance and 250 ppb in total. This is particularly relevant for mail-order businesses selling food or cosmetics.

Declaration of Conformity

With immediate effect, you must be able to provide technical documentation and an EU declaration of conformity for each type of packaging. If in any doubt, your fulfilment service provider will request these from you before continuing to dispatch goods on your behalf.

Recyclability classes A–C

From 2030, only packaging in classes A, B or C may be placed on the market. According to the regulation, there are no Classes D or E: packaging below Class C is simply deemed technically non-recyclable and may therefore no longer be placed on the market. From 2038, the requirement will be further tightened – at which point at least Class B will be required.

What this means for your choice of fulfilment partner

As fulfilment service providers are now legally obliged to carry out checks, working with the right 3PL partner is becoming a genuine compliance issue – not just an operational one. When selecting or evaluating a fulfilment partner, it is worth considering:

Verification process: Does the partner actively check their customers’ LUCID registration before dispatching goods?
Flexibility in box sizes: Does the partner have a range of cardboard boxes in different sizes to ensure that the void space ratio is maintained?
Documentation: Can your partner break down packaging quantities by material type in a way that is traceable for the purposes of your reporting obligations?
Transparency regarding responsibilities: Does your partner make it clear when they are acting as the creator and when you are?

These criteria are complex – particularly when you are comparing several partners across different European markets. This is precisely where Warehousing1 helps retailers to compare logistics partners not only on the basis of price and delivery times, but also in terms of their level of compliance.

Checklist: 5 steps for online retailers

Check and update your LUCID registration. It’s free and takes about 15–20 minutes at lucid.verpackungsregister.org.
Analyse the packaging portfolio. What materials, sizes and quantities do you use? Where is there scope for improvement?
Clarify compliance requirements with suppliers. Obtain the technical documentation and the declaration of conformity.
Check system participation. Do the quantities reported to LUCID and the dual system match?
Sort packaging according to the producer’s role. Standard, plain packaging versus customised packaging – who is responsible in each case?

FAQ on PPWR in Fulfilment

Who is the manufacturer of a standard, plain shipping box?
Usually the box manufacturer – not the retailer, provided the box is simply fitted with a dispatch label.

Does the PPWR also apply to B2B shipments?
Yes. The PPWR also applies in full to B2B packaging, including transport, industrial and commercial packaging.

What happens if I’m not registered with LUCID?
Your fulfilment service provider will then no longer be permitted to dispatch goods on your behalf. Furthermore, under the German Packaging Act (Section 36 VerpackG), fines of up to 200,000 euros per individual case may be imposed. The PPWR itself does not yet specify any specific fine amounts across the EU – Member States must first lay down their national rules on penalties by 12 February 2027. In the meantime, existing national regulations, such as the German Packaging Act, continue to apply unchanged.

As a small business owner, do I have to take part as well?
In principle, yes – the PPWR and the LUCID registration requirements do not specify a general de minimis threshold for online retailers. Please check with your dual system on a case-by-case basis to determine which volume thresholds apply to your reporting obligations.

Will there be a transitional arrangement or a moratorium?
The German E-commerce and Mail Order Association (BEVH) has called for a moratorium. No decision has yet been made on this matter – the obligations have remained in force unchanged since 12 August 2026.

Conclusion

The PPWR not only changes the way packaging can be designed, but also the way retailers and fulfilment service providers must work together. Those who take action now will not only avoid a sales ban, but can also reduce postage costs by optimising packaging sizes.

Are you currently comparing fulfilment partners in Europe and would like to know how they deal with the PPWR? Warehousing1 helps you compare logistics partners not only on the basis of price, but also according to compliance criteria such as LUCID verification and packaging optimisation.

Enquire now

Please note: This article does not constitute individual legal advice and does not represent a statement by Warehousing1 as to whether specific packaging or processes comply with the PPWR. The basis for a legally sound assessment is always the text of Regulation (EU) 2025/40 and the European Commission’s current guidelines. The retailer, as the distributor, remains responsible for complying with all requirements under Extended Producer Responsibility (EPR) – in every country to which goods are sold. In case of uncertainty, it is advisable to seek advice from a specialist law firm or a compliance service provider.