PPWR 2026: what changes for your e-commerce packaging

The PPWR hits every e-commerce seller in the Netherlands

On 12 August 2026 the first obligations of the PPWR come into force. The Packaging and Packaging Waste Regulation. European legislation that sets out how packaging has to look from now on. Every package you put on the Dutch market has to meet the new rules. No exception for small sellers. No exception for brands that sell through Bol.com or Amazon.

This is not some distant future. 12 August 2026 is four months away. And it goes further than most e-commerce entrepreneurs think. The PPWR replaces the current European directive from 1994 with a regulation. The difference: a directive is interpreted country by country. A regulation applies directly, in every EU country, in the same way. No room for national exceptions.

If you want to develop sustainable e-commerce packaging that complies with the PPWR, you have to start now. Not next month. Now. The first obligations cover toxic substances, traceability and the definition of who is responsible. After that come stricter requirements for recyclability, empty space and reusability.

In this article I walk through what changes in concrete terms, when it takes effect and what you need to do now.

What is the PPWR and why is it different from what we had

The PPWR stands for Packaging and Packaging Waste Regulation. It is the successor to the European Packaging Directive from 1994. That old directive was exactly that: a directive. Member states could decide for themselves how to fill it in. The Netherlands had Verpact (formerly Afvalfonds Verpakkingen). Germany had its Duales System. France had Citeo. Each one slightly different.

The PPWR changes that. It is a regulation. Direct effect in all 27 EU member states. No more national interpretation. The same rules in the Netherlands as in Germany, Spain and Poland.

Why now? The European Commission has established that packaging waste has only increased over the past 10 years. Despite all the recycling targets. E-commerce is one of the biggest drivers: more orders, more boxes, more filler material, more return packaging. The growth of online shopping has accelerated the problem.

The PPWR tackles three things: which materials you may use (and which you may not), how much air is allowed in your box, and whether your packaging is actually recyclable (not just in theory). Watch the timing: the material requirements start in 2026, the empty-space and recyclability requirements only in 2030.

For e-commerce sellers this is not an abstract policy document. It touches your packaging costs, your logistics, your product design and your relationship with fulfilment partners.

First obligations from 12 August 2026: what changes right away

The PPWR does not come into force all at once. The EU has chosen a phased rollout. But the first phase is four months away. These are the obligations that apply from 12 August 2026.

Ban on toxic substances

The total of lead, cadmium, mercury and chromium VI in packaging may not exceed 100 mg/kg. This is not new as a principle, but enforcement is getting stricter. On top of that come specific PFAS restrictions for food packaging. Think of pizza boxes, baking paper and other food-contact packaging.

For e-commerce brands selling food products on Bol.com or Amazon this is immediately relevant. Your packaging has to be demonstrably free of these substances. Do you have a supplier in China producing your packaging? Then you have to be able to provide proof that it meets the EU standard.

Traceability mandatory

Every package has to carry a type, batch or serial number. This sounds technical, but it means your packaging process has to be traceable. If there is a problem with a specific batch of packaging, you have to be able to find out where it came from and where it went.

Definition of producer changes

This is one of the most underestimated changes. Under the PPWR the definition of "producer" is broadened. Fulfilment services become liable. If you ship through Bol.com FBB and Bol.com packs your products, part of the responsibility shifts. But that does not relieve you as the brand owner of your obligations.

Registration requirement

In the Netherlands a registration requirement already applies through Verpact for producers that put more than 50,000 kg of packaging material on the market. This threshold stays in place for now, but the expectation is that it will be lowered. Smaller brands that currently fall under the threshold have to count on registration in the near future.

Declaration of conformity

Every company that puts packaging on the market has to be able to demonstrate that the packaging meets the rules. That means documentation. Material specifications from your supplier. Test results for toxic substances. Evidence of recyclability.

E-commerce specific rules: empty space, recyclability and Design for Recycling

The PPWR has rules aimed specifically at e-commerce packaging. This is not a side note. The EU has explicitly acknowledged that online orders account for a disproportionate share of packaging waste.

Max 50% empty space (2030)

From 2030 an e-commerce package may contain a maximum of 50% empty space. That sounds like a lot, but take a look at your own orders. How often do you receive a box that is twice the size of the product inside it? Exactly.

This directly affects packaging design. If you currently use three standard box sizes for all your products, you probably have to add more sizes. Or switch to flexible packaging that adapts to the product size.

For sellers shipping through Bol.com FBB this is extra relevant. Bol.com now decides which box your product gets. If that box contains more than 50% air, it will no longer be compliant. The question is who becomes responsible: you as the seller or Bol.com as the fulfilment partner. The PPWR points to the producer. But practice still has to crystallise.

At least 70% recyclability (2030)

From 2030 at least 70% of all packaging has to be genuinely recyclable. Not in theory. Not "technically recyclable." But actually recyclable in the existing infrastructure. That is a big difference.

Many packages are recyclable on paper now, but in practice they get incinerated. Because they consist of multiple materials that cannot be separated from each other. Or because the local recycling infrastructure cannot process them.

Design for Recycling criteria (January 2028)

From January 2028 Design for Recycling criteria become mandatory. These have not been fully published yet. What we know: packaging has to be designed so it is easy to take apart and sort. Mono-materials are preferred over composites.

The KIDV Recyclecheck 2026 has already been updated and gives a preview of what is coming. If you have new packaging designed now, it is wise to take these criteria into account from the start. Adjusting afterwards is more expensive than getting it right immediately.

Uniform EU waste logos (2028)

From 2028 uniform waste logos become mandatory on all packaging in the EU. No more national variants. This means your packaging design has to leave room for these pictograms. Including material composition, recycling or compostability info and, for reusable packaging, a QR code.

What this means in practice for sellers on Bol.com and Amazon

The impact differs per type of seller. But no one escapes it.

Own packaging, own fulfilment

You are the producer. All PPWR obligations rest with you. That means: materials have to meet the toxic-substance standards, packaging has to be traceable, you need a declaration of conformity and you have to register with Verpact.

In time (2030) your packaging also has to meet the empty-space rule and recyclability requirements. Start now by evaluating your current packaging. Which materials do you use? Are they mono-materials or composites? How large is the empty-space ratio?

Fulfilment by Bol (FBB)

With FBB, Bol.com ships your product in their own packaging. The PPWR makes fulfilment services co-responsible. But as the brand owner you remain responsible for your own product packaging (the packaging around your product itself, not the shipping box).

The empty-space rule gets interesting with FBB. Bol.com uses standard box sizes. If your product ends up in a box that is too big, who is then responsible for the non-compliance? This has not yet fully crystallised in the regulation. Bol.com is expected to tighten their FBB packaging requirements in the coming months to be PPWR-compliant. For you as a seller that may mean stricter product-dimension requirements.

Bol.com has so far announced no specific PPWR-related updates for FBB sellers. But given the deadline it is only a matter of time. Do not wait until Bol.com comes out with an update. Make sure your own product packaging is already compliant.

Amazon FBA

Amazon already enforces strict packaging requirements for FBA. The PPWR adds a layer on top of that. Amazon will almost certainly update their packaging guidelines to comply with the EU regulation. If you already sell through Amazon FBA, count on tightened requirements around materials and recyclability.

Private label with a Chinese supplier

This is where it gets complex. You order products and packaging from a supplier in China. That supplier produces for the whole world. The PPWR is an EU rule. It is your responsibility as the importer to make sure the packaging is compliant. That means: requesting test certificates for toxic substances, documenting material specifications and making sure the packaging is recyclable according to EU standards.

Many Chinese suppliers do not know the PPWR yet. Or they say their packaging is "compliant" without proof. Always ask for certificates. Have it tested if you have doubts. The fines for non-compliance go to you, not to your supplier.

Bol.com FBB packaging requirements in relation to the PPWR

Bol.com's Fulfilment by Bol service has its own packaging requirements that stand apart from the PPWR. SSCC labels are mandatory on delivery to the FBB warehouse. Product dimensions and weight have to be entered accurately for the correct box assignment.

With the PPWR, extra requirements come on top of that.

Current FBB requirements: SSCC labels mandatory, correct product dimensions and weight, packaging has to protect the product during transport, standard box sizes from Bol.com.

PPWR requirements that affect FBB: max 50% empty space (2030) in the shipping box, recyclability of both the product packaging and the shipping box, traceability of packaging materials, toxic-substance standards for all packaging layers.

The tension sits in the empty space. Bol.com uses standard box sizes to keep their logistics efficient. But standard box sizes lead by definition to empty space for products that do not fit the format exactly. The PPWR forces Bol.com either to offer more box sizes, or to implement flexible packaging solutions.

For you as a seller: make sure your own product packaging is as compact as possible. The better your product packaging fits, the smaller the shipping box Bol.com chooses and the less empty space remains.

The Bol Growth Reward rewards sellers with a high quality score. Packaging compliance will probably become part of that quality score in time. Sellers who make their packaging PPWR-proof early will be at an advantage.

Concrete checklist: what to do now

The PPWR is being introduced in phases. But waiting until the last phase is not a strategy. This is what you need to do now, in the coming weeks and in the coming months.

Now (April 2026), inventory

1. Map out all your packaging. Product packaging, shipping box, filler material, labels, tapes.
2. Document the materials per packaging component. Which cardboard? Which ink? Which laminate?
3. Ask your supplier for material specifications and test certificates for toxic substances.
4. Measure the empty space in your current shipping boxes. What percentage is product, how much is air?
5. Check your registration with Verpact. Are you registered? Do you need to be?

Before 12 August 2026, first-phase compliance

6. Make sure all packaging stays under 100 mg/kg for lead, cadmium, mercury and chromium VI.
7. If you sell food products: check for PFAS in packaging materials.
8. Implement traceability: type, batch or serial number on every package.
9. Draw up a declaration of conformity for each packaging type.
10. Inform your Chinese suppliers about the PPWR requirements if you import.

Before January 2028, Design for Recycling

11. Evaluate whether your packaging consists of mono-materials or composites.
12. Plan a redesign if your packaging consists of multiple non-separable materials.
13. Reserve room in your design for the mandatory EU waste logos.
14. Have your packaging design tested against the KIDV Recyclecheck 2026.

Before 2030, empty space and recyclability

15. Revise your box sizes so that every package contains a maximum of 50% empty space.
16. Ensure at least 70% recyclability of all your packaging.
17. Consider reusable packaging solutions if your return rate is high.

This is not a one-off project. The PPWR is tightened in phases. Whoever starts with the inventory now will not have to panic and overhaul everything at once later.

Why you have to start now (and not in July)

The temptation to wait is strong. The first real enforcement is 12 August. That is still four months. Plenty of time, right?

No. And here is why.

Production packaging has a lead time of 4-8 weeks. If you start adjusting your packaging in July, you will not be ready in time. Certainly not if you have your packaging produced in China. There you add at least 6 weeks of production time, plus 4-6 weeks of shipping. You are talking about a 3-4 month lead time. If you start today, you make the deadline. If you start in June, it gets tight.

Your supplier does not know yet. Most Chinese packaging suppliers are not aware of the PPWR. They produce for the whole world and EU regulation is not their priority. It takes time to inform them, request certificates and possibly adjust materials.

Packaging design is iterative. Designing new packaging that meets the PPWR, protects your product, looks good and fits your budget is not something you do in a week. At least 2-3 rounds of design, feedback and adjustment are needed.

The competition is waiting too. Whoever starts now will have compliant packaging while competitors are still figuring out what the PPWR actually entails. The first brand in your category to come out with fully PPWR-proof packaging sets the tone. From obligation to distinctive advantage.

At Oase Creative we help e-commerce brands with the full journey: from packaging design to product photography. We do not see the PPWR as a burden but as a chance to improve your packaging. Many brands now work with generic brown boxes or cheap standard packaging. The PPWR forces you to look at your packaging again. So do it properly right away.

The PPWR as an opportunity: from obligation to distinctive advantage

Most sellers see the PPWR as a cost. More rules. More paperwork. More compliance stress.

But the data tells a different story.

More than a third of consumers are more likely to return to webshops with sustainable packaging (Thuiswinkel Duurzaamheid Monitor 2025). Packaging that radiates quality makes shoppers perceive a brand as premium. And sustainable packaging weighs in for a growing share of Dutch consumers in their buying decision.

The PPWR forces you to think about materials, recyclability and efficiency. Those are precisely the things consumers already want. The regulation makes mandatory what the market already rewards.

A PPWR-proof package that is also well designed is not an extra cost. It is a selling point. It is retention. It is the difference between a brown box that disappears into the paper bin and an unboxing experience that brings a customer back. The numbers behind this effect are in the overview of packaging design ROI in e-commerce.

The brands that understand this do not invest in the minimum. They invest in packaging that meets the law and at the same time strengthens their brand, as described in the difference between brand identity and e-commerce revenue. That is the opportunity.

Frequently asked questions

Does the PPWR also apply to small e-commerce sellers?

Yes. The PPWR makes no distinction based on size. Every producer that puts packaging on the EU market has to meet the obligations. The registration threshold with Verpact in the Netherlands (50,000 kg) stays in place for now, but the toxic-substance standards, traceability and declaration of conformity apply to everyone. If you sell through Bol.com or Amazon with your own product packaging, you fall under the PPWR.

What happens if my packaging does not comply after 12 August 2026?

Non-compliant packaging may no longer be placed on the market. In practice this means that regulators (in the Netherlands the ILT, Human Environment and Transport Inspectorate) can impose fines. Marketplaces such as Bol.com and Amazon are also expected to tighten their own compliance requirements.

Do I have to throw away my current packaging stock on 12 August?

No, there is a transitional arrangement for packaging that was already produced before the start date. But new production runs after 12 August have to comply. It is wise to take stock of your current inventory and estimate when you need to place a new order. Plan that new order as compliant from the start.

Is the PPWR the same as the EPR regulation?

No, but they complement each other. EPR regulation (Extended Producer Responsibility, such as the registration requirement with Verpact) governs who is responsible for collecting and recycling packaging waste. The PPWR goes a step further: it governs what may be in the packaging, how it has to be designed and how much space it may take up. Both are relevant. Both require action.

Where do I find the most up-to-date PPWR requirements?

The official Dutch source is Verpact. They monitor the implementation of the PPWR in the Netherlands. In addition, the KIDV (Netherlands Institute for Sustainable Packaging) publishes the Recyclecheck 2026, which offers a practical translation of the Design for Recycling criteria.

How do I know if my Chinese supplier delivers PPWR-compliant?

Ask specifically for test certificates for the toxic-substance standards (lead, cadmium, mercury, chromium VI under 100 mg/kg). Ask for material specifications per packaging component. If your supplier cannot provide certificates, have it tested independently through an EU-recognised laboratory. Do not take "we are compliant" without proof. The fine goes to you as the importer, not to your supplier.