Is my webshop affected by the PPWR?

Yes, if your Dutch webshop places packaged goods on the EU market. The PPWR catches all packaging, with design-for-recycling rules and empty-space limits from 1 January 2030 and conformity documentation already binding. Your exact obligations depend on whether you source standard packaging or manufacture it to your own specifications.

The PPWR already applies. What do I have to do now?

Hold a declaration of conformity for every packaging type you have made or import, confirm PFAS compliance for any food-contact packaging with your supplier, and appoint an authorised representative in each EU country you ship to and are not established in. Those three are binding today. The design work, auditing your portfolio against the recyclability criteria and the 50 percent empty-space rule, is preparation for 1 January 2030.

What happens if my webshop does nothing?

Non-compliant packaging will eventually be blocked from the EU market. If you fail to meet the recyclability grades, empty-space limits, or reporting duties, you risk penalties, interrupted cross-border sales, and enforcement action by the Human Environment and Transport Inspectorate (ILT).

PPWR requirements for reusable and recyclable packaging

Which PPWR reuse and recyclability requirements are coming

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) entered into force on 11 February 2025 and has applied across all EU member states since 12 August 2026. The regulation replaces the former Packaging Directive and establishes unified EU-wide standards for sustainability, waste reduction, and circularity. For ^[1]Dutch webshops, this framework introduces concrete obligations for packaging design, recyclability, and volume reduction that phase in between 2026 and 2030.

The transition unfolds along specific regulatory milestones established by EU law and communicated by national authorities:

12 August 2026: Application date for the first PPWR obligations. Packaging manufacturers must have completed a conformity assessment and drafted a conformity statement, must draw up and keep a packaging dossier with information on material, weight and environmental impact, and must comply with the maximum levels for PFAS; every business must determine its role or roles in the packaging chain^[2]^[3]. The PFAS restriction applies to food-contact packaging, which can no longer be placed on the EU market above the limits from that date^[4]. The limits are published: 25 ppb for any individual PFAS measured by targeted analysis, 250 ppb for the sum of PFAS, and 50 mg/kg total fluorine^[6]. Cross-border sellers pick up a second duty on the same date: Article 45(3) requires an authorised representative for extended producer responsibility in every member state where you make packaging available for the first time and are not established^[6].
From 2028: a harmonised EU labelling system applies to facilitate waste sorting, so customers know how and where to dispose of packaging^[4]. The standardised symbols have not been published yet and are, per KVK, likely to be announced by the end of 2026^[1].
From 1 January 2030: measures fostering the circular economy apply, including the mandatory use of recycled plastic in new plastic packaging and the requirement that all packaging is recyclable^[4].
From 1 January 2030: the empty space in a shipping box must not exceed 50 percent, and packing material counts as empty space^[1].

Not all PPWR rules have been finalised yet: the European Union will continue to work out the regulation over the coming years, and as a result further rules will be introduced up to and including 2029^[2]. The European Commission states that it is advancing its work to put forward the necessary secondary legislation in time^[4]. Preparing your packaging portfolio early keeps operations running across EU markets.

The reuse targets, and why a cardboard parcel sits outside them

The word "reusable" in the PPWR does most of its work in Article 29, and that article is narrower than the headline suggests. It sets a binding target of at least 40 percent reusable transport packaging from 1 January 2030, rising to 70 percent from 1 January 2040, and it names the formats it means: pallets, foldable plastic boxes, plastic crates, intermediate bulk containers, pails, drums, canisters, pallet wrappings and securing straps^[6]. Where an operator moves transport packaging between its own sites or with linked enterprises, the requirement is stricter: that packaging has to sit inside a reuse system altogether^[6].

Cardboard boxes are exempt from those targets^[6]. For most Dutch webshops that single exemption decides the whole question: the parcel you ship to a consumer in a cardboard box is not what the reuse percentages are aimed at. On top of that, the reuse rules are more flexible if you use less than 1,000 kg of packaging per year, and businesses with fewer than 10 employees and turnover under EUR 2 million get flexibility on some rules generally^[1].

Read that as a relief and you will misread it. The pressure on a cardboard parcel arrives through the other half of the regulation: the recyclability grades and recycled-content rules from 1 January 2030, the 50 percent empty-space limit, the conformity documentation you need from 12 August 2026, and the Dutch waste contribution, whose tariffs are already modulated by how recyclable your packaging is. Being outside Article 29 changes which rules you plan against, not whether you have to plan.

Who is affected: test your packaging portfolio

Do you package, sell, import, or ship products? If so, you are subject to the PPWR, and the requirements apply to all packaging: not only packaging for products, but also packaging used in shipping, such as boxes, packing material, tape, and labels^[1]. The regulation names packaging manufacturers, importers, distributors, businesses that place packaging on the market, and businesses that use packaging^[2]. If you have fewer than 10 employees and turnover below EUR 2 million per year, some rules are more flexible, and the reuse rules are also more flexible if you use less than 1,000 kg of packaging per year^[1].

To determine whether your current packaging portfolio meets the PPWR criteria, test your items against these core operational benchmarks:

Recyclability criteria: Are your boxes, mailers, and protective wraps made from mono-materials (such as 100 percent paperboard or unlaminated PE) that commercial recyclers can easily process?
Empty-space ratio: Does your shipping packaging contain more than 50 percent empty space, air padding, or void fill when packed for shipment?
Conformity documentation: Can your suppliers provide official declarations of conformity proving compliance with EU chemical restrictions and material safety limits?
Substance safety: Does any food-contact packaging in your catalog contain restricted PFAS substances exceeding statutory limits?

Which PPWR obligations apply to your webshop depends on your exact role in the packaging chain. From 12 August 2026 every business must determine its role or roles, a company can have more than one, and which obligations apply depends on that role and the type of packaging^[2]^[3]. A webshop using standard packaging sourced from an EU supplier faces different duties from a business importing packaging or having it manufactured under its own specifications. These distinctions cannot reliably be resolved through a general checklist alone. Contact ClearoSystems for PPWR consultation to evaluate your specific setup and identify which requirements actually apply to your business.

What to do before the deadlines

Preparing for PPWR compliance requires structured operational adjustments well ahead of the phased requirements. We recommend three immediate practical steps to evaluate and adjust your packaging inventory:

Audit your packaging portfolio: keep a record of how much packaging you use and what materials it is made from, and document how you manage packaging and why you make certain choices. This helps you show the ILT, customers and suppliers that you follow the rules^[1]^[3].
Engage packaging suppliers: if you have packaging manufactured or import it, you must be able to prove it complies with European rules through an EU declaration of conformity. The manufacturer must arrange this document, and suppliers must provide the information required for it^[1].
Pilot right-sizing and reusable packaging: take a critical look at the packaging you ship orders in, use as little material as possible, and choose reusable or recyclable materials such as cardboard or types of plastic that are easy to recycle^[1].

There is no need to scrap existing stock overnight: old packaging that does not meet the new requirements may still be used provided it was placed on the market before 12 August 2026^[1]. Early adjustments still reduce friction when stricter material standards phase in.

What has not changed

While the PPWR introduces new design and structural standards across Europe, established national producer responsibility rules remain fully active in the Netherlands. If you bring more than 50,000 kilograms of packaging material onto the Dutch market in a calendar year, counted across all materials together, you still pay the packaging waste management contribution to Verpact, report the quantity you place on the market each year, and submit a prevention and recycling report through Verpact every year before 1 August^[3]^[5].

Key existing statutory frameworks that remain in force today include:

^[3]Verpact registration and reporting: the Dutch national producer responsibility system operates as usual. If you bring packaging onto the Dutch market you must be able to show the weight of the packaging and the materials it is made from, whatever your volume, and once you reach the threshold you also report the quantity you place on the market each year^[5].
The 50,000 kg threshold: the contribution and reporting threshold sits in the 2014 Packaging Management Decree (Besluit beheer verpakkingen) and remains in force today^[5]^[3]. Per KVK, the waste contribution is expected to apply from 2028 to businesses using less packaging than that, but no Dutch implementing instrument setting this out has been published^[1].
German packaging obligations: shipping directly to German end-consumers triggers separate German VerpackDG registration via LUCID, independent of Dutch packaging law.
Separate waste regimes: electrical equipment and battery obligations operate under distinct legal frameworks and are not altered by packaging regulation.

Understanding how these national rules interact with the new EU requirements is what keeps you compliant across all sales channels.

Outlook and your role in the chain

As implementation progresses, national governments and producer organisations will publish detailed administrative decrees. Verpact expects the declaration threshold to disappear once the PPWR producer register is in place from 12 August 2027 at the earliest, with a simplified declaration for companies placing less than 10,000 kilograms on the Dutch market, and KVK expects the contribution to reach businesses below today's threshold from 2028^[1]. Those are expectations, not rules. The fee levels, tariff structures and calculation formulas for smaller volumes have not been determined in published national legislation, and future financial duties only become binding when a formal instrument appears in the Staatsblad.

Understanding compliance involves three distinct levels of orientation:

General regulatory orientation: Published articles and guides outline broad EU framework principles and application timelines^[2]^[4].
Individual compliance assessment: Evaluating specific packaging materials, supply contract terms, and manufacturing specifications.
Legal and operational implementation: Securing exact supplier declarations, verifying chemical compliance, and managing country-specific registrations.

Which specific PPWR requirements apply to your webshop depends on your exact role in the packaging chain. The rules distinguish manufacturers, importers, distributors, businesses that place packaging on the market and businesses that merely use it, and the obligations that bite follow from that role and the type of packaging^[2]^[3]. A business that manufactures custom packaging or imports packaged goods therefore carries a heavier documentation load than an online store sourcing standard shipping boxes from an EU wholesaler. These individual distinctions cannot reliably be resolved through a general article or standard checklist alone.

To understand your PPWR position today and be on the safe side, contact ClearoSystems for PPWR consultation now. Our experts will evaluate your specific packaging setup, clarify your exact obligations under upcoming EU rules, and ensure your business remains compliant as implementation details develop.

Frequently asked questions

Is my webshop affected by the PPWR?: Yes, if your Dutch webshop places packaged goods on the EU market. The PPWR catches all packaging, with design-for-recycling rules and empty-space limits from 1 January 2030 and conformity documentation already binding. Your exact obligations depend on whether you source standard packaging or manufacture it to your own specifications.
The PPWR already applies. What do I have to do now?: Hold a declaration of conformity for every packaging type you have made or import, confirm PFAS compliance for any food-contact packaging with your supplier, and appoint an authorised representative in each EU country you ship to and are not established in. Those three are binding today. The design work, auditing your portfolio against the recyclability criteria and the 50 percent empty-space rule, is preparation for 1 January 2030.
What happens if my webshop does nothing?: Non-compliant packaging will eventually be blocked from the EU market. If you fail to meet the recyclability grades, empty-space limits, or reporting duties, you risk penalties, interrupted cross-border sales, and enforcement action by the Human Environment and Transport Inspectorate (ILT).