Starting August 12th, the EU's Packaging and Packaging Waste Regulation (PPWR, 2025/40) officially came into force. All parcels shipped to the EU market, regardless of the shipping channel or whether they use the CZL (Closed Zone) system, must have their packaging reviewed according to the new regulations. This rule doesn't just apply to large sellers or local manufacturers; as long as goods are intended for entry into the EU, their packaging falls under its jurisdiction.
For sellers operating on the EU marketplace, three things are directly affected: packaging design needs to be recalculated for void ratio, compliance documents need to be kept on file for future reference, and ERP registration needs to be completed in advance. The declaration process for exports from China remains unchanged; the trouble lies entirely in packaging and local EU compliance procedures.
Several articles that will take effect immediately from August 12th
The porosity does not exceed 40%. The air inside the box cannot exceed 40% of the total space. In other words, the practice of using an oversized cardboard box to pack small items and stuffing it with a lot of bubble wrap to support it is now non-compliant (except for situations that are technically unavoidable, such as fragile items that must have cushioning space).
For example, a 30×20×15cm cardboard box has a volume of 9000 cubic centimeters. If the goods inside, including necessary cushioning, only occupy 5000 cubic centimeters, the void ratio is 44%, which exceeds the standard. Either you switch to a box of approximately 27×18×13cm to reduce the void ratio to below 40%, or you need to recalculate the packaging design.
This is actually beneficial for logistics costs, as a more compact box results in a lower volumetric weight. DHL, FedEx, and UPS all use the formula length × width × height ÷ 5000 for volumetric weight. Reducing the box size from 30×20×15 to 27×18×13 reduces the volumetric weight from 9kg to approximately 6.3kg, saving a significant amount on volumetric weight costs per shipment. Compliance and cost savings are now combined.
The Declaration of Compliance (DoC) document should be retained. Each type of packaging must have a corresponding declaration of conformity and technical documentation, which must be available for inspection by customs or market regulators. Without this documentation, it's difficult to explain the situation when goods are randomly inspected within the EU, and the resulting trouble is far greater than simply obtaining a replacement document.
Restricted substances cause a blockage. Food contact packaging must not contain PFAS (per- and polyfluoroalkyl substances), and there are clear upper limits on the total amount of heavy metals such as lead, cadmium, mercury, and hexavalent chromium. The materials used to package food products now need to be re-checked against the new standards.
EPR registration is done by country, not once and valid throughout the entire EU. Sellers must complete Extended Producer Responsibility (EPR) registration for packaging in each EU member state where they generate sales orders. Germany, France, and the Netherlands each have separate registration systems, and a registration is required for each country where sales occur. Waiting until an inspection is conducted before completing this process is essentially too late; it should be started now.
The platform was also drawn into the chain of responsibility. If an e-commerce platform handles packaging or logistics for a third-party seller, the platform is also one of the responsible parties, and it is no longer a case of "the platform is not responsible when the seller has problems".
The online claim that "stainless steel snap-lock cardboard boxes are no longer usable" is simply moving a project originally slated for 2030 to 2026.
A rumor has been circulating widely recently: that stainless steel clips or staples used to secure cardboard box seams will be banned starting August 12th, rendering previously stockpiled boxes useless. This rumor has about half the truth, but the timeline is incorrect.
Metal fasteners are definitely a negative factor in the recycling process. Cardboard box recycling involves pulping, and metal parts can easily jam machines and damage equipment. Recycling plants usually separate these items for other processing or even refuse to accept them. In PPWR's "Recyclable Design" rating system, cardboard boxes with metal fasteners are indeed rated lower than boxes made of pure paper and paper tape.
However, the mandatory thresholds for recyclability ratings (A/B/C are acceptable, D/E are prohibited from sale) will be implemented later.January 1, 2030It just came into effect, not this month. Using metal clips to fasten cardboard boxes is not currently considered a violation; this requirement was not included in the batch of requirements that took effect immediately on August 12th.
The practical advice is: don't rush to replace all the stock boxes now, but start evaluating the transition to boxes made of pure paper with a hinged lid interlocking structure. Replace them in batches, instead of waiting until the end of 2029 for a concentrated transformation, when suppliers' capacity and costs will be even tighter.
What should we do now?
For sellers on the EU marketplace, please prioritize these tasks:
- Measure the void ratio of the existing packaging. For box types exceeding 40%, find smaller sizes to replace them first.
- Check the materials used in the packaging of food contact products; make sure they don't cross the line regarding PFAS and heavy metals.
- Register your EPR (Electronic Permit) for each country where your sales orders originated, one by one. Don't try to register them all at once.
- Organize and archive the compliance declaration documents on hand so that they can be readily retrieved during spot checks.
- There's no need to rush to replace metal-buckled cardboard boxes, but you can start connecting with suppliers of alternative packaging materials and gradually transition.
Changes in packaging will ultimately be reflected in logistics costs. Reducing the void ratio lowers the volumetric weight, resulting in tangible cost savings. EPR registration and compliance documentation are more administrative procedures and less related to the shipping channel, but they are still obligations that will be implemented starting August 12th, so don't miss them.
You can check shipping costs at [website name] Freight Inquiry The page compares different channels; those involving remote areas can be checked. Remote address searchThe latest figures for fuel surcharges Fuel Surcharge page.
Information source:
- Official gazette of the European Union, Regulation (EU) 2025/40
- Greenberg Traurig《EU Packaging and Packaging Waste Regulation: New Compliance Requirements for E-Commerce》
- Tanso《PPWR explained: EU Packaging Regulation 2026》