On 12 August 2026 the European Union's packaging regulation, PPWR for short (Regulation (EU) 2025/40), applies directly in every member state - without a national law having to transpose it first. For companies that ship goods in B2B, this is more than an environmental rule: declaration of conformity, void-space ratio, recyclability and country-specific authorised representatives become data points that must be maintained, evidenced and traceable within the order process. Breaches can be penalised under the German Packaging Act enforcement statute with fines of up to EUR 200,000 (VerpackDG) per breach. At the same time, around 186.5 kg (Eurostat) of packaging waste per capita arose in the EU in 2022, and in Germany it was as much as 215.2 kg (Eurostat) in 2023 - the regulatory pressure is correspondingly high. This article shows how to map the new obligations in Shopware and your ERP connection instead of managing them in scattered spreadsheets and emails.
Key takeaways
- The PPWR (Regulation (EU) 2025/40) applies directly in every member state from 12 August 2026. It also covers the shipping packaging in which goods leave the warehouse.
- Declaration of conformity with technical documentation, recyclability class, recycled content and labelling become master data per packaging - maintained in the leading PIM or ERP and mirrored into the shop through an interface.
- From 2030 the void space in grouped, transport and e-commerce packaging may not exceed 50 percent (European Commission). Filling material counts as void space, not as product.
- From 2030 only packaging in classes A, B or C is permitted, meaning at least 95, 80 and 70 percent (European Commission) recyclability per unit respectively.
- Anyone shipping across borders needs an EPR registration per country and often a local authorised representative. In Germany, breaches can be penalised with up to EUR 200,000 (VerpackDG) per breach.
What the PPWR Requires From August 2026
The PPWR is a regulation, not a directive framework. That means it takes effect in all EU states at the same time and with the same wording, while the previous packaging acts and comparable national rules are gradually supplemented or replaced. Part of the obligations applies immediately on the cut-over date - including the declaration of conformity and limit values for certain substances. Other requirements come with later deadlines, above all the void-space limit and recyclability from 2030. Those who plan now buy themselves time to bring their master data and processes in order rather than coming under pressure just before a deadline. The regulation also pursues a volume target: packaging waste per capita is to fall by 5 percent (European Commission) by 2030 and by 15 percent (European Commission) by 2040 compared with 2018.
Affected is anyone who first makes packaging available on the EU market - and in online retail that expressly includes the shipping packaging in which the goods leave the warehouse. For manufacturers, wholesalers and technical trade this means: not only the product packaging but also the outer carton, the filling material and the secondary packaging fall under the rules. Through extended producer responsibility (EPR), those who place packaging on the market bear the costs for collection, sorting and recovery of their packaging - and have to register. The online shop thus becomes the place where many of these details converge: it knows the item, the destination country, the packaging type and the quantity and can carry the corresponding evidence, provided the data is cleanly connected from PIM and ERP.
PPWR in Brief
The Central Obligations at a Glance
Declaration of Conformity
For packaging, an EU declaration of conformity plus technical documentation must be kept and presented on request - a data record that belongs to the packaging.
Void-Space Ratio
From 2030 the void space in grouped, transport and shipping packaging may be at most 50 percent. Filling material counts as void space, not as product.
Recyclability
From 2030 only packaging of classes A, B or C is permitted - with at least 70 percent recyclability per unit under uniform criteria.
Recycled Content
Plastic packaging must contain a minimum share of recycled material from 2030. The share has to be documented and evidenced on request.
Representative per Country
Anyone placing packaging in several EU states needs an EPR registration there in each case and often a designated authorised representative on the ground.
Labelling
Packaging and in part collection containers carry harmonised symbols for material sorting. The details must match the actual material.
Mapping the Declaration of Conformity in Shop and ERP
The declaration of conformity is the heart of the evidence: it confirms that a packaging meets the requirements of the PPWR and is underpinned by technical documentation. In practice this means that every packaging in use - from the product carton through the secondary packaging to the shipping box - should be kept as its own data record, with details on material, weight, recyclability, recycled content and the associated documents. If this information is maintained as the leading source in the PIM or ERP and mirrored into the shop via a clean interface, the evidence can be assigned to an order at any time instead of being laboriously searched for in folders. Good data quality is the basic prerequisite here, as described in our article on product data quality and PIM.
- Each packaging type as its own master record with material and weight
- Declaration of conformity and technical documentation stored audit-proof
- Recyclability class and recycled content maintained per packaging
- Assignment of packaging to item and typical shipping unit
- Destination country and relevant EPR registration traceable on the order
- Changes to packaging versioned so that old evidence is preserved
The Void-Space Ratio in Shipping Packaging
From 1 January 2030 a void-space limit of at most 50 percent (European Commission) applies to grouped, transport and e-commerce packaging. What is meant is the unused share in the box relative to the volume of the products it contains. A frequently underestimated detail is decisive: filling material such as paper cushions, air pillows or loose chips counts as void space and not as product. Anyone filling a clearly oversized box with cushions therefore breaches the rule, even if the box looks packed in the end. For the online shop this means making the packaging choice plannable: carton sizes that match the order contents, a logic that suggests the right shipping unit based on dimensions and weight, and documentation that keeps the void space demonstrable.
Filling Material Counts as Void Space
The right carton size therefore has an immediate bearing on the calculation. Less volume often means lower shipping costs, and the additional effort for compliant packaging and EPR fees needs to be reflected in pricing. How to price such cost components cleanly without losing the margin is covered in our article on dynamic pricing in the B2B shop. The concrete calculation of shipping costs and freight logic is also closely tied to the packaging choice and should not be thought of separately in the shop.
Country-Specific Representatives and EPR
Extended producer responsibility is particularly delicate in B2B because many companies deliver across borders. Anyone placing packaging on the market in another EU state must, as a rule, register there and bear the EPR fees that arise; frequently an authorised representative in the respective country also has to be appointed to fulfil the obligations on their behalf. For a shop that ships to Austria, France or the Netherlands, the destination country thus becomes a legally relevant factor. The order process should therefore know which country is being delivered to, which registration applies there and which evidence has to be carried - information that can be stored and evaluated on the order.
Those who run several country shops or roll out an assortment internationally should factor the EPR logic in from the start. Our article on internationalisation with country-specific shops shows how language, prices, tax and legal requirements can be separated per country without duplicating operations. For the PPWR it is decisive that the country-dependent registrations and representatives are cleanly stored and that the shop knows the relevant obligations when an order goes to a particular country. This turns a confusing legal situation into an orderly data structure that can be maintained and checked.
Recyclability and Recycled Content From 2030
From 2030 only packaging classified as recyclable may be placed on the market. The regulation introduces performance classes for this: class A stands for at least 95 percent (European Commission) recyclability per unit, class B for at least 80 percent (European Commission) and class C for at least 70 percent (European Commission). Packaging below this threshold is no longer permitted from the cut-over date. In parallel, minimum shares of recycled material apply to plastic packaging and must be documented. For companies this means checking early which packaging meets the criteria and which has to be changed - because switching material and suppliers needs lead time. The resulting evidence belongs to the technical documentation and thus in the shop's master data.
| Deadline | What applies | Meaning for the shop |
|---|---|---|
| 12 Aug 2026 | PPWR applies directly, first obligations take effect | Keep declaration of conformity and substance limits as master data |
| from 2030 | Void space in shipping packaging at most 50 percent | Tie carton logic and packaging choice to the order contents |
| from 2030 | Only recyclability of classes A, B or C | Maintain recyclability class per packaging and plan the switch |
| from 2030 | Minimum recycled content in plastic packaging | Document recycled content and evidence it per packaging |
| from 2030 | Reduction target for packaging waste per capita | Record packaging volumes and evidence avoidance |
Implementation in Shopware and the ERP
Shopware open source offers an open foundation for keeping packaging data as dedicated attributes and linking them with items, customer groups and destination countries. It makes sense to define the leading system for packaging master data - usually the PIM or ERP - and to mirror the details into the shop via a robust interface rather than maintaining them twice. The shop then uses the data in several places: when choosing the right shipping unit, when documenting per order and when assigning the country-dependent obligations. Such a connection is the core of any solid Shopware development and should be planned from the outset so that compliance does not become a retrofitted add-on.
- Keep packaging as dedicated master data with material, weight and class
- Define the leading system for packaging data and mirror it via interface
- Make void space calculable from product dimensions and carton sizes
- Link the destination country on the order with the relevant EPR registration
- Store conformity documents audit-proof on the data record
- Supply mobile order channels with the same compliant data
Packaging data has to be available wherever orders arise - not only in the desktop shop. If field sales capture orders on the move, the right shipping unit including evidence should apply there too; how to solve this on mobile and offline is shown in our article on the field-sales app for mobile B2B orders. Closely related is the connection of the merchandise management system as a whole, because stock, orders and indeed packaging data live in the ERP - details in the article on ERP integration in B2B e-commerce.
Keeping Fines and Liability in View
The sanctions are noticeable. Under the German Packaging Act enforcement statute, fines range depending on the breach from a few thousand euros up to EUR 200,000 (VerpackDG); incomplete or late data reports can be penalised with up to EUR 100,000 (VerpackDG). Alongside the fine there is the threat of sales bans and reputational damage if packaging is not compliant. The most effective protection is seamless, traceable documentation: those who can prove which packaging with which properties was placed on the market in which country are able to act in the event of an audit. Compliance in the B2B shop is a cross-cutting topic anyway - from the e-invoicing mandate through IT security under NIS2 to the digital product passport under the ESPR, which will further interlink packaging and product data.
Compliance is not created on audit day but in the master data. Those who cleanly keep packaging, evidence and destination country turn a confusing legal situation into an auditable data structure.
Step by Step to PPWR Conformity
The path to conformity begins with taking stock, not with technology. First, it is a matter of recording which packaging is actually used, which countries are delivered to and where evidence is missing today. From this overview it follows which master data has to be built up, which packaging has to be changed and which registrations have to be added. A step-by-step approach makes sense that prioritises the immediately applicable obligations and treats the deadlines up to 2030 as an orderly roadmap. This creates no last-minute scramble before the cut-over date but a robust structure that grows with you.
- Fully record the packaging, materials and destination countries in use
- Define the leading system for packaging master data in PIM or ERP
- Secure declarations of conformity and technical documentation per packaging
- Document void space, recyclability class and recycled content per packaging
- Check and store EPR registrations and representatives per country
- Mirror the data into Shopware via interface and evidence it on the order
Those who understand the PPWR early as a data task win twice: the obligations are achievable without overloading the order process, and the orderly packaging data incidentally lowers material and shipping costs. Which steps make sense for your shop depends on the assortment, destination countries and the existing system landscape; comparable project approaches give an initial orientation, and the concrete implementation is something we are happy to discuss in direct contact.