COMPLIANCE DEEP DIVE
EU Packaging Rules for Fashion E-Commerce: Mailer Boxes, Polybags, Hangers and Dust Bags Under the PPWR, and the DPP Link
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) has applied since 12 August 2026 (Article 71). It covers every item a fashion brand uses to contain, protect, handle, deliver or present its products: the box or bag a webshop order travels in, the polybag and tissue around a garment, the shoe box and, according to the Regulation's own list and the Commission's guidance, hangers sold with a garment and dust bags for shoes and garments. A brand that sells directly to consumers in another Member State is a producer there, with extended producer responsibility (EPR) and, as the law stands, a duty to appoint an authorised representative in each such country. Most design rules, from empty space and reuse targets to the harmonised sorting label, start later: in 2028, in 2030 or after Commission implementing acts that have not yet been adopted.
This guide maps the PPWR onto the packaging that fashion e-commerce actually ships, separates what applies now from what comes later, and gives the status on 21 October 2026 of the proposal to suspend the authorised-representative duty and of the label and register implementing acts. It also explains where packaging meets the Digital Product Passport (DPP). The short version: packaging does not fall under the textile DPP, but the PPWR uses the ESPR's definitions of substance of concern and data carrier and requires a single data carrier for product and packaging information wherever Union law requires a data carrier for the product. The packaging data you build now is part of the same data work.
12 Aug 2026
The date from which Regulation (EU) 2025/40 applies (Article 71). Several of its design and labelling requirements apply only from later dates.
50 %
The maximum empty space ratio for e-commerce packaging, from 1 January 2030 or three years after the methodology act enters into force, whichever is later (Article 24(1)).
40 %
The minimum share of reusable transport packaging in the forms listed in Article 29(1), including for e-commerce, from 1 January 2030. Cardboard boxes are excluded (Article 29(4)(d)).
1. What the PPWR covers for a fashion brand
The PPWR defines packaging by function, not by material. An item is packaging if it is intended to be used by an economic operator for "the containment, protection, handling, delivery or presentation of products" to another economic operator or to an end user (Article 3(1), point (1)). For webshops, the Regulation adds a specific category. E-commerce packaging means "transport packaging used to deliver products in the context of sale online or through other means of distance sales to the end user" (Article 3(1), point (8)). The classification matters, because several rules treat transport packaging, sales packaging and e-commerce packaging differently.
Annex I gives an indicative list of what is and is not packaging (Article 3(2)). For fashion, it lists "Clothes hangers (sold with a clothing item)" as packaging and "Clothes hangers (sold separately)" as not packaging (Annex I, Part A). It also lists "Labels hung directly on or attached to a product" as packaging, while "Radio frequency identification (RFID) tags" are listed as not packaging (Annex I, Part B). On that wording, swing tickets hung on garments are packaging items; an RFID inlay is not.
For dust bags, the Commission's guidance (Notice C/2026/3084, published in the Official Journal C series on 10 June 2026) is explicit: "Dust bags for shoes and garments are deemed packaging if they are intended to be used for the containment, protection, handling, delivery or presentation of products to an end user". It adds that "There is no exemption for textile packaging from the general packaging definition". A dust bag is not packaging where it is an integral part of the product, or where it is not placed on the market for packaging use, for example when it is sold separately (guidance, point 1).
The Regulation applies from 12 August 2026, and Directive 94/62/EC is repealed from that date, with some of its provisions kept for a transition period (Articles 70(1) and 71). Applying from that date does not mean that every requirement bites now: the design-for-recycling criteria, recycled content, minimisation, empty space, reuse targets and the harmonised label all have later dates, several of which depend on Commission acts that are still pending. The Commission's PPWR FAQ (second edition, August 2026) makes the same point for the obligations of manufacturers, which must be read together with the substantive requirements and their own dates (section X, question 2). For formal non-compliance, such as a missing EU declaration of conformity or incomplete technical documentation, Article 62 requires the Member State first to require the operator to put an end to it.
2. Who is the producer, and what EPR means for cross-border webshops
EPR under the PPWR attaches to the producer, which Article 3(1), point (15), defines by where packaging is first made available, not by who made it. A brand established in a Member State is the producer at home for the packaging it first makes available there (points (a) and (b)). A manufacturer, importer or distributor established in a Member State or in a third country that "makes available for the first time on the territory of another Member State, directly to end users" transport packaging, such as the mailer box (point (c)), or products in other packaging, such as a garment in its polybag (point (d)), is the producer in that other Member State. The Commission's guidance gives the webshop example: a company that sells through its web shop to an end user in another Member State is the producer there and must fulfil the EPR obligations in that Member State (guidance, point 3).
In each such Member State the producer has extended producer responsibility for the packaging it makes available there for the first time (Article 45(1)). It must register in that Member State's register of producers and may not make packaging available there unless it, or where applicable its authorised representative, is registered (Article 44(2) and (4)). Reporting is annual, by 1 June for the preceding calendar year, and covers quantities by weight of packaging categories; producers below 10 tonnes a year in a Member State report a reduced set of information (Article 44(7) and (8); Annex IX, Part B). A Member State may lower that threshold for a given year and, for budgetary reasons, require quarterly reporting (Article 44(8) and (9)). The Commission had to adopt the harmonised format for registration and reporting by 12 February 2026 (Article 44(14)); it is still pending, and each Member State has 18 months from its entry into force to set up its register under the PPWR (Article 44(1)). This packaging EPR is separate from EPR for the textile products themselves, which our textile EPR guide covers.
The cross-border webshop rule with the most immediate cost is Article 45(3). A producer under Article 3(1), point (15)(c) or (d), must appoint, by written mandate, an authorised representative for EPR "in each Member State where the producer makes packaging or packaged products available for the first time, other than the Member State where the producer is established". For a brand established outside the EU and selling directly to consumers, that is every Member State it ships to. Online platforms must obtain your registration number in the consumer's Member State and a self-certification of EPR compliance before allowing you to use their services, and fulfilment service providers must receive the same information when you conclude a contract with them (Article 45(4), (7) and (8)).
The Commission has proposed to suspend that duty. Article 2 of its proposal COM(2025) 982 reads: "The application of Article 45(3) of Regulation (EU) 2025/40 shall be suspended until 1 January 2035". Member States could then either require producers established in third countries to appoint an authorised representative or ensure traceability and enforcement by alternative means. On 20 October 2026 the European Parliament adopted amendments that narrow the suspension to "producers established in the Union qualifying as microenterprises or small enterprises" within the meaning of Recommendation 2003/361/EC, end it earlier if a Union act with horizontal EPR rules, including rules on authorised representatives, applies before 1 January 2035, and delete the Commission's option for producers established in third countries (amendments 12 and 13, text adopted P10_TA(2026)0345). Neither version is law yet; the dated status is in section 6. The PPWR's few micro-enterprise carve-outs, including the private-label rule for packaging, are compared in our SME thresholds guide.
3. The packaging fashion brands ship: what applies now and what comes later
The table maps the items that typically leave a fashion warehouse to the PPWR. In the table, now means since 12 August 2026. Two duties apply to every item in the table: the substance rules of Article 5, and EPR in each Member State where you are the producer. Article 5(1) requires the presence and concentration of substances of concern in packaging to be minimised, and Article 5(4) caps the sum of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg. For substances of concern in the ESPR sense, see our substances-of-concern guide.
| Item | Status under the PPWR | What applies, and when | Provisions |
|---|---|---|---|
| Mailer box (corrugated cardboard) | E-commerce packaging, a form of transport packaging. If it carries your name or trademark, you are its manufacturer, subject to the micro-enterprise rules in Article 3(1), point (13)(b), and Article 15(12); for an unbranded, standardised box it is the company that physically makes it (Commission FAQ, section II, question 5). | Now: if you are the manufacturer, the duties in Article 15. Later: harmonised sorting label, from which e-commerce packaging is not exempt; maximum 50 % empty space from 1 January 2030 at the earliest; design-for-recycling criteria from 1 January 2030 at the earliest. Not covered by the 40 % reuse target, which excludes packaging "in the form of cardboard boxes". | Article 3(1), points (8) and (13); Articles 6(2), 12(1), 15 and 24(1); Article 29(4)(d) |
| Mailer bag (plastic or paper) | E-commerce packaging. | As for boxes: label, 50 % empty-space ratio and design-for-recycling criteria, all from later dates. Plastic bags: at least 35 % post-consumer recycled content in the plastic part, calculated as an average per manufacturing plant and year, from 1 January 2030 at the earliest, subject to the exemptions in Article 7. Reuse target: the cardboard exclusion covers boxes only; the Commission FAQ reads the list of forms in Article 29(1) as exhaustive, including flexible versions of the listed formats (section XIII, question 9), so coverage depends on the format. | Article 7(1)(d); Articles 6(2), 12(1), 24(1) and 29(1) and (4) |
| Polybag around a garment; tissue paper; void fill | Packaging where used to contain, protect or present the product (Article 3(1), point (1)). | Polybags: recycled-content target for plastic packaging from 1 January 2030 at the earliest; label rules once applicable. Space filled by filling materials such as paper cuttings, air cushions and bubble wraps counts as empty space when the 50 % ratio is calculated. | Articles 7(1)(d), 12(1) and 24(3) |
| Clothes hanger | Packaging when sold with a clothing item; not packaging when sold separately. | Now: EPR and substance rules for hangers shipped on garments. Later: the design-for-recycling criteria and, for plastic hangers, the recycled-content target. | Annex I, Part A; Articles 6 and 7 |
| Swing ticket (hang tag) | Annex I lists labels hung directly on or attached to a product as packaging; RFID tags are listed as not packaging. | Now: part of the packaging you make available, so within EPR. | Annex I, Part B; Article 45(1) |
| Dust bag (textile) | Packaging if intended for the containment, protection, handling, delivery or presentation of shoes or garments to an end user (guidance, point 1). | Textile sales packaging is exempt from the recyclability requirements of Article 6, but the recyclability-based modulation of EPR fees in Article 6(8) still applies to it, from 18 months after the delegated and implementing acts under Article 6(4) and (5) enter into force. EPR, substance rules and, once applicable, the label apply as to other sales packaging. | Article 6(8) and (11)(g) |
| Shoe box | Sales packaging; when shipped as it is, sales packaging used as e-commerce packaging. | From 12 February 2028: empty space reduced to the minimum necessary for the packaging's functionality. From 1 January 2030: weight and volume reduced to the minimum necessary. If shipped as it is, exempt from the 50 % ratio but still subject to Article 10. | Articles 10, 24(4) and 24(5) |
Article 6(11)(g) is narrower than it is sometimes read. It takes out of Article 6 "sales packaging made from lightweight wood, cork, textile, rubber, ceramic, porcelain or wax; however, paragraph 8 shall apply to such packaging". It covers packaging made of textile, such as a dust bag, not packaging used for textile products, and only sales packaging. A polybag or a mailer around a garment gets no relief from it. The Commission's FAQ confirms that the recyclability assessment for such textile sales packaging will still be carried out to modulate EPR fees (section IV, question 9).
If your name or trademark is on the packaging, you are its manufacturer (Article 3(1), point (13)(a)). Since 12 August 2026 that means, before placing the packaging on the market: a conformity assessment, technical documentation under Annex VII and an EU declaration of conformity (Article 15(2)); a type, batch or serial number or other identification element (Article 15(5)); and your name, registered trade name or registered trademark and a postal address on the packaging or via a QR code or other data carrier (Article 15(6)). Your suppliers must give you the information and documentation you need to demonstrate conformity (Article 16(1)). If the brand is a micro-enterprise, a packaging supplier located in the same Member State is the manufacturer instead (Article 3(1), point (13)(b)), and a supplier located anywhere in the Union is considered the manufacturer for the purposes of Article 15 (Article 15(12)).
The reuse targets in Article 29(1) apply from 1 January 2030 to economic operators that use transport packaging, or sales packaging used for transporting products, "including for products distributed via e-commerce", in the listed forms: at least 40 % must be reusable packaging within a re-use system. The duty to demonstrate that the target is met applies from 1 January 2030 or 18 months after the calculation methodology enters into force, whichever is later (Article 30(4)). An economic operator is exempt for a calendar year only if it both "made not more than 1 000 kg of packaging available on the territory of a Member State" and is a micro-enterprise under Recommendation 2003/361/EC as applicable on 11 February 2025 (Article 29(13)).
4. The harmonised label, online display and substances of concern
Article 12(1) requires packaging placed on the market to carry a harmonised, pictogram-based label with information on its material composition, to help consumers sort it. It applies "From 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to paragraphs 6 or 7 of this Article, whichever is the latest". Those implementing acts were due by 12 August 2026 (Article 12(6) and (7)) and had not been adopted on 21 October 2026. The start date therefore depends on when they enter into force; it is not 12 August 2028. Transport packaging is generally out of scope, but not your parcels: "With the exception of e-commerce packaging, this obligation does not apply to transport packaging or to packaging that is subject to a deposit and return system".
The label must be affixed, printed or engraved visibly, legibly and firmly, and the PPWR adds an online rule: "The information contained therein shall also be available to end users before the purchase of the product through online sales" (Article 12(5)). In practice, your product pages will need to show the sorting information for the packaging the customer receives. Where the size or nature of the packaging does not allow a label, it goes on the grouped packaging, and where even that is not possible or not warranted, the information is provided via a single electronically readable code or other data carrier. The information must be in a language or languages easily understood by end users, as determined by each Member State (Article 12(5)).
Until the harmonised label applies, national sorting-label rules remain relevant. The Commission's guidance treats labelling under Article 12 as fully harmonised and states that Member States may not keep national labels next to the EU labels after 12 August 2028 or 24 months after the implementing act enters into force (guidance, point 13). Packaging manufactured in the Union or imported before a labelling deadline that does not meet it may be made available until three years after the labelling requirement enters into force (Article 12(12)).
Packaging containing substances of concern must be marked by standardised, open, digital-marking technologies, in accordance with a methodology that the Commission must adopt by 1 January 2030 (Article 12(1), second subparagraph, and Article 12(7), second subparagraph). The marking must include "at least the name and concentration of the substance of concern present in each material in a packaging unit". The Commission's FAQ says that ECHA is studying which substances of concern occur in packaging and that the methodology will follow from that work (section VIII, question 4). Until the methodology exists there is nothing to apply, but the data it will require is the substance data you collect from packaging suppliers today.
5. Where packaging meets the Digital Product Passport
Packaging does not fall under the textile DPP. Recital 9 of the PPWR notes that under the ESPR "packaging is not addressed as a specific product category", although ESPR delegated acts may set additional requirements for the packaging of specific products. A DPP for garments requires an ESPR delegated act for textiles, and the Publications Office records show none adopted as of 21 October 2026. For what a passport data carrier is and how the registry works, see our data carrier guide.
The two laws are nevertheless built to connect. The PPWR applies the ESPR's definitions of substance of concern and data carrier (Article 3(1), last subparagraph, referring to Article 2, points (27) and (29), of Regulation (EU) 2024/1781). The last subparagraph of Article 12(5) then sets the rule for shared carriers: "Where Union law requires information on the packaged product to be provided via a data carrier, a single data carrier shall be used for providing the information required for the packaged product and for the packaging, and both shall be easily distinguishable". Recital 70 names the passport directly: "where the packaged product is covered by Regulation (EU) 2024/1781 or other Union law requiring a digital product passport, that digital product passport should also be used for providing the relevant information under this Regulation". Under the ESPR, the passport's data carrier must be physically present on the product, its packaging or accompanying documentation, as the delegated act specifies (Article 10(1)(b) of Regulation (EU) 2024/1781).
On that wording, once a textile delegated act requires a DPP data carrier and the PPWR's digital labelling elements apply, the packaging information required under the PPWR would be provided via the same carrier as the garment's passport, kept distinguishable from the product information. That is the DPP link: not packaging inside the textile passport, but one carrier and one data discipline. The data overlaps in practice: material composition per packaging component, weights per Member State for EPR reporting, substances of concern and recycled content. Keeping one master record for each product and its packaging avoids parallel versions of the same facts. That is good practice, not a legal requirement. Physical product labels follow their own rules; see our Textile Labelling Regulation guide.
6. Pending acts and proposals: status on 21 October 2026
Status on 21 October 2026
Suspension of the authorised-representative duty. Proposal COM(2025) 982 of 10 December 2025 (procedure 2025/0395(COD)) would suspend Article 45(3) of the PPWR until 1 January 2035. On 20 October 2026 the European Parliament voted on the report A10-0266/2026 of its environment committee and adopted amendments (text adopted P10_TA(2026)0345): they limit the suspension to micro and small enterprises established in the Union and could end it before 1 January 2035 (section 2). Parliament did not adopt its first-reading position: "The matter was referred back for interinstitutional negotiations to the committee responsible, pursuant to Rule 60(4), fourth subparagraph". When we checked on 21 October 2026, the Legislative Observatory still showed the stage "Awaiting Parliament's position in 1st reading". The suspension needs Parliament and Council to agree on the same text, and it would enter into force on the twentieth day after publication in the Official Journal (Article 3 of the proposal). Until then, Article 45(3) applies as written. Harmonised label. Have Your Say initiative 19243, "Packaging and packaging waste – new Commission implementing rules on harmonised labels", shows the draft act as not yet published for feedback and adoption as planned for the second quarter of 2027. Register format. The draft implementing regulation under Have Your Say initiative 15352, "Packaging and packaging waste – rules on national registers of producers", was open for feedback from 6 August to 10 September 2026 (7,667 responses) and has not been adopted. Official Journal. The Publications Office records list no act amending Regulation (EU) 2025/40, seven corrigenda to individual language versions (the latest of 18 September 2026, none to the English version), and no implementing act adopted under it.
What this means for a brand selling across borders: the authorised-representative duty applies today. If the Commission's version is adopted, the duty would be suspended for all producers, with each Member State free either to require an authorised representative from producers established in third countries or to ensure traceability and enforcement by other means. If Parliament's version prevails, medium-sized and large brands established in the Union, and brands established outside the Union, would still need authorised representatives. Plan for the law as it stands, and review your arrangements once a final text is published in the Official Journal.
The label date moves with the implementing acts. The Regulation fixes it by reference to their entry into force, so each delay in their entry into force moves the obligation back by the same amount of time. If the label act is adopted in the second quarter of 2027 as planned, the label obligation could not start before the second quarter of 2029; it would start later if the act enters into force later or if the paragraph 7 methodology act follows after it. Other acts based on the PPWR that the Publications Office lists, such as Delegated Decision (EU) 2026/429 on pallet wrappings and straps and the Commission's Notice C/2025/946 on Northern Ireland, do not change the obligations described in this guide.
7. What to do now
Build a packaging inventory per product and channel. For each article and each shipping configuration, list every packaging item (mailer, bag, polybag, tissue, void fill, hanger, swing ticket, dust bag, shoe box), its material per component, its weight and its supplier, and whether it carries your name or trademark. That record tells you where you are the manufacturer (Article 3(1), point (13), and Article 15) and gives you the weights you report by packaging category and Member State (Annex IX, Part B).
Map your producer status country by country. For every Member State where you sell directly to end users from another country, you are the producer for that packaging (Article 3(1), point (15)(c) and (d)). Register there, organise EPR, appoint an authorised representative as long as Article 45(3) applies, and give your marketplaces and fulfilment service providers your registration numbers and self-certification (Articles 44, 45(3), (4) and (7)).
Get the evidence from your packaging suppliers. Ask for the information and documentation that demonstrate conformity, including heavy-metal content against the 100 mg/kg limit and data on substances of concern (Articles 5 and 16(1)). For branded packaging, keep the technical documentation and the EU declaration of conformity for 5 years for single-use packaging, or 10 years for reusable packaging (Article 15(3)).
DPP AUDIT
Packaging data and product data belong in one record.
Producer status per country, the authorised-representative duty, packaging weights for EPR reporting and, later, a single data carrier shared with the DPP all draw on the same product and packaging records. In a DPP audit we check how your packaging and product data are recorded, per item and per Member State, and where they fall short of the PPWR. Under NDA.
Start Your DPP AuditPlan the 2028 and 2030 changes now. Check your shoe and gift boxes against the empty-space rule for sales packaging (from 12 February 2028), your mailers against the 50 % ratio, and your plastic polybags and bags against the recycled-content target (both from 1 January 2030 at the earliest), and decide whether any of your transport packaging falls under the reuse targets (Articles 7, 24 and 29). Cardboard mailer boxes are outside the reuse targets; the empty-space rule and the label still apply to them.
Prepare one data carrier for product and packaging. Hold packaging data in the same system as product data, so that the sorting information can appear on product pages before purchase (Article 12(5)) and, once a textile delegated act requires a passport, be provided via the same carrier as the DPP. Follow Have Your Say initiatives 19243 and 15352 and procedure 2025/0395(COD), and review your plan when each is published in the Official Journal.
Frequently asked questions
Do we need an authorised representative for packaging EPR in every country we ship to?
Are dust bags and hangers packaging under the PPWR?
When do our mailer boxes need the harmonised sorting label?
Will our packaging data go into the Digital Product Passport?
Do the reuse targets force us to switch to reusable mailers in 2030?
What has applied to our packaging since 12 August 2026?
Sources
- Packaging Regulation (PPWR)Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (OJ L, 2025/40, 22.1.2025). Recitals 9 and 70; Articles 3, 5, 6, 7, 10, 12, 15, 16, 24, 29, 30, 44, 45, 62, 70 and 71; Annexes I, VII and IX. The English text has not been corrected or amended. CELEX 32025R0040 ↗
- Commission guidanceCommission Notice – Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (C/2026/3084) (OJ C, C/2026/3084, 10.6.2026). Points 1, 3, 13, 18 and 20. CELEX 52026XC03084 ↗
- Suspension proposalProposal for a Regulation of the European Parliament and of the Council suspending the application of the rules on the appointment of an authorised representative for extended producer responsibility for batteries and waste batteries and packaging and packaging waste, COM(2025) 982 final of 10 December 2025, Articles 2 and 3. CELEX 52025PC0982 ↗ European Parliament, Legislative Observatory, procedure 2025/0395(COD). OEIL 2025/0395(COD) ↗ Committee on the Environment, Climate and Food Safety, report A10-0266/2026 (rapporteur Ingeborg Ter Laak), amendments 1 to 14 tabled for plenary on 14 October 2026. A10-0266/2026, amendments 1–14 ↗ European Parliament, amendments adopted on 20 October 2026 on the proposal COM(2025)0982, P10_TA(2026)0345. P10_TA(2026)0345 ↗
- Ecodesign regulation (ESPR)Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC. Article 2, points (27) and (29); Article 10(1). CELEX 32024R1781 ↗
- Commission FAQEuropean Commission, Directorate-General for Environment, Packaging and Packaging Waste Regulation (PPWR) – Frequently Asked Questions, second edition, August 2026 (doi:10.2779/4868962). Sections II, IV, VIII, X, XIII and XVI. Publications Office ↗
- Have Your SayEuropean Commission, Have Your Say initiative 19243, Packaging and packaging waste – new Commission implementing rules on harmonised labels. HYS 19243 ↗ Have Your Say initiative 15352, Packaging and packaging waste – rules on national registers of producers. HYS 15352 ↗
- Commission PPWR pageEuropean Commission, Directorate-General for Environment, Packaging waste. environment.ec.europa.eu ↗
Regulation (EU) 2025/40, Regulation (EU) 2024/1781, Commission Notice C/2026/3084 and COM(2025) 982 were read in the versions published by the EU Publications Office (EUR-Lex); the Publications Office records checked on 21.10.2026 show no act amending Regulation (EU) 2025/40, seven corrigenda to other language versions and no ESPR delegated act for textiles. The Legislative Observatory, the European Parliament's open data and texts adopted, and Have Your Say were accessed on 21.10.2026, and the Commission pages on 20.10.2026. This is general information, not legal, financial or investment advice.