# The PPWR’s 50% empty-space cap exempts parcels shipped in the product’s own box, the route Amazon and Cainiao already run at scale

> Regulation (EU) 2025/40 caps empty space in grouped, transport and e-commerce packaging at 50% from 1 January 2030, or three years after its calculation act if that is later, and asks users of transport packaging for 40% reusable packaging from 2030 while leaving cardboard boxes out; Amazon's Ships in Product Packaging (11% of global shipments in 2025) and Cainiao's original-container shipping (over 680 million packages in FY2025) use the one route Article 24(5) exempts from the cap.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/ecommerce-packaging-amazon-alibaba-ppwr/

**Regulation (EU) 2025/40 caps empty space in grouped, transport and e-commerce packaging at 50% from 1 January 2030, or three years after its calculation act if that is later, and asks users of transport packaging for 40% reusable packaging from 2030 while leaving cardboard boxes out; Amazon's Ships in Product Packaging (11% of global shipments in 2025) and Cainiao's original-container shipping (over 680 million packages in FY2025) use the one route Article 24(5) exempts from the cap.**

The two rules pull e-commerce packaging in different directions. The empty-space cap rewards smaller boxes and parcels with no outer box at all, while the reuse target reaches pallets, crates and possibly flexible formats but not cardboard, so a shift from boxes to mailers can move volume out of one rule and into the other.

## Executive summary

E-commerce packaging gets two numbers in the Packaging and Packaging Waste Regulation (PPWR). Article 24(1) requires any economic operator that fills grouped, transport or e-commerce packaging to keep the empty space ratio at or below 50%, from 1 January 2030 or three years after the Commission's calculation act enters into force, whichever is later. Article 29(1) requires operators that use transport packaging, or sales packaging used for transport, including for products distributed via e-commerce, to make at least 40% of it reusable within a re-use system from 1 January 2030, and to endeavour to reach 70% from 2040 (Commission Notice C/2026/3084, 10 June 2026).

Two carve-outs decide how hard the rules bite on parcels. Article 24(5) exempts operators that use the product's own sales packaging as e-commerce packaging, or reusable packaging within a re-use system, from the 50% cap, though the sales packaging must still meet the Article 10 minimisation rules. Article 29(4)(d) takes boxes made of cardboard or paperboard out of the reuse targets altogether (German text of Articles 24 and 29; Commission guidance, section 27).

Both companies already report large volumes on the exempt route. Amazon shipped 11% of global shipments in 2025 without additional Amazon packaging, and 7.9 billion packages in North America and Europe since 2020 used only the manufacturer's packaging and a label (Amazon 2025 Sustainability Report). Cainiao, Alibaba's logistics arm, shipped over 680 million packages in their original containers in FY2025 (Alibaba FY2025 ESG Report).

Timing is the open question. The empty-space method act is due by 12 February 2028; if it enters into force after 1 January 2027, the cap starts later than 2030. The reuse calculation act is due by 30 June 2027, and the reuse obligation slips only if that act enters into force after 1 July 2028.

For leaders, three moves matter now: measure today's parcels against a provisional 50% test, grow the share of products certified to ship in their own packaging, and map which mailers and transport units may fall inside the Article 29(1) list, because the reuse target is likely to start on time and the cap may not.

## Key findings

1. Article 24(1) sets a maximum empty space ratio of 50% for grouped, transport and e-commerce packaging, applying from 1 January 2030 or three years after the Article 24(2) implementing act enters into force, whichever is later; the act is due by 12 February 2028 (Commission Notice C/2026/3084; Commission PPWR FAQ, August 2026).
2. Article 24(3) counts filling material such as paper, air cushions and foam as empty space, so void fill does not improve the ratio; only a smaller outer pack does (German text of Article 24).
3. Article 24(5) exempts operators that ship products in their own sales packaging, or in reusable packaging within a re-use system, from the 50% cap; Amazon reports 11% of global shipments in 2025 sent without additional Amazon packaging, and Cainiao over 680 million original-container packages in FY2025.
4. Article 29(1) sets a 40% reusable share for transport packaging from 2030, including for products sold via e-commerce, but Article 29(4)(d) excludes cardboard and paperboard boxes (German text of Article 29; Commission guidance, section 27).
5. **SPI calculation:**  an operator whose parcels average 70% empty space today must cut outer box volume by 40% at the same contents to reach 50%; at 60% empty space the cut is 20% (Exhibit 12).
6. Amazon reports 1,199 metric tons of single-use plastic delivery packaging in Europe in 2025, up 34% from 894 tonnes, while also reporting 0% of European shipments containing plastic and saying it has removed single-use plastic delivery packaging from its European distribution network; the report does not reconcile the two.
7. **SPI analysis:**  the two companies' packaging figures cannot be added or ranked. Amazon reports tonnes of plastic delivery packaging by calendar year and region; Cainiao reports tons of material avoided by fiscal year in its own logistics network (Exhibit 11).

## What the PPWR asks of an e-commerce parcel

The PPWR defines e-commerce packaging as a kind of transport packaging: Article 3(8), in the German text, covers transport packaging used to deliver products to end users in online sales or other distance selling. The Commission's FAQ makes the same point, describing it as a special form of transport packaging used for distance sales to end users (PPWR FAQ, August 2026). That classification matters, because it puts parcels inside both the empty-space cap in Article 24 and the transport reuse targets in Article 29.

Article 24 has six paragraphs (Exhibit 2). The paragraph map follows the German text as reproduced by LX Gesetze; the start rule and the 50% figure match Commission Notice C/2026/3084, which quotes Article 24(1) as applying "By 1 January 2030 or 3 years from the entry into force of the implementing acts", whichever is the latest, and the Commission's FAQ, and the Legislative Observatory summary states the same 50% maximum for operators that fill grouped, transport or e-commerce packaging. SPI has not yet confirmed the English wording of every paragraph against the Official Journal text.

The duty follows whoever fills the pack. The Commission's guidance states that the ratio applies to grouped, transport and e-commerce packaging and must be met by the natural or legal person using or filling such packaging (Commission Notice C/2026/3084, section 11; quoted in full under Industry reaction). For a retailer that packs its own orders, that is the retailer; for a marketplace seller using a fulfilment service, it is whoever puts the goods in the box. The FAQ adds that, unlike Article 10, Article 24 has no exemption for packaging protected by design rights or trademarks.

Article 10 is the general minimisation duty behind the number. By 1 January 2030, manufacturers and importers must cut packaging weight and volume to the minimum needed for its function, and features meant only to increase perceived volume, such as double walls and false bottoms, are barred, with exemptions for designs and trademarks protected before 11 February 2025 and for geographical indications (Commission guidance, section 10; [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/)). The Commission notes that consumer acceptance and marketing no longer justify extra weight or volume, and that the existing EN 13428:2004 standard applies until the end of 2029.

Sales packaging gets no fixed ratio. The FAQ states that the PPWR sets no maximum threshold for sales packaging, and leaves it to the filler to minimise empty space and record it in the technical documentation. Article 24(6) asks the Commission to consider, by 12 February 2032, whether ratios should be set for the sales packaging of toys, cosmetics, do-it-yourself kits and electronics, which are among the product groups most often sold online.

SPI analysis

Article 24(5) changes the economics of shipping in the product's own box. A parcel shipped in its sales packaging leaves the 50% test, but the brand that made that box carries the Article 10 duty, and the Article 24(6) review could later bring a ratio to the sales packaging itself. Programmes such as Amazon's certification of products for Ships in Product Packaging therefore move compliance work upstream to brand owners rather than removing it.

## Reuse targets: 40% for transport packaging, with cardboard left out

Article 29 is the second rule a parcel network meets, and its reach is set by a list of forms. In the Commission's reading, from 1 January 2030 operators that use transport packaging, or sales packaging used for transporting products, including for products distributed via e-commerce, within the Union, in the form of pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters of any size or material, including flexible formats and pallet wrappings or straps, must make at least 40% of that packaging reusable within a re-use system (Commission guidance, section 18). Exhibit 3 maps the paragraphs that bear on e-commerce and logistics.

The cardboard carve-out is the headline for parcel networks. Article 29(4)(d) excludes boxes made of cardboard or paperboard from paragraphs 1 to 3, and the Commission's guidance says Member States cannot set re-use targets for transport packaging such as cardboard boxes, which it describes as expressly exempted from re-use under the PPWR (section 27). The same section says Member States cannot make the indicative 2040 targets binding.

Imports are counted from the first warehouse in the Union. The guidance explains that the targets apply to imported goods after they are placed on the EU market, from the first warehouse where they are stored and unpacked to their final destination; a consignment for a single final destination need not be unpacked and repacked, but distribution centres and logistics hubs are not final destinations (section 19; [PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/)). A delegated act adopted in February 2026 exempts certain operators that use pallet wrappings and straps from the 100% reuse requirements (Green Forum timeline).

SPI analysis

For an e-commerce network the cardboard exclusion means the corrugated box, the largest single format in most parcel flows, sits outside the 40% target. What remains inside are the units that move goods into and between warehouses, such as pallets, plastic crates and totes, and possibly flexible formats. Whether a paper or plastic mailer bag counts as a flexible format within the Article 29(1) list is not settled in the guidance SPI has read; SPI has not yet confirmed how the Article 30(3) calculation act will treat mailers. A move from boxes to bags could therefore take parcels out of a reuse-exempt format and into a counted one. Check with counsel before relying on either reading.

The Spanish layer sits above the EU one. Royal Decree 1055/2022 already sets a national target of 20% reusable commercial and industrial packaging in 2030 and 30% in 2035 ([PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/)), and the Commission lists Article 29 among the provisions that leave room for national measures ([PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/) rule notes).

## When the rules start

Both 2030 dates are conditional, and the conditions differ. The empty-space cap starts three years after its method act enters into force if that is later than 1 January 2030, so any entry into force after 1 January 2027 moves it. The obligation to demonstrate the reuse targets starts 18 months after its calculation act if that is later, so only an entry into force after 1 July 2028 moves it (Exhibit 4).

**SPI calculation:**  if the empty-space method act is published on its 12 February 2028 deadline and enters into force on 3 March 2028, the cap starts on 3 March 2031, 14 months after the date usually quoted. A reuse calculation act in force on 20 July 2027 gives 20 January 2029 at 18 months, earlier than 1 January 2030, so the reuse date holds.

The planning consequence runs against the order in which the rules are usually discussed. The reuse target, which most commentary treats as the harder rule, is the one most likely to start on 1 January 2030; the 50% cap, which many parcel networks are already preparing for, may not bite until 2031. [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/) in the SPI tracker records 1 January 2030 as its date, which is the earliest possible start.

## A framework: four parcel routes under the PPWR

The two rules combine into four routes a product can take to an EU customer (Exhibit 5). SPI sorts them by whether the 50% cap applies and whether the pack counts toward the Article 29 reuse targets. The device is an SPI planning tool built from Articles 24 and 29, not a legal classification.

**Route 1, own container.**  This is the only route outside both numeric tests, provided the sales packaging is cardboard. Its cost moves to the brand, which must meet Article 10 and be able to show it.

**Route 2, single-use box.**  This is the route the 50% cap was written for. A box is outside the reuse target, so the only lever is size: Article 24(3) counts paper and air cushions as empty space, so the fix is a smaller box or a better match between order and box, not more filler.

**Route 3, mailer.**  A bag or envelope that wraps the product closely may meet a ratio more easily than a box, but SPI has not yet confirmed how the Article 24(2) method will measure a flexible pack, and the Article 29(1) list includes flexible formats. This route carries the most legal uncertainty.

**Route 4, reusable unit.**  Reusable packaging within a re-use system is outside the cap and is what the reuse target asks for. The cost is the re-use system itself: return logistics, reconditioning and, for closed loops, labels and data carriers under Article 12.

SPI analysis

The framework shows why a parcel network's 2030 plan has two halves. The outbound parcel to a consumer sits mostly in routes 1 to 3, where the cap matters and reuse is optional. The inbound and inter-site flows, pallets, crates and totes, sit in route 4, where Article 29(2) asks for 100% reusable packaging between an operator's own sites from 2030.

## Amazon: paper in Europe, plastic in North America

Amazon publishes no numeric packaging target with a target year; it reports annual metrics on the delivery packaging it adds to customer orders, by region (SPI Packaging Buyers Database, Amazon profile). Its 2025 Sustainability Report, published in August 2026, gives the plastic series by region (Exhibits 6 and 7). Manufacturer packaging of the products it sells is outside these figures.

The European numbers point two ways. Amazon reports 0% of European shipments containing plastic in 2024 and 2025, and a footnote states that Amazon has removed single-use plastic delivery packaging from its European distribution network. The same table shows 1,199 metric tons of single-use plastic delivery packaging in Europe in 2025, against 894 tonnes in 2024 and 877 tonnes in 2023, a rise of 34% in the latest year (Exhibit 7). The report does not explain which formats make up the European tonnage.

**SPI calculation:**  Europe's 1,199 tonnes are 1.6% of Amazon's 74,073 tonnes of global plastic delivery packaging in 2025, and North America's 68,196 tonnes are 92.1%. Under the PPWR, the plastic question for Amazon is small in tonnage; the larger EU questions are box size and the format of its paper mailers.

Paper replaced plastic in Europe first. Amazon's packaging page, updated on 26 August 2026, says that across its European fulfilment network it replaced single-use plastic delivery bags and air pillows with recyclable paper and cardboard, a change dated to 2022. It reports a paper-padded envelope in Europe with a 100% paper-based lining, recyclable in household recycling, and says more than 50% of shipments in North America and Europe used lightweight bags or envelopes in 2025, which it describes as up to 90% lighter than comparable cardboard boxes. All plastic air pillows were removed from delivery packaging at global fulfilment centres as of October 2024 and replaced with paper filler made from 100% recycled content.

In practice: Amazon in Europe.

The 2025 report states that, beginning in 2025, Amazon installed automated packaging machines in European fulfilment centres that create custom-sized cardboard boxes and paper bags in real time, matching packaging to each item (p. 23). That is route 2 and route 3 of Exhibit 5 at the point of packing. Custom-sized boxes address the Article 24 ratio directly, and the paper filler that replaced air pillows still counts as empty space under Article 24(3). Amazon also reports avoiding 5.4 million metric tons of packaging materials in North America and Europe since 2015 by using lighter, right-sized packaging (p. 21). SPI has not yet confirmed any Amazon figure for the empty space ratio of its European parcels.

In practice: Amazon Ships in Product Packaging.

Amazon reports that 11% of global shipments in 2025 went without additional Amazon packaging, that 28 million unique products were certified for the programme, and that 7.9 billion packages in North America and Europe since 2020 used only the manufacturer's packaging and an Amazon shipping label (2025 Sustainability Report, p. 21). These parcels follow route 1, the one Article 24(5) exempts. The report also announces a 2026 pilot to prevent over-boxing of eligible products. Neither figure is split by EU country.

Amazon's exposure goes beyond the cap. The SPI Buyers Database profile lists [PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/), [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/) and [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/) among its EU rules, with country sites for France, Germany, Italy, Poland and Spain, and Germany net sales of USD 45,900 million in 2025. As a user of pallets, totes and crates between its own sites, Amazon is also an operator under Article 29(2) from 2030. Amazon's report shows expanded use of universal plastic pallets and GoCarts avoiding 35 million wood pallets, without a regional split (p. 19).

## Alibaba and Cainiao: original boxes, reused cartons and circulation boxes

Alibaba also sets no numeric packaging target. What it reports are outcomes from Cainiao's logistics operations for FY2025, the year from 1 April 2024 to 31 March 2025, and they cover Cainiao only, not the packaging that merchants on Taobao, Tmall, Lazada or AliExpress use (SPI Packaging Buyers Database, Alibaba profile; Alibaba FY2025 ESG Report, p. 5). Exhibit 9 sets out the figures.

The split matters for reading Cainiao against the PPWR. The report attributes around 138,000 tons to source-reduction initiatives in the fiscal year and around 31,000 tons to circulation boxes and reused cardboard (Exhibit 10). SPI calculation: 138,000 is about 82% of the 169,000 total, and 31,000 about 18%.

In practice: Cainiao.

Cainiao's three reported practices line up with three of the four routes in Exhibit 5. Original-container shipping, over 680 million packages in FY2025, is route 1. Reusing nearly 36 million cardboard boxes is a variant of route 2: a reused carton is still a cardboard box, which Article 29(4)(d) leaves outside the reuse targets, and the PPWR's reuse definitions rest on a re-use system rather than ad hoc second use. Circulation boxes for merchant warehouses, more than 1.33 million deployments cumulatively from a pool of about 143,000 by 31 March 2025, are route 4. These are operations in China, and the report gives no figure for Europe.

Alibaba's EU link runs through AliExpress, where SPI has least data. The FY2026 results credit improved operating efficiency at AliExpress and higher revenue from it for the International Digital Commerce Group's FY2026 revenue of RMB 144,170 million, but name no European markets (Alibaba FY2026 results, 13 May 2026). SPI has not yet confirmed which EU countries AliExpress ships to from Alibaba's own filings, or how Article 24 applies to a parcel filled outside the Union and sent to an EU consumer; the FAQ places the duty on the operator that fills the pack and makes the product available on the market.

## Why the two companies' numbers do not add up

The two companies report packaging on different bases, so their figures sit side by side here and are never added or ranked (Exhibit 11). The point is not to score one against the other but to show what a regulator or customer would need to ask each for under the PPWR.

SPI analysis

Neither company publishes the two numbers the PPWR will test, the empty space ratio of filled parcels and the reusable share of transport packaging used in the EU. Both will need them for EU operations from 2030, and Article 29(17) sets the count per calendar year, which for Alibaba differs from its fiscal year. The [buyers database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) records both companies' figures as published, and the sister pieces on [retailer supplier rules](https://www.strategicpackaginginsights.com/insights/retailer-packaging-supplier-rules-compared/) and [food companies' pledges](https://www.strategicpackaginginsights.com/insights/fmcg-packaging-pledges-compared/) show the same pattern of incomparable definitions in other sectors.

## Scenarios: how much smaller a box must get

The 50% cap translates into a simple box-size test. Under Article 24(3) the ratio is the empty space, including any filler, over the outer volume, so a pack at the limit has an outer volume no more than twice the volume of the sales packaging inside. SPI ran the arithmetic for a range of starting ratios (Exhibit 12). The starting ratios are illustrative, because SPI has not yet confirmed any company's published parcel ratios and the official method is not yet adopted.

**SPI calculation:**  in the base case, a box with 3.3 units of volume for each unit of product must shrink to 2.0 units, a 40% cut; at 80% empty space the cut is 60%. Replacing air pillows with paper, as Amazon did, does not change the ratio, because both count as empty space.

The arithmetic also shows the value of route 1. A parcel shipped in its own container leaves the test, so every product moved into Ships in Product Packaging or original-container shipping removes one parcel from the denominator of any internal compliance measure. For a mixed order of several products, the outer box must fit all of them at 50% or better, and the Article 24(2) method is meant to address multi-item packs.

SPI analysis

The cut needed is larger than it looks, because box ranges are discrete. An operator with ten box sizes cannot fit every order exactly, and the Article 24(2) method will decide how much tolerance there is. On-demand packing, of the kind Amazon reports installing in European fulfilment centres from 2025, removes the discrete-size problem for the orders it handles.

## China's parcel rules, briefly

Cainiao's home market measures parcels differently. China's mandatory express packaging standard GB 45186-2024, in force since 1 July 2026, tests box fit, layers and tape rather than a single ratio, and the State Post Bureau's rules sit alongside it; the [Ledger piece on China's packaging rules](https://www.strategicpackaginginsights.com/insights/china-packaging-rules-ecological-environment-code/) covers them in full. [PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/) in the SPI tracker records the earlier express packaging measures. A parcel designed to pass the Chinese tests is not, by that fact, compliant with the EU ratio, and the reverse also holds.

## Industry reaction

> "Online shops will have to reduce the empty space in delivery boxes."

***European Commission** , Directorate-General for Environment, [Facts about the new EU rules on packaging and packaging waste](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en), consulted 23 October 2026*

The page adds that this means smaller boxes and fewer half-empty boxes being shipped, with products still protected.

> "The empty space ratio in Article 24 applies to grouped, transport, and e-commerce packaging and needs to be complied with by the natural or legal person using or filling such packaging."
>
>
>
> **European Commission** , [Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084), section 11, 10 June 2026
>
>
>
> "We are piloting a new initiative in 2026 to prevent over-boxing of eligible products"
>
>
>
> **Amazon** , online retailer, [2025 Sustainability Report](https://sustainability.aboutamazon.com/2025-amazon-sustainability-report.pdf), page 21, August 2026
>
>
>
> "In FY2025, over 680 million packages were shipped with SIOC."

***Alibaba Group** , on its logistics arm Cainiao, [FY2025 ESG Report](https://www.sec.gov/Archives/edgar/data/1577552/000110465925062815/tm2519164d1_ex99-2.pdf), page 9, June 2025*

Neither company's report mentions the PPWR in its packaging section.

## What leaders should do now

1. **E-commerce and fulfilment leads, by 30 June 2027:**  sample outbound EU parcels by box size and order mix and record a provisional empty space ratio with filler counted as empty space, so the gap to 50% is known before the Article 24(2) method arrives.
2. **Packaging engineers, before the 2027 equipment budget:**  plan box ranges and on-demand packing so that the most common orders can meet 50%, and treat void fill as a protection choice, not a compliance tool.
3. **Brand owners selling through marketplaces, during 2027:**  test which products can ship in their own packaging, and hold Article 10 minimisation evidence for those boxes, because the Article 24(5) exemption moves the duty to them.
4. **Logistics and procurement teams, by 31 December 2027:**  map pallets, crates, totes, wraps and mailers by route (own sites, same Member State, cross-border, imports from the first warehouse), and flag which fall inside the Article 29(1) list, to plan for a 40% reusable share from 1 January 2030.
5. **Regulatory affairs, within a month of each act:**  read the Article 30(3) reuse calculation act, due by 30 June 2027, and the Article 24(2) method act, due by 12 February 2028, and reset both start dates from their entry into force; check with counsel how mailers are treated.
6. **Sustainability reporting teams, for the 2027 report:**  add an EU empty space ratio and an EU reusable transport packaging share to the packaging disclosure, on a calendar-year basis.
7. **Boards, at the next strategy review:**  ask for the EU parcel plan in both halves, outbound parcels against the cap and inbound and inter-site flows against the reuse targets, with the cost of each.

## Questions for your board

- What is the average empty space ratio of our EU parcels today, measured with filler counted as empty space?
- What share of our EU orders could ship in the product's own packaging, and who carries the Article 10 duty for those boxes?
- Which of our transport and e-commerce packaging formats fall inside the Article 29(1) list, and what is our reusable share of them now?
- Are our mailers inside or outside the reuse target, and what is our plan under each reading?
- How do our plans change if the empty-space cap starts in 2031 but the reuse obligation starts in 2030?
- Can we report the two numbers the PPWR will test, by calendar year and by Member State?

## What to watch

- **12 Feb 2027:**  the Commission's standardisation request on packaging minimisation under Article 10(3) is due, including maximum empty space for common formats where relevant.
- **30 Jun 2027:**  the implementing act on calculating the Article 29 reuse targets is due; its entry into force sets the reuse start date if later than mid-2028 ([PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/)).
- **12 Feb 2028:**  the Article 24(2) empty space ratio method is due; its entry into force plus three years sets the cap's start if later than 2030 ([PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/)).
- **1 Jan 2030:**  earliest start of the 50% cap and of the 40% transport reuse target; Article 10(1) and (2) apply.
- **12 Feb 2032:**  the Commission reviews the 50% ratio and the Article 24(5) exemptions, and assesses ratios for sales packaging of toys, cosmetics, kits and electronics.
- **1 Jan 2034:**  the Commission reports on the 2030 reuse targets and the feasibility of the 2040 levels.
- **1 Jan 2040:**  operators endeavour to reach 70% reusable transport packaging.

## Methodology

- **Data used:**  the SPI Regulation Tracker and rule notes for [PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/), [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/), [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), [PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/) and [PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/), among 3 reuse-target and 6 design rules in the [tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/); the SPI Packaging Buyers Database profiles for Amazon and Alibaba, two of 42 companies; and the official and company sources listed below, consulted 23 October 2026.
- **PPWR text:**  the 50% figure and the start rule come from Commission Notice C/2026/3084, the Commission's PPWR FAQ (August 2026) and the Legislative Observatory summary; the paragraph maps for Articles 3, 24, 29 and 30 come from the German text as reproduced by LX Gesetze. SPI has not yet confirmed the English wording against the Official Journal text.
- **Company data:**  Amazon's 2025 Sustainability Report and its packaging page updated on 26 August 2026; Alibaba's FY2025 ESG Report and FY2026 results; Cainiao's ESG page. All figures are self-reported and are shown with their period and scope. No figure is summed, averaged or ranked across the two companies.
- **Calculations:**  Exhibit 4 assumes entry into force 20 days after publication. Exhibit 12 applies the Article 24(3) definition to illustrative ratios. No currencies are used in any calculation.
- **Cut-off:**  23 October 2026.
- **Limitations:**  the calculation acts are not adopted; Alibaba's FY2026 ESG figures and AliExpress's EU footprint are not confirmed; neither company reports EU parcel ratios. This is business analysis, not legal advice; check with counsel.

## Sources

1. LX Gesetze, Art. 3, Art. 24, Art. 29 and Art. 30 PPWR, German text of Regulation (EU) 2025/40 as reproduced, [https://lxgesetze.de/ppwr/24](https://lxgesetze.de/ppwr/24), [https://lxgesetze.de/ppwr/29](https://lxgesetze.de/ppwr/29), [https://lxgesetze.de/ppwr/30](https://lxgesetze.de/ppwr/30) and [https://lxgesetze.de/ppwr/3](https://lxgesetze.de/ppwr/3), consulted 2026-10-23.
2. EUR-Lex, Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (OJ C, 10 June 2026), sections 10, 11 and 18 to 27, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084), consulted 2026-10-23.
3. European Commission (DG ENV), Packaging and Packaging Waste Regulation (PPWR) Frequently Asked Questions, August 2026 edition, catalogue KH-01-26-068-EN-N (copy hosted by CIBUM), Sections I, II, VII, X and XI, [https://cibum.gr/wp-content/uploads/2026/08/packaging-and-packaging-waste-regulation-ppwr-KH0126068ENN.pdf](https://cibum.gr/wp-content/uploads/2026/08/packaging-and-packaging-waste-regulation-ppwr-KH0126068ENN.pdf), consulted 2026-10-23.
4. EUR-Lex, Regulation (EU) 2025/40, OJ L 22.1.2025, recitals 61, 84, 86, 91, 94 and 95, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-23.
5. European Parliament Legislative Observatory, Regulation (EU) 2025/40 summary, [https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233](https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233), consulted 2026-10-23.
6. European Commission Green Forum, Packaging and Packaging Waste Regulation implementation, [https://green-forum.ec.europa.eu/green-business/packaging-and-packaging-waste-regulation-implementation_en](https://green-forum.ec.europa.eu/green-business/packaging-and-packaging-waste-regulation-implementation_en), consulted 2026-10-23.
7. European Commission (DG ENV), Facts about the new EU rules on packaging and packaging waste, [https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en), consulted 2026-10-23.
8. European Parliament, Texts adopted TA-9-2024-0318, legislative resolution of 24 April 2024 on packaging and packaging waste, [https://www.europarl.europa.eu/doceo/document/TA-9-2024-0318_EN.html](https://www.europarl.europa.eu/doceo/document/TA-9-2024-0318_EN.html), consulted 2026-10-23.
9. Amazon, 2025 Sustainability Report (August 2026), pages 3, 19 and 21 to 23, [https://sustainability.aboutamazon.com/2025-amazon-sustainability-report.pdf](https://sustainability.aboutamazon.com/2025-amazon-sustainability-report.pdf), consulted 2026-10-23.
10. Amazon, How Amazon is reducing packaging, first published 13 December 2022, updated 26 August 2026, [https://www.aboutamazon.com/md/news/sustainability/how-amazon-is-reducing-packaging](https://www.aboutamazon.com/md/news/sustainability/how-amazon-is-reducing-packaging), consulted 2026-10-23.
11. Alibaba Group, FY2025 ESG Report, furnished on SEC Form 6-K as Exhibit 99.2 (June 2025), pages 5, 9 and 43, [https://www.sec.gov/Archives/edgar/data/1577552/000110465925062815/tm2519164d1_ex99-2.pdf](https://www.sec.gov/Archives/edgar/data/1577552/000110465925062815/tm2519164d1_ex99-2.pdf), consulted 2026-10-23.
12. Alibaba Group, Announcement of the March Quarter 2026 Results and Fiscal Year 2026 Annual Results (HKEX, 13 May 2026), [https://www1.hkexnews.hk/listedco/listconews/sehk/2026/0513/2026051300653.pdf](https://www1.hkexnews.hk/listedco/listconews/sehk/2026/0513/2026051300653.pdf), consulted 2026-10-23.
13. Alibaba Group, Form 6-K of 18 June 2026 furnishing the FY2026 Hong Kong annual report and ESG report (filing index), [https://www.sec.gov/Archives/edgar/data/1577552/000119312526274928/](https://www.sec.gov/Archives/edgar/data/1577552/000119312526274928/), consulted 2026-10-23.
14. Alibaba Group Holding Limited, Form 20-F for the fiscal year ended 31 March 2026, [https://www.sec.gov/Archives/edgar/data/0001577552/000119312526231755/baba-20260331.htm](https://www.sec.gov/Archives/edgar/data/0001577552/000119312526231755/baba-20260331.htm), consulted 2026-10-23.
15. Cainiao, ESG: Environmental, [https://www.cainiao.com/en/esg-environmental.html](https://www.cainiao.com/en/esg-environmental.html), consulted 2026-10-23.
16. SPI Packaging Buyers Database, profiles for Amazon and Alibaba Group (prepared 13 October 2026, analysis of 14 October 2026), /data/packaging-buyers-database/, consulted 2026-10-23.
17. SPI Regulation Tracker and rule notes PR-EU-006, PR-EU-009, PR-EU-010, PR-ES-002 and PR-CN-002, /data/packaging-regulation-tracker/european-union/, consulted 2026-10-23.
18. SPI Ledger, China's packaging rules after the Ecological Environment Code (Ledger 19), /insights/china-packaging-rules-ecological-environment-code/, consulted 2026-10-23.