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

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). 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.

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). A delegated act adopted in February 2026 exempts certain operators that use pallet wrappings and straps from the 100% reuse requirements (Green Forum timeline).

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), and the Commission lists Article 29 among the provisions that leave room for national measures (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 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.

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.

Amazon’s exposure goes beyond the cap. The SPI Buyers Database profile lists PR-EU-006, PR-EU-009 and 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%.

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.

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.

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 covers them in full. 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.