Is a fulfillment service provider automatically the party placing the packaging it uses on the market?

Not necessarily. The decisive factor is who procures the packaging materials and in whose name they are first made available on the EU market. If your client orders the cartons and hands them to you for filling, they generally remain the party responsible for placing them on the market. However, if you procure the materials yourself – even if they are neutral or white-label – PPWR responsibility shifts to you. A clear contractual arrangement is essential.

What applies to air cushion film and paper cushioning that we order directly from our supplier?

Void fill materials such as air cushion film, paper cushioning, or foam inserts are considered packaging within the meaning of the PPWR. If you procure these materials yourself and use them in the dispatch process, you are responsible for their compliance – this includes labeling requirements, recycled content levels (mandatory on a graduated basis from 2030), and documentation obligations. Request corresponding declarations of conformity from your suppliers.

Do we need to re-label our white-label cartons?

Yes, if you qualify as the party placing them on the market. The PPWR requires that packaging be marked with harmonized symbols indicating recyclability and material separation. The specific implementation of the labeling obligations will be set out in delegated acts by the European Commission; the key date of 12.08.2026 marks the beginning of the application of the framework regulation. Work together with your packaging supplier to determine which markings can already be applied to the cartons now.

Does the PPWR also apply to parcel labels and shipping labels?

Parcel labels as such are not considered packaging within the meaning of the PPWR. However, carrier materials for labels (e.g. paper or plastic loops that remain permanently attached to the packaging) may be classified as a packaging component and are then subject to the corresponding requirements. If in doubt, contact your IHK or a lawyer specializing in EU packaging law to obtain a binding classification.

Branchenguide · PPWR

PPWR for Logistics & Fulfillment Service Providers: Who Is the Party Responsible for Placing Goods on the Market from 12.08.2026?

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) confronts logistics and fulfillment service providers with a central question: who actually qualifies as the party placing goods on the market – the manufacturer, the online retailer, or the fulfillment center? From the key date of 12.08.2026 onwards, incorrect assumptions can lead to substantial fines and operational disruptions. This article clarifies what specifically applies to your industry – from white-label cartons and parcel labels through to air cushions.

Placing on the Market in Fulfillment: The Decisive Distinction

Under Regulation (EU) 2025/40, the party placing goods on the market is defined as anyone who makes packaging or packaged goods available on the EU market for the first time. In the classic fulfillment model, this is generally the client – i.e. the retailer or manufacturer on whose behalf you dispatch the goods. However, as soon as you use your own branded packaging materials or procure and pass on packaging in your own name, the responsibility shifts.

Practical tip: For each client project, establish contractually who procures the packaging materials and whose name or brand appears on the carton. Record this distinction in writing – in case of doubt, the relevant authority will decide based on actual economic conduct, not on the wording of contracts.

White-Label Cartons and Branded Adhesive Tape: Where the Obligation Arises

If you operate a fulfillment center and order neutral or custom-labeled shipping cartons that you then adapt to your clients' SKUs, you are considered the party placing those cartons on the market. The same applies to branded adhesive tape bearing your logo and to cushioning material that you procure and use under your own name.

For such packaging, the PPWR prescribes, among other things:

Minimum recycled content requirements (graduated by packaging type, mandatory from 2030 with a transitional target for 2026)
Labeling obligations for recyclability and material separation
Registration and reporting obligations in the national producer register (in Germany: LUCID with the Dual System)
Volume reduction targets for unnecessary packaging volumes

Practical tip: Maintain an internal packaging register that records for each material item: who is the procurer, whose brand the material carries, and in which country it is first placed on the market. This register forms the basis of your PPWR compliance.

Parcel Labels and Digital Accompanying Documents

Parcel labels themselves are not considered packaging within the meaning of the PPWR. They are, however, relevant when they are inseparably connected to a packaging component – for example as permanently printed labels on outer packaging. Be aware that adhesive label carriers (e.g. paper loops or carrier materials) may also fall under the labeling requirements.

Air Cushions and Void Fill Material: Underestimated Volume Relevance

Air cushion film, paper cushioning, and similar void fill material count as packaging. If you procure these materials yourself and use them in the dispatch process, you are responsible for their PPWR compliance. The regulation also requires that void space in packaging be reduced to a minimum – an aspect that can already be addressed today in automated fulfillment lines by adjusting carton sizes or quantities of fill material.

Practical tip: Commission a packaging optimization process in accordance with DIN EN ISO 11607 or a comparable method and document the results. This not only establishes PPWR compliance but simultaneously reduces material costs and your CO₂ footprint.

Recommended Actions Before 12.08.2026

1. Contract audit: Clarify in writing with each client who is placing which packaging components on the market. 2. Material inventory: Record all packaging materials you procure yourself and review recycled content levels and current labeling status. 3. LUCID registration: Ensure that all parties placing goods on the market – whether yourself or your clients – are correctly registered. 4. Supplier agreements: Request written declarations of conformity with the PPWR from your suppliers.

For legally binding guidance on your individual situation, contact your relevant Chamber of Industry and Commerce (IHK).

Häufige Fragen

Is a fulfillment service provider automatically the party placing the packaging it uses on the market?: Not necessarily. The decisive factor is who procures the packaging materials and in whose name they are first made available on the EU market. If your client orders the cartons and hands them to you for filling, they generally remain the party responsible for placing them on the market. However, if you procure the materials yourself – even if they are neutral or white-label – PPWR responsibility shifts to you. A clear contractual arrangement is essential.
What applies to air cushion film and paper cushioning that we order directly from our supplier?: Void fill materials such as air cushion film, paper cushioning, or foam inserts are considered packaging within the meaning of the PPWR. If you procure these materials yourself and use them in the dispatch process, you are responsible for their compliance – this includes labeling requirements, recycled content levels (mandatory on a graduated basis from 2030), and documentation obligations. Request corresponding declarations of conformity from your suppliers.
Do we need to re-label our white-label cartons?: Yes, if you qualify as the party placing them on the market. The PPWR requires that packaging be marked with harmonized symbols indicating recyclability and material separation. The specific implementation of the labeling obligations will be set out in delegated acts by the European Commission; the key date of 12.08.2026 marks the beginning of the application of the framework regulation. Work together with your packaging supplier to determine which markings can already be applied to the cartons now.
Does the PPWR also apply to parcel labels and shipping labels?: Parcel labels as such are not considered packaging within the meaning of the PPWR. However, carrier materials for labels (e.g. paper or plastic loops that remain permanently attached to the packaging) may be classified as a packaging component and are then subject to the corresponding requirements. If in doubt, contact your IHK or a lawyer specializing in EU packaging law to obtain a binding classification.

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