Yes for mailers and courier bags. Under the EU packaging regulation (PPWR), the boxes, mailers and bags used to deliver online orders are e-commerce packaging and have been in scope since 12 August 2026. Void fill is not named as packaging, but it counts as empty space, so it cannot help a parcel pass the 50% empty-space cap.
What counts as e-commerce packaging?
The regulation defines it as transport packaging used to deliver products sold online or by other distance sales to the end user. That covers the outer box, the padded mailer and the plastic courier bag, along with the tape and the shipping label stuck on them. A mailing pouch holding a magazine is listed as packaging too.
How is void fill treated?
Paper cuttings, air cushions, bubble wrap, foam and polystyrene chips all count as empty space. The empty space in e-commerce, grouped and transport packaging may not exceed 50%. That cap starts on 1 January 2030, or three years after the Commission sets the measuring method, due by 12 February 2028, if that comes later. Plastic loose-fill chips go further: they join the EU’s list of banned single-use plastic products from 12 February 2029. The minimisation and empty-space answer covers the cap in detail.
One route avoids the cap. A product shipped in its own sales packaging, with no outer box, is exempt from the 50% limit, though the general minimisation rules still apply to it.
Example: one product, two box sizes
Example. An online shop ships a product in a 4-litre retail box. Inside a 10-litre mailer box, the empty space is 6 litres, a ratio of 60%, which is over the cap. In an 8-litre mailer the ratio is 50%, exactly at the cap. Filling the gap with paper changes neither result, because the paper counts as empty space.
What else applies, and what is still open?
| Point | Status on 26 October 2026 |
|---|---|
| Mailers and courier bags are packaging, heavy-metal cap applies | Decided, since 12 August 2026 |
| Sorting label on e-commerce packaging, unlike other transport packaging | Decided, from 12 August 2028 or 24 months after the label rules, whichever is later |
| Whether a plastic mailer counts toward the 40% transport reuse target | Open, waits on counting rules due by 30 June 2027 |
Where this comes from: Regulation (EU) 2025/40, Articles 3(1)(8), 12(1), 24, 29(1), 67(5) and 71, Annex I; PPWR FAQ, 2nd edition, section II.4.
More on this: EU PPWR guide · EU PPWR compliance
Reviewed by Team GreenSutra on 26 October 2026.