RE-ZIP joins industry effort to keep e-commerce packaging inside the EU’s reuse targets.
The Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) was written to do exactly what RE-ZIP does: build reusable packaging systems at scale. Article 29(1) sets a target that, from 1 January 2030, at least 40% of transport packaging — explicitly including packaging used for products distributed via e-commerce, and explicitly including “flexible formats” — must be reusable within a reuse system.
A narrowing interpretation
Over the past months, however, the European Commission’s practical reading of Article 29(1) has moved in a different direction. Cardboard boxes used for e-commerce shipments have already been read out of scope, and ongoing discussions suggest flexible formats such as envelopes and mailer bags could be next. E-commerce packaging today splits roughly 50/50 between the two formats, so excluding both would take the entire e-commerce category out of the reuse target, not just a share of it. That would go directly against what the Parliamentarians voted for when adopting PPWR.
Mobilizing the industry
RE-ZIP is coordinating with other reusable-packaging providers through New ERA’s E-Commerce Working Group to push back on this narrow reading. The working group has written directly to the Commission and, on 8 September, presented its case to Commission officials in Brussels, arguing that the plain text of Article 29(1) — which names e-commerce and flexible formats explicitly — supports a broad interpretation, not a narrow one.
The effort also extends to the European Parliament, where RE-ZIP is engaging Members of the European Parliament to help carry the legislative-intent argument back to the Commission. The working group will continue making its case publicly in the months ahead.
Why it matters
If e-commerce packaging is excluded, the PPWR’s reuse target risks becoming a rule that skips the category it was arguably designed to transform. RE-ZIP believes the law, read as written, already includes e-commerce — and is working to make sure it stays that way in practice, not just on paper.
“Flexible formats and e-commerce aren’t a footnote in Article 29(1) — they’re written directly into the text. If the Commission interprets this narrowly, we’d be excluding the very packaging category the reuse target was designed to transform. We’re not asking for a favor; we’re asking the Commission to read its own law.”
– Daniel Nygaard, Director Northern Europe, RE-ZIP
We’ll keep sharing updates as this advocacy work develops.
The LIFE RE-ZIP project is co-funded by the European Union under project LIFE22-ENV-DK-LIFE-RE-ZIP-101113962. Views and opinions expressed are those of the author(s) only and do not necessarily reflect those of the European Union or CINEA. Neither the European Union nor the granting authority can be held responsible for them.