PPWR at two months: e-commerce void fill, PFHxA gaps, and the SME rule fight

Regulation (EU) 2025/40 has now been in general application for two months. Trade press retrospectives published this week, from Packaging Europe and Packaging Gateway, give the first real read on where compliance is working and where it isn’t. Three threads stand out: e-commerce packaging is proving harder to measure than expected, PFAS compliance work on PFHxA is turning up recurring errors, and small firms are pushing back on an obligation that was already due to be suspended by proposal.

Void fill now counts, and e-commerce feels it first

Packaging Gateway reports that void fill materials, the air pillows, paper crumple and foam inserts used to stop products moving in transit, now count directly against the PPWR’s empty-space ratio requirement for grouped, transport and e-commerce packaging. The regulation sets a maximum 50% empty-space ratio from 1 January 2030, subject to the usual caveat that dates tied to pending implementing acts can shift later.

That sounds distant, but Packaging Gateway’s reporting and a related piece on cross-border e-commerce make clear that packaging teams are already redesigning now. Void fill has traditionally been treated as a protective add-on, not part of the packaging-to-product ratio calculation. Under PPWR it is part of the packaging system being measured, which means a box that passes today’s damage-rate targets might fail the 2030 empty-space threshold if it relies on loose fill rather than right-sized cartons or fitted inserts.

The cross-border angle matters because an online retailer shipping the same SKU from a single EU fulfilment centre to multiple member states has to meet one empty-space rule, but national enforcement capacity and guidance interpretation still vary. Packaging Gateway notes this is creating friction for retailers who standardised packaging across borders expecting a single EU standard to behave like a single national one. It doesn’t, yet, because enforcement and verification infrastructure is still being built out by member states at different speeds.

For converters and brand owners, the practical task is auditing current transport and e-commerce packaging against the 50% ratio now, not in 2029. Redesign cycles for cartons and void-fill systems take time, and firms that start testing right-sizing equipment and fitted inserts this year will have more design options than those who wait for a national enforcement notice.

PFHxA assessments: a narrower problem than PFAS limits, but a real one

A Lexology analysis published this week looks specifically at PFHxA, perfluorohexanoic acid, and where compliance assessments for it go wrong. This sits alongside, but is distinct from, the PPWR’s own PFAS limits for food-contact packaging that took effect on 12 August 2026: 25 ppb for any single PFAS substance, 250 ppb for the sum of PFAS, and 50 ppm total fluorine, with no stock-exhaustion period for non-compliant food-contact packaging already in the supply chain.

PFHxA is one specific PFAS compound subject to its own restriction activity outside the PPWR food-contact limits, and Lexology’s analysis is aimed at compliance teams who may be conflating PFHxA-specific restrictions with the broader PPWR PFAS thresholds, or applying the wrong test method or reference substance when screening. The piece is legal commentary, not a regulatory announcement, and firms should treat it as a prompt to check their own PFHxA testing protocols against current guidance rather than as a new legal requirement in itself.

The common failure mode described is testing total fluorine and assuming that satisfies both the PPWR food-contact thresholds and any separate PFHxA-specific obligations, when the two can require different analytical approaches and different substances of concern. Packaging engineers working with fluoropolymer coatings, barrier treatments or grease-resistant papers should confirm with their test labs exactly which substances and methods are being used, and should not assume a single test report covers every PFAS-related obligation that applies to their packaging.

SMEs press for faster relief on the authorised representative rule

IndexBox reports that SMEunited, the European association representing small and medium enterprises, has urged the Commission to suspend the PPWR’s authorised representative obligation for SMEs. This is the Article 45(3) requirement for an EU-based authorised representative, and it’s already the subject of proposal COM(2025) 982, tabled 10 December 2025, which would suspend that obligation until 1 January 2035.

As of early October 2026 that proposal had not been adopted. It remains a proposal, not law, and SMEunited’s intervention reads as pressure to move it through the legislative process faster, or to extend relief more broadly, rather than a report of a new development. Firms affected by Article 45(3), particularly non-EU manufacturers and smaller EU producers without in-house regulatory infrastructure, should continue planning as if the obligation applies on schedule. Relying on a proposal that hasn’t cleared the legislative process is a planning risk, not a compliance strategy.

If votes or formal adoption are reported after this piece, that later reporting should be treated as more current and followed in preference to this status update.

The common thread: measurement infrastructure is the bottleneck

These three stories share a pattern. The PPWR’s headline obligations, PFAS limits, empty-space ratios, authorised representatives, are not ambiguous in their broad intent. What’s missing in each case is settled, granular guidance on how to measure and verify compliance in specific operational situations: a multi-SKU e-commerce fulfilment operation, a fluoropolymer barrier coating, a non-EU SME’s compliance chain.

The Commission’s June 2026 guidance document and the August 2026 FAQ second edition have helped close some of these gaps, but both the void-fill and PFHxA stories this week describe real-world assessments still catching people out. That’s consistent with a regulation that applied on schedule in August but whose implementing and delegated acts remain, in several areas, late.

What to do now

Audit transport and e-commerce packaging against the 50% empty-space ratio now, including void fill, rather than waiting for the 2030 deadline or a national enforcement notice.
Confirm with test labs which specific PFAS substances and methods are covered by current test reports, and whether PFHxA-specific obligations are being assessed separately from the PPWR’s food-contact PFAS thresholds.
Continue planning for the Article 45(3) authorised representative obligation as currently in force. Treat the suspension proposal as pending, not adopted, until confirmed otherwise.
Check the Commission’s June 2026 guidance and August 2026 FAQ directly for your specific packaging format, and take legal advice where a compliance decision carries financial or regulatory risk.