What is the difference between sales packaging and transport packaging?

Sales packaging envelops the product, transport packaging enables shipment

Sales packaging is the packaging that directly surrounds a product and with which the consumer purchases the product: the bottle, the box, the film around it. Transport packaging — also called shipping packaging — is the packaging that is added to safely transport a product, such as the cardboard box and cushioning material with which an online retailer sends an order to the customer. Both fall under the packaging regulation, but they are two different categories, each with their own place in the supply chain.

This distinction is not merely linguistic: it determines who is responsible for which part of the packaging. A brand or importer places sales packaging on the market at the moment the product is manufactured or imported. An online retailer that adds its own shipping box at the moment of dispatch thereby places that transport packaging separately on the market — often in the country where the customer is located, and not necessarily the same country from which the sales packaging originates. For the role and registration obligation, each packaging layer counts separately.

Article 3 Regulation (EU) 2025/40 and the definition of manufacturer

Article 3 of Regulation (EU) 2025/40 distinguishes packaging categories, including the packaging that directly surrounds the product and the packaging that serves for transport; the Commission's guidelines C/2026/3084 on the definition of manufacturer clarify that anyone who places packaging under their own name on the market is considered a manufacturer for that packaging — for transport packaging this is usually the party that ships, not necessarily the party that manufactures the product.

Because transport packaging typically only comes into being when dispatched to the end customer, the registration obligation for it applies in the country of delivery. In the Netherlands, transport packaging counts towards the 50,000 kg threshold at Verpact, a threshold that is expected to be removed once the PPWR manufacturer register becomes operational, at the earliest 12 August 2027. In Germany, LUCID has no threshold: a registration obligation applies from the first parcel with transport packaging that is delivered there.