Yes, in most cases the regulation treats transport packaging as its own category, separate from the packaging that directly surrounds the product. The PPWR looks at the function of packaging, not at who manufactured it or what material it is made of. A box that you use to protect an order during transport to the customer can therefore count as a separate packaging unit, even if the product itself is already in its own packaging from the manufacturer.
For webshops this concretely means that sometimes two packagings are in view simultaneously for one order: the packaging of the product itself, and the shipping box that you place around it. Both can be subject to a registration obligation, and both are counted separately in the volumes that you report annually. Anyone assuming that only the product packaging counts may miss part of the administration that is actually mandatory.
What the regulation means by product and transport packaging
The PPWR works with a classification by function: packaging that directly surrounds the product, packaging that groups products together, and packaging that serves for transport or shipment. This classification also determines which rules apply. For example, the requirement regarding empty space in transport packaging, which will apply from 2030 onwards, applies specifically to transport packaging and not to the packaging that directly surrounds the product. Those who do not make that distinction risk reporting incorrect volumes or the wrong category.
It is advisable not to draw your own conclusions about which category applies to your situation. The guidelines from the European Commission and national supervisory authorities provide explanations per packaging type, and in case of doubt it is customary to consult that text or ask a lawyer. Through the role finder that maps your situation per packaging type and country you get an initial indication which category may apply to your shipping box.
Why this distinction is relevant for you
If you yourself purchase the shipping box, have your logo printed on it or otherwise bring the box to market as your own packaging, you can be identified as a manufacturer for that specific packaging, even if for the product itself you are merely a reseller. This touches on the well-known filler-is-manufacturer rule, but then applied to the transport packaging separately. The role you have for the product packaging and the role you have for the transport packaging can thus differ, and that is precisely why many webshops inadvertently miss something here.
The knowledge base contains an explanation of how this role determination works per packaging layer, including situations in which a supplier or fulfilment partner does or does not take that role from you. the knowledge base with explanations per packaging situation is a logical place to investigate this further before you register anything.
What this means for registration and reporting
Because product packaging and transport packaging are assessed separately, they are also registered and reported separately in most national registers, sometimes even in different material categories. For example, a cardboard shipping box with plastic cushioning material counts for two materials, while the product packaging is separate from that. This distinction also appears in the annual report: you do not provide one total weight, but a breakdown per packaging type and material. Those who mix these up do not necessarily risk a fine, but rather an annual report that does not match what was actually brought to market.
Whether and how this applies specifically to your shipping process depends on how you ship, in which country your customer is located, and whether you choose the shipping box yourself or leave this to a fulfillment partner. For frequently asked questions about such situations, there is an overview of frequently asked questions about packaging types, which also includes when this distinction is not relevant, for example in certain forms of B2B resale where the shipping packaging does not reach the end user.
When the distinction does not create extra work
Not every webshop deals with this. If you sell only products that arrive pre-packaged and you ship them in exactly that same packaging without your own box around it, there may be only one packaging layer to assess. The micro-exemption and the thresholds per country can also mean that a separate assessment of shipping packaging is not necessary. That is precisely why a generic checklist offers little guidance here: the answer depends on your own shipping process.
Do you want to know if this applies to your shipping boxes and what exactly is required of you? Take the free quick scan or browse through the topics in the knowledge base; within a few minutes you will know whether the distinction between product and shipping packaging makes a difference in your case.