On 27 September 2026, describing a product as “eco-friendly” to a shopper in the EU became a legal question as much as a marketing one. In April 2027, the fee for putting hard-to-recycle packaging on the UK market will rise further. Taken together, these changes mean sustainable eCommerce will be judged in 2027 on the evidence a brand can show behind each claim it makes.
Most of what the new rules reward is already within a brand’s control: what goes in the box, how far it travels, what happens when it comes back, and whether the green claims on your site have proof behind them.
Why 2027 Is a Turning Point for Sustainable eCommerce
Rules on green claims and packaging have been tightening for several years. In 2027, most of the main UK and EU changes will apply together for the first time, with more to follow in 2028 and beyond. They reach every stage of an order, from the box it ships in to the claims on the product page, so brands working with a third-party logistics (3PL) provider or using EU fulfilment need those partners working to the same standards.
| Date | What changes | Who it affects |
| 6 April 2025 | The Competition and Markets Authority (CMA) can fine businesses directly for breaking consumer law, including misleading green claims, up to £300,000 or 10% of global turnover, whichever is higher | Brands selling to UK consumers |
| January 2026 | New CMA guidance confirms retailers can be liable for repeating a manufacturer’s green claim | Brands reselling or stocking third-party products |
| 1 April 2026 | UK packaging extended producer responsibility (EPR) fees start to vary by recyclability, using red, amber and green ratings | Large UK packaging producers |
| 12 August 2026 | The EU Packaging and Packaging Waste Regulation (PPWR) applies, including a duty to minimise packaging weight and volume | Brands shipping to EU customers |
| 27 September 2026 | EU rules on green claims (Directive 2024/825) become enforceable | Brands whose claims reach EU consumers |
| 1 January 2027 | A new Recyclability Assessment Methodology, RAM 2027, applies to UK packaging placed on the market during the year | Large UK packaging producers |
| April 2027 | The fee for red-rated packaging rises to 1.6 times the amber base fee | Large UK packaging producers |
| October 2027 | The UK deposit return scheme for drinks containers goes live | Brands selling drinks in plastic or metal containers |
| By February 2028 | Empty space in sales packaging must be cut to the minimum needed to protect the product | Brands shipping to EU customers |
| 2030 at the earliest | A 50% maximum empty space ratio applies to eCommerce packaging | Brands shipping to EU customers |
One proposal is still unresolved: the EU’s separate Green Claims Directive, which would require environmental claims to be checked in advance, has been stalled since June 2025, when the final round of negotiations was cancelled. Keep an eye on it, but don’t plan around it yet.
In both the UK and the EU, the rules point the same way: claims need evidence, and oversized or hard-to-recycle packaging is becoming more expensive.
Start With Where Your Impact Really Sits
Packaging is what customers see, so it gets most of the attention. For most product brands, though, it is not the largest part of the footprint. The materials and manufacturing behind the products often account for the biggest share, with transport, returns and packaging making up the rest in proportions that vary by product.
Much of this sits in what is known as Scope 3 emissions, which include the emissions from your suppliers, manufacturers, logistics partners and couriers. You don’t control them directly, but they count towards your footprint, and they are where the larger reductions tend to be found.
A practical way to start is to list the five decisions that shape most of your impact:
- What you sell: the materials, how long products last, and whether they can be repaired or resold
- Where you source it: supplier energy use, transport distance and working practices
- Where you hold stock: how far it sits from your customers and how often goods travel by air
- How you pack it: box sizes, void fill and material choices
- How returns are handled: how many orders come back and what happens to them
Then ask each supplier and partner what data they can share. Gaps in that data are useful too, because they show where your claims would currently be hardest to back up.
Operational Choices That Count
These are the areas an eCommerce brand runs day to day, and many of them reduce cost as well as impact. We’ve also covered eight eCommerce sustainability wins beyond packaging, including warehouse energy, stock placement and carrier choice.
Smaller Boxes and Less Void Fill
Oversized boxes topped up with paper or air pillows have long been a cost problem. You pay for the extra material, for dimensional weight (couriers charging by parcel size as well as weight) and for the wasted space in every van. For parcels going to EU customers, they are now becoming a compliance problem too.
Under the PPWR, filling materials such as paper, air cushions and bubble wrap count as empty space. Empty space in sales packaging must be cut to the minimum by February 2028, and eCommerce packaging faces a 50% maximum empty space ratio from 2030 at the earliest.
To get started:
- Review your box range against your best-selling products and most common order combinations
- Add box sizes where the same products regularly ship with lots of filler
- Choose protective materials that do the job with less volume
- Track the share of orders shipped in a right-sized box
If you’re weighing up protective materials, it helps to understand what dunnage is in eCommerce fulfilment and which options take up the least space in the box.
Packaging That Is Recyclable in Practice
“Recyclable” on a label is no longer enough on its own. Under UK packaging EPR, large producers must assess household packaging using the RAM, set by PackUK, the body that runs the UK scheme. It rates each item red, amber or green.
The rating depends on what happens in practice. Packaging collected at kerbside by at least 75% of UK local authorities can be rated green at the collection stage, while packaging that is technically recyclable but can’t be processed reliably in current UK infrastructure can still be rated red. The rating also affects what large producers pay, with the red fee rising to 1.6 times the amber fee in 2027/28 and to double the amber fee in 2028/29.
Plastic packaging is also covered by the Plastic Packaging Tax, charged at £228.82 per tonne from 1 April 2026 on plastic packaging with less than 30% recycled content. Businesses that manufacture or import 10 tonnes or more of finished plastic packaging in a rolling 12-month period must register.
Where to begin with your packaging range:
- Ask packaging suppliers for the RAM rating of each component
- Prioritise swaps on your highest-volume red-rated items
- Avoid mixed materials that are hard to separate, such as plastic windows in paper mailers
- Check the recycled content of any plastic you still use
To check what applies to your business, we’ve explained how packaging EPR works and who needs to register for the Plastic Packaging Tax. If you’re redesigning your mailers at the same time, there’s practical advice on switching to greener branded packaging without losing the unboxing experience.
Delivery Choices and Where Stock Sits
Distance, speed and the number of journeys all drive delivery emissions. Holding stock closer to your customers, for example in both the UK and the EU, shortens last-mile journeys and reduces reliance on air freight for cross-border orders. Sending a customer’s items in one parcel rather than several means fewer trips, and a slower grouped delivery option gives customers a simple way to choose lower-impact shipping.
A multi-carrier shipping set-up also lets you pick lower-emission options by route without giving up speed where customers need it.
If you hold stock in the EU, compliance comes with it. Most non-food consumer products sold there need an EU-based responsible person under the General Product Safety Regulation (GPSR), which can be simpler to arrange alongside EU fulfilment than as a separate project.
Returns That Don’t Undo Your Progress
Every return adds at least one more journey, often to a different site, and usually new packaging as well. Return rates tend to be highest in fashion, so cutting them is often one of the most effective changes a clothing brand can make.
The biggest gains come from preventing returns in the first place, through accurate size guides, honest photography and clear product descriptions. For the returns that do come back, grade items quickly, restock what can be sold, refurbish or repair where possible, and recycle responsibly when resale isn’t viable. Tracking return reasons by product shows which pages need work. There is more on this in our guide to the environmental cost of returns.
Claims You Can Prove
Green claims are where the rules have moved furthest. A brand can make real progress on packaging and delivery and still run into trouble if the way it describes that progress is vague or overstated.
This section is general guidance rather than legal advice, so take specialist advice on specific claims.
The UK Rules Under the CMA
The CMA’s Green Claims Code sets out six principles. Claims must be truthful and accurate, clear and unambiguous, must not omit or hide important information, must make fair and meaningful comparisons, must consider the full life cycle of the product, and must be substantiated.
Since April 2025, the CMA has been able to decide for itself whether consumer law has been broken and fine businesses directly, as set out in the table above. Its January 2026 guidance adds an important point for retailers: offering a product for sale can amount to repeating the manufacturer’s green claim. If you copy supplier wording onto your product pages, you take on responsibility for it.
The EU Rules for Brands Selling Into Europe
The EU’s Directive 2024/825 on consumers and the green transition, known as the ECGT Directive, applies to claims that reach EU consumers, including claims made by UK brands. Since 27 September 2026:
- Generic claims such as “eco-friendly”, “green” and “climate friendly” are prohibited unless the product holds the EU Ecolabel or an officially recognised Type I ecolabel (an independently certified scheme meeting ISO 14024, such as the Nordic Swan), or meets the top performance level set under other EU law for the feature being claimed
- Claims that a product has a neutral, reduced or positive climate impact because of carbon offsetting are banned
- Sustainability labels must be based on a certification scheme with independent third-party checks, or set by public authorities
- Claims about future performance, such as “net zero by 2030”, need a detailed, publicly available delivery plan that is checked by an independent third party
Brands can still say they support climate projects, as long as that support isn’t presented as cancelling out their own emissions.
What No Longer Counts
These are the claims most likely to cause problems in 2027:
- Vague words on their own, such as “eco-friendly”, “planet-friendly” or “green”
- “Carbon neutral delivery” that relies on offsets, where customers are in the EU
- Claims about a whole product based on one feature, such as describing a product as eco because its mailer is recyclable
- Self-made badges and labels
- Targets with no published plan behind them
Here is how vague claims can be rewritten to be specific. These are illustrations only, so use wording that is true and evidenced for your own products.
| Instead of | Try something like |
| “Eco-friendly packaging” | “Our mailers are made from 100% recycled paper and can go in household recycling” |
| “Carbon neutral delivery” | “We combine orders and ship from UK and EU stock to cut delivery miles” |
| “A green brand” | “In 2026 we cut void fill by a third by adding two new box sizes” |
Writing Claims That Hold Up
Run every claim through this check before it goes live:
- Specific: it names the feature, material or change
- Scoped: it says what it covers, such as packaging only or delivery only
- Evidenced: you can produce the data, certificate or supplier document behind it
- Current: it reflects what you do today
- Recorded: the evidence is filed where your team can find it if a customer or regulator asks
Using Certifications as Evidence
Certifications will matter more in 2027, because independent checks are the most reliable way to back up an environmental claim. They measure very different things, though, and only some of them allow generic wording. For EU customers, a broad claim such as “eco-friendly” generally needs the EU Ecolabel or an officially recognised Type I ecolabel, or top performance under other EU law for that feature. Company-level certifications such as B Corp or ISO 14001 support specific claims about how you operate, but they don’t permit generic product claims on their own.
| Certification | What it covers | Most useful for |
| EU Ecolabel | Products that meet EU environmental criteria across their life cycle | Using broad environmental claims with EU customers |
| B Corp | Whole-company social and environmental performance | Showing company-wide practice and governance |
| ISO 14001 | Environmental management systems | Showing how impacts are managed and reviewed |
| FSC (Forest Stewardship Council) | Paper and wood sourcing | Packaging and paper-based products |
| GOTS (Global Organic Textile Standard) | Organic textiles across the supply chain | Fashion and home textiles |
| Fairtrade | Terms for producers and workers | Raw materials such as cotton |
When weighing up a certification, look at what it would require you to change. If those changes would be worth making for your business anyway, the certification is likely to pay its way. If the main benefit is a logo for your website, the time and cost may outweigh what you get back.
The same thinking applies to your partners. Ask your third-party logistics (3PL) provider, carriers and packaging suppliers for certificates and data rather than promises. If a partner says they’re a B Corp, it’s worth knowing what B Corp certification involves so you know which questions to ask.
The Commercial Case for Greener Operations
Lower-impact choices are easier to keep funding when they also protect margin, and many of the changes above do both:
- Right-sized packaging cuts material costs and dimensional weight charges
- Fewer returns protect margins and reduce handling costs
- For large producers, moving away from red-rated packaging avoids higher EPR fees from April 2027
- Clear, evidenced claims reduce the risk of enforcement action and costly rework of marketing materials
- Customers are more likely to trust, and come back to, a brand whose claims they can check
Your 2027 Planning Checklist
| When | What to do |
| Now (Q4 2026) | The EU claims rules already apply, so audit every environmental claim across your website, product pages, packaging, emails and ads, and remove or rewrite generic and offset-based claims that reach EU customers. If you are a large producer, get RAM ratings for your packaging before 1 January 2027 |
| January to March 2027 | Plan swaps for high-volume red-rated items, review box sizes and void fill, and if you sell drinks, start preparing for the deposit return scheme |
| April to June 2027 | Ask suppliers and partners for evidence and certificates, and set one measurable goal each for packaging, delivery and returns |
| July to December 2027 | Have deposit return scheme labelling and pricing ready before October, review your returns data, and publish an honest progress update |
Getting Ready for 2027
The brands best placed for 2027 will have fixed the operational basics first and will be able to describe their progress plainly, with evidence ready if a customer or regulator asks.
Packaging and delivery are the most practical places to act first, followed by returns, because they are run directly by your team and face the nearest regulatory deadlines. Sourcing, where the larger reductions usually sit, takes longer to change, so start those supplier conversations alongside. Once the basics are in hand, claims become much easier to make and to defend. Green Fulfilment, a UK 3PL that has been B Corp certified since 2024, works with brands on these areas, including right-sized packing, UK and EU stock placement and returns handling.
Frequently Asked Questions
What makes an eCommerce brand sustainable in 2027?
A sustainable eCommerce brand in 2027 is one that can show real reductions in the areas it controls, such as packaging, delivery, returns and sourcing, and that describes them using specific claims it can back up. Certifications and supplier data help provide that evidence.
Can I still describe my products as green?
In the UK, only if the claim is accurate, clear and backed by evidence under the CMA’s Green Claims Code. For customers in the EU, generic terms such as “green” or “eco-friendly” are now prohibited unless the product holds the EU Ecolabel or an officially recognised Type I ecolabel, or meets the top performance level set under other EU law, so specific, evidenced claims are the better route for most brands.
Is carbon neutral shipping still allowed?
For EU consumers, claims that a delivery or product is carbon neutral because of offsetting are now banned. In the UK, any carbon neutral claim must meet the Green Claims Code, so it needs to be accurate, clearly scoped and evidenced. In both markets, describing the reductions you have actually made is the more defensible approach.
Do UK packaging rules apply to small online brands?
Only above certain thresholds, Packaging EPR applies to businesses with a turnover above £1 million that handle more than 25 tonnes of packaging a year, so smaller brands have no EPR obligations. Small producers, broadly those with a turnover of £1 million to £2 million or 25 to 50 tonnes of packaging, must register and report packaging data. Large producers, with a turnover above £2 million and more than 50 tonnes of packaging, report every six months and pay waste disposal fees. The Plastic Packaging Tax has a separate threshold of 10 tonnes of finished plastic packaging manufactured or imported in a rolling 12-month period.
How can a fulfilment partner help reduce a brand’s footprint?
A fulfilment partner can right-size packaging at dispatch, consolidate shipments, hold stock in the UK and EU closer to customers, grade and restock returns quickly, and replace printed dispatch paperwork with digital versions. Ask any partner for the data and certificates that show what they do in practice.
