Study of the environmental sustainability of e-commerce in Germany (OENO Study)

Study of the environmental sustainability of e-commerce in Germany (OENO Study)

Executive Summary by Fraunhofer ISI

Given the continuous growth in sales generated in Germany up until 2021 by e-commerce, this form of retail is expected to become increasingly important in the future. Although a slight decline in the volume of trade was observed in 2022, despite the current economic situation a fundamental long-term reversal of the growth trend is unlikely.

In view of this, a structured and comprehensive analysis of the environmental sustainability of e-commerce in Germany seems both expedient and appropriate. This study focuses on the environmental impact and a division into different areas of e-commerce, which are examined separately. The four areas, each of which was addressed as an independent work package, were:

  • Delivery transport (including returns)
  • Packaging (paper, plastic, reusable)
  • Digital infrastructure (data centres, servers, energy requirements)
  • Logistics centres (energy consumption and emissions of distribution and logistics centres)

In addition, two other current trends in German e-commerce were identified and investigated separately:

  • New business models (instant delivery, recommerce platforms, retail-as-a-service)
  • Sustainable consumption decisions in e-commerce

The most important findings with regard to each of these six aspects are briefly summarised in the following.

The delivery transport of an average B2C parcel by a CEP service provider currently causes 790 g of CO2e (this corresponds almost exactly to the emissions estimated for producing 1 kg of pasta or those emitted by driving a car for approximately 5 kilometres). Delivering a parcel from the sender to the customer causes approx. 866 g CO2e, whereas a return causes only 524 g CO2e, because returns are often transported by the customers themselves and there is therefore less delivery transport. For an average online purchase, the emissions from the delivery and the share of emissions from returns add up to 981 gCO2e (not taking into account any customer transport). Since most emissions are generated in the last mile, a parcel which is collected from a parcel pick-up point (without a prior delivery attempt) generates 442 gCO2e, which is significantly less than a parcel delivered to the front door, which generates 866 gCO2e. In total, approximately 1.7 million tCO2e are emitted for the transport of the 2.1 billion domestic B2C parcels. This corresponds to 3.7 % of road freight transport emissions. Of this parcel volume, 20% are returns, which are responsible for 13% of emissions. A total of 58% of the emissions are emitted on the final leg of the journey, the so-called last mile. At 20 ktCO2e, customer transport (e.g. to the parcel pick-up point) only accounts for a small share of the total emissions.

The growth of e-commerce is also accompanied by an increased volume of packaging. Cardboard makes up the largest share of packaging for shipping. Plastic packaging is now perceived as less sustainable. In general, the issue of sustainability is becoming increasingly relevant and approaches such as reusable packaging and other measures to reduce the environmental impact are gaining importance. Important aspects when weighing up the various packaging options include the volume of waste, recyclability, the proportion of recycled material, greenhouse gas emissions and, in the case of reusable packaging, the number of cycles. In Germany, disposable packaging made of paper or cardboard is generally recycled to a much greater extent and contains a higher proportion of recycled material than plastic packaging. Plastic packaging, on the other hand, generates less waste. Greenhouse gas emissions for disposable packaging range from 20 to 756 g CO2e, depending on the material used (paper/cardboard or plastic, proportion of recycled material) and the size of the packaging. For reusable packaging and assuming that return processing takes place at a central location within Germany, between 14 to 828 g CO2e of emissions are produced per cycle of use, this is dependent on the size, the proportion of recycled material and whether the packaging is flexible or rigid (i.e. foldable or non-foldable for return shipping). It is not possible to conduct a general evaluation comparing paper/cardboard packaging with plastic packaging; this requires a case-by-case assessment. However, plastic packaging can have lower CO2e emissions than paper/cardboard for smaller packaging sizes. The origin of the CO2 emissions must also be taken into account. When paper and cardboard packaging is finally disposed of (i.e. incinerated), biogenic CO2 is released. This means that this CO2 was previously taken out of the atmosphere as a result of the growth of the trees. In contrast, the disposal of plastic packaging currently releases fossil CO2, which is more problematic.

Determining the environmental footprint of the digital infrastructure of e-commerce is subject to many uncertainties and is dependent on individual consumer behaviour. When considering the emissions of a single online purchase, the influence of the consumer's behaviour (choice of energy-efficient end devices and sustainable use of the ICT infrastructure) can be identified and partially quantified. Thus, emissions of 63 g CO2e, resulting from the additional energy expenditure of a singular online ordering process, could be determined for the digital infrastructure of an average online order in Germany in 2020. However, this value can vary greatly depending on the assumptions made and the different usage scenarios.

A top-down analysis of the energy consumption of logistics centres revealed emissions of 66 g CO2e per parcel. The accuracy of this figure was verified using comparisons with the literature and the evaluation of various annual and sustainability reports of CEP service providers. In the bottom-up analysis, the values calculated were between 20-32 g CO2e per parcel and per logistics centre passed through. In general, however, such emissions can vary greatly depending on the logistics centres involved and related factors such as the size of the site (quantitative throughput, etc.), the work requirements and functions of the site (type of consignments, cold storage, hazardous goods, proportion of space for longer-term storage, etc.) as well as the technical equipment (e.g. degree of automation) and optimisation measures already implemented.

The three new business models examined (instant delivery, re-commerce and retail-as-a-service (RaaS)) differ from conventional e-commerce in only a few aspects and the impact of these differences on environmental sustainability is considered to be comparatively small. In the area of delivery transport, however, additional emissions can occur in all three business models examined: through the delivery to intermediate distribution centres and the low possibility of bundling deliveries in the case of instant delivery, through additional transport routes for reprocessing in the case of re-commerce (which, incidentally, would occur in exactly the same way in the case of a "right to repair") and through the combination of online and stationary trade in the case of RaaS, in which both customer traffic and delivery transport occur in the case of online trade. The electrification of transport again appears to be an important starting point for reducing the environmental impact. Especially the use of BEVs for the last mile can be one way to reduce emissions, e.g. for the prompt delivery of groceries ordered shortly beforehand, (provided it replaces the customers separate weekly shopping trip). In addition, the bundling of deliveries and the establishment of loading zones can have positive effects. Even if re-commerce does lead to increased delivery traffic, it can be assumed, in most cases, that GHG abatement through the lifetime extension of goods and the resulting avoidance of new production offsets any additional emissions. Meaning that the business models of re-commerce platforms (both C2C and B2C) can be seen as very positive for climate protection overall.

From a consumer psychology perspective, there are particularities in sustainable consumption decisions that arise from e-commerce. As a result, impulse buying can increase due to the high speed and ease of purchase. There are also heuristics that are of particular relevance to e-commerce and that can be used to promote sustainable purchasing decisions. Two heuristics of decision-making here are emotional stability ("avoidance of frustration purchases") and the need-satisfying effect of consumption ("identity creation"). The so-called attitude-behaviour gap explains why there is awareness of sustainability, but at the same time contradictory actions are taken. This correlation can be influenced by habits, which can also be suspended in the context of the purchase decision, as well as by social norms. These are some of the most powerful levers for changing purchasing behaviour.

An overarching view shows that most of the environmental impact generated by a product (e.g. resource consumption, emissions, etc.) does not occur during the trading process, but rather during the manufacturing or production process and any subsequent disposal (cf. Zimmermann et al. 2020; Collini et al 2022). The comparatively short trade segment is in most cases only responsible for a relatively small share of GHG emissions.

If customers choose to order online, which has been increasingly the case in recent years (IFH Cologne 2022), it becomes clear that online trade is responsible for a considerable range of different effects on environmental sustainability, but this must be seen in the context of the alternative to e-commerce, namely traditional, stationary retail, which also has an impact on the environment (e.g. in the form of GHG emissions and land consumption) (cf. Zimmermann et al. 2020; Collini et al 2022) and, in addition, here, too, customers travel a variety of distances (during purchase and possible return).

A real reduction in the harmful effects of trade could therefore only be achieved through greater consumer sufficiency, i.e. consciously refraining from consumption. Once the decision to consume has been made, however, or if consumption simply cannot be avoided, the choice between stationary retail or e-commerce must be made on the basis of environmental considerations, depending on the framework conditions of the individual case. Nevertheless, some specific starting points can be formulated for further improving the environmental sustainability of e-commerce.

25 starting points for greater sustainability in e-commerce

In total, 25 different starting points for greater sustainability in e-commerce could be identified for the six areas examined. It is important to note here that some of the 25 starting points listed may be somewhat contradictory, these are points which would have to be resolved through discourse and by weighing up overall interests.


Starting point

Delivery transport

(1) Using electric vehicles for the last mile


(2) Delivery to a parcel pick-up point


(3) Reducing the number of returns


(4) Avoiding empty space in packages


(5) Consolidation in rural areas


(6) Route optimisation


(7) Reducing the amount of packaging used


(8) Optimisation in terms of material selection


(9) Use of reusable shipping packaging


(10) Creating transparency and providing information to consumers


(11) Increasing the intensity and duration of use of the end devices


(12) Addressing emissions resulting from the use of essential ICT infrastructure


(13) Making greater use of scaling effects


(14) Making environmental effects visible


(15) More energy-efficient data transmission and data centres

Logistics centres

(16) Easing the burden on the logistics infrastructure


(17) Exploiting (energy) efficiency potentials


(18) Developing logistics centres into prosumers

business models

(19) Bundling of deliveries for instant delivery


(20) Setting up loading zones


(21) RaaS at locations with good transport links


(22) Personalisation and gamification


(23) Marketing that promotes sufficiency


(24) Green nudging


(25) Eco-labelling and information at the POS

Source: Fraunhofer ISI

It is possible to use the results and starting points presented to analyse not only the figures for an average "standard" package, but also a "best case" and "worst case" scenario for an e-commerce purchase.

In 2021, an average or typical "standard" parcel delivered to the door (including customer traffic) generated 866 g CO2e of GHG emissions from delivery traffic, 333 g CO2e from average shipping packaging (folding box 12.7 l) and 32 g CO2e at the logistics centre involved. On top of this were 63 g CO2e for the use of the digital infrastructure and 127 g CO2e as a share of the costs for possible returns. This results in 1421 g CO2e for the dispatch of an average parcel.

In the "best case" scenario, sending a parcel using optimally planned and implemented transport (last mile by electric vehicle delivered to a parcel pick-up point) would only generate 408 g CO2e. Reusable packaging, which has a high number of cycles and therefore a very long service life, would only cause approx. 14 g CO2e of GHG emissions (packaging is foldable for return shipping, yet durable and contains a high proportion of recycled material). Moreover, the logistics centre processing would only produce 20 g CO2e of GHG emissions. As a result of efficient ordering by a well-informed customer, the IT infrastructure would also only be used to a minimum with 27 g CO2e and a return of the goods would of course not be necessary. Only the reusable packaging would have to be returned. This would result in a total of 469 g CO2e of GHG emissions for the "best case". (This is roughly equivalent to three times the emissions of a passenger kilometre travelled by car).

However, in the "worst case" scenario, a shipment delivered to the doorstep by a diesel vehicle on the third attempt, transport would have to be estimated at 2060 g CO2e. Shipping a parcel would involve excessively large and material-intensive reusable packaging and cause approx. 828 g CO2e of GHG emissions (non-foldable for return shipping, low number of cycles, not made from recycled material). Meanwhile, logistics centre processing would produce comparatively high GHG emissions of 66 g CO2e. As a result of an inefficient and ill-informed search, the IT infrastructure would be placed under a comparatively heavy burden resulting in 506 g CO2e and, in addition, the customer decides in favour of an item that is subsequently the "wrong" one and immediately sends it back as a return (an additional 66 g CO2e for logistics and 900 g CO2e for transport, i.e. a total of 966 g CO2e), thereby triggering an additional replacement order. In the "worst case", this would result in a total of 4,426 g CO2e of GHG emissions. (This is approximately ten times higher than the "best case" and therefore the equivalent of 30 times the environmental impact of a passenger kilometre travelled by car).

As these two "extreme examples" show, environmental sustainability depends on many factors that can vary greatly depending on the individual case. This study lists 25 different starting points (covering all the areas analysed) that can be used to achieve the "best case" effectively. Theoretically, even lower emissions would be possible than those presented for the 'best case' if all the above starting points were implemented at the same time, but currently it does not appear possible to quantify the exact contributions of the individual starting points and their combined overall effect. 

However, focusing on delivery transport alone (which is responsible for the largest share of GHG emissions) shows that the current average emissions per parcel of 866 g CO2e caused bydelivery transport could be reduced by around half, namely to 408 g CO2e, if, for example, transport for the last mile was carried out exclusively by electric vehicles and deliveries were consistently made to parcel pick-up points close to the customer (see starting points 1 and 2).

Afterword: Political recommendations for action from bevh's (the German e-commerce association) perspective

Even though most greenhouse gas emissions are generated during production and not just when goods are sold, online retailers are constantly working to make their offer even more sustainable, and they are successful in doing so. In many situations, e-commerce is not worse, but in fact better than bricks-and-mortar retail in terms of sustainability and should therefore not be discriminated against by regulations. Instead, the development of sustainable trade and a sustainable economy should be supported by promoting new digital business models.

This study is a positive and assertive way for us as an e-commerce sector to approach this topic in order to identify possible levers and utilise them in the interests of greater environmental sustainability. To ensure that this also happens in other sectors and that the disclosure of emissions in the individual sub-sectors in e-commerce does not result in finger-pointing, all sectors should carry out such an inventory, have their environmental impact and emissions measured in order to identify where there is potential for further improvement. In view of the constantly growing regulatory burden on retail and especially on e-commerce, a stronger focus should be placed on practicability and the environmental benefits. Environmental sustainability is a high priority for companies in the e-commerce sector and at the same time it is of the utmost importance, especially in these very difficult economic times, to ensure that companies can still generate the revenue they need to drive the sustainable transformation forward.

This study by the Fraunhofer Institute identifies a number of starting points and factors that can be used to achieve this. Even if some measures can be implemented by the retailers themselves, an overall sustainable ecosystem is necessary in order to reduce emissions in the long term. On the one hand, this also affects parcel and postal service providers as well as providers of infrastructure solutions, consumers, but also policy makers, who can support the transition of e-commerce towards even more sustainability by promoting an appropriate regulatory framework. Policy recommendations can be derived from the study for all six sub-areas analysed: delivery transport, packaging, digital infrastructure, logistics centres, new business models and consumer behaviour, which can support the establishment or further expansion of a sustainable ecosystem for e-commerce. It is important that the individual measures are coordinated and can therefore generate positive effects in different sub-areas.

1. Delivery transport

According to the study, emissions from delivery transport in the last-mile can be reduced in particular by the electrification of vehicle fleets. To achieve this, even stronger incentives should be provided, especially for delivery and transport vehicles, so that parcel and logistics service providers convert their fleets accordingly. If the expected savings potential is confirmed by further research, micro-hub solutions and the expansion of alternative delivery networks to van transport, such as the freight tram network, should also be promoted more strongly. However, these measures are already helping to improve urban air quality and traffic volumes and are therefore worthy of support (see p. 28). Last but not least, as envisaged in the current draft of the StVO amendment (the German road traffic regulation), the creation of specific loading zones would also help to avoid unnecessary detours by delivery vehicles (see New business models).

Parcels delivered to pick-up points only cause around half (51 %) of the GHG emissions of a doorstep delivery and 45 % of a parcel that is collected from a pick-up point after an unsuccessful delivery attempt (see p. 29). This is why parcel pick-up points, especially if they are supplier-neutral, help to reduce GHG emissions - provided they are easily accessible for customers - ideally on foot or by bike - and can be easily integrated into their everyday lives because they are well situated, e.g. at supermarkets, train stations or bus stops. With this in mind, the authorisation procedures for parcel pick-up points should be accelerated and the relevant bureaucracy greatly reduced. In areas where no private space is available, public spaces should be made available as easily as possible for parcel lockers. The promotion of supplier-neutral services should also be encouraged by politicians, as bundling not only reduces operating costs but also GHG emissions even further (see p. 29).

This can also help to reduce GHG emissions from returns. Unnecessary customer detours can be avoided by providing more easily accessible return options at parcel drop-off points or even in bricks-and-mortar shops, which can be easily integrated into everyday journeys such as the journey to work. At present, 33% of respondents still have to make detours when returning goods (see p. 25) - a figure which could be improved with the appropriate political support.

Even if it is up to retailers themselves to consider what tools they have at their disposal and how to set the right incentives for specific target groups and to provide customers with information in order to help them find the best product for them, politicians can also support retailers here. They should ensure that retailers are able to fully utilise all the tools available to them in order to avoid returns.[1] This includes, for example, promoting the use of new technologies for body measurement or size recommendations based on previous purchase history as well as avoiding bad purchases by means of personalisation and nudging. However, current debates suggest that politicians are rather sceptical about the use of the personal data required for this and nudging, which is maligned by some as "dark patterns", is also highly controversial. However, nudging must remain an option, at least in this area, if retailers are to avoid returns effectively (see sustainable consumption).

In the fashion industry in particular, there are many returns. One of the reasons for this is that there are no really standardised sizes to date. This is where policymakers could intervene and ensure standardisation, ideally at an international level. Even more returns could be avoided in this way.

After all, the best return is no return. However, if a customer does exercise their legal right of withdrawal, which can never be completely ruled out, retailers recondition the goods as far as possible and resell them either directly or as clearance goods or through outlets, or donate them to charitable organisations. Goods may only be disposed of in justified exceptional cases. However, to ensure that even more goods can be donated, the legislation that exempts donations in kind from sales tax and which was already announced as part of the coalition agreement should finally be implemented. This is already possible within the current EU tax legislation.[2] 

Another way to reduce emissions in logistics is to avoid empty space in vans. According to the study, a reduction of just 5 % of the average parcel volume could save 61 kt CO2e by 2026 (see p. 31). But as the authors rightly point out, reducing parcel volumes to a minimum is also in the economic interest of retailers, as this saves costs. Proposals such as the EU Packaging Regulation currently under discussion, which aims to stipulate a maximum empty space of 40% per parcel, are more of a hindrance. Products with irregular shapes such as balls or hockey sticks, but also buckets or ring binders, which themselves already contain empty space, cannot comply with this requirement if they are packed in rectangular packaging. However, even if they were no longer packed in rectangular packaging, meaning that the empty space in the parcels would be less than 40 %, this would not actually achieve the desired effect, as the empty space would then be created in the transporter itself. This is because the space in the van can be used most efficiently with stackable, rectangular parcels, thereby saving journeys (more on promoting optimum packaging in the next section).

In terms of optimising routes and reducing the distances to be covered to a minimum, especially in rural areas, politicians must introduce the requisite exceptions under competition law to allow cooperation between different CEP service providers in certain geographical areas. Merging just two suppliers can reduce emissions by 25 % - with five suppliers, emissions are reduced by as much as a third (see p. 31). For such cooperation to work, standardisation is necessary, for example of tracking numbers.

2. Packaging

Retailers are already constantly trying to optimise their packaging and reduce empty space and packaging materials. However, protecting the product remains the top priority. The Fraunhofer Institute calculates a potential saving of 6.5% in packaging volume through the use of better-fitting shipping boxes (see p. 46). However, this should not be taken to the point of absurdity by blanket stipulations such as those being suggested for the EU Packaging Regulation. After all, the blanket stipulation of a maximum empty space of 40% in parcels is simply not practicable. In some cases, this requirement even leads to the use of more packaging material, thereby undermining the aim of the regulation. For example, goods with irregular shapes (e.g. hockey sticks, balls and other spherical objects) or those that naturally contain empty space themselves (e.g. buckets, bowls or ring binders), which previously did not require product packaging, would have to be packed additionally in future so that the packaging for shipping contains less than 40% empty space. Exceptions are also necessary for very small products, since parcel service providers specify minimum sizes for parcels so that the label can be affixed and read properly. Likewise, an exception must be made for fragile products that require padding materials as protection. After all, if a product arrives broken, nothing has been gained by saving on packaging volume: the product has to be returned and may have to be disposed of. A feasible solution could therefore be to set 40% empty space as an average for all consignments from a company. This could also prevent long, confusing positive/negative lists of exceptions, which would otherwise involve a considerable amount of bureaucracy Reusable boxes should also be exempt from this requirement. This is because stable reusable boxes, which are the only possible reusable packaging option for some products, are not adjustable in size, but can be used for the highest number of cycles and are therefore more environmentally-friendly.

For economic reasons alone, reducing the amount of packaging material without compromising the protective function of the shipped goods is a top priority for online retailers. However, as the study reveals, it is often difficult to weigh up the advantages and disadvantages of plastic and cardboard packaging. In certain cases, plastic packaging can even be more environmentally-friendly than cardboard. It is not possible for the researchers to make a blanket recommendation in favour of or against plastic and cardboard packaging, as weighing up the advantages and disadvantages is extremely complex and requires a case-by-case assessment (see p. 49). Therefore, policymakers should not impose a blanket ban on any packaging material. Instead, they should work towards making the situation a little less complex - also in the interests of consumers: For example, biodegradable plastics are not yet environmentally beneficial in Germany as they are not recycled but incinerated, because they cannot be disposed of in the organic waste bin or the ‘yellow bag’ (waste bag for packaging which can be recycled) and therefore are being removed from the material cycle. To make investments in biodegradable plastics worthwhile, policymakers should support further research in this area to ensure that they can also be disposed of sustainably. Furthermore, customers urgently need to be made aware of the facts, as they often consider cardboard packaging to be generally more sustainable than plastic and penalise companies that opt for plastic, even if in some cases this is the most sustainable packaging option.

The study also identifies reusable packaging as a way of reducing packaging waste, although it points out that the empty transport that results from returning the packaging must also be taken into account (see p. 43). This must also be considered during the current debate on the proposed EU Packaging Regulation, which states that retailers should pack 10% of their shipments in reusable solutions by 2030 and 50% by 2040. Although there are now various types of reusable packaging on the market - boxes and mailing bags - apart from the fact that not all consignments are suitable for reusable shipping options, the necessary infrastructure needed to make using reusable packaging more environmentally-friendly is still lacking. This is because reusable packaging is only sustainable if it is used as many times as possible and only has to be transported short distances from the customer to the processing site and back to the retailer (see p. 50). Something which can only be achieved using pooling solutions. Standardising processes and offering simple, easy-to-use return options that can be integrated into everyday life also help to foster the much-needed customer acceptance (see p. 51), since customers must also be willing to play their part by using a deposit system. The development of this infrastructure, similar to the bottle deposit system, must be supported by policymakers, ideally throughout Europe with the involvement of all stakeholders - because this is the only way to ensure that the advantages of reusable packaging are not outweighed by the disadvantages of long, empty return transport. In addition, it is important to ensure that reusable solutions can be used for as many products as possible. To achieve this, the variety of packaging currently available on the market must be maintained. In particular, sturdy hard plastic boxes, which cannot be adjusted in size but are particularly stable, can be used for many cycles and can also transport more fragile products, must therefore be exempt from the 40% empty space ratio limit of the EU Packaging Regulation. Furthermore, the degree to which the reusable shipping solutions are utilised is less relevant than the choice of material itself (see p. 50). Otherwise, these models would simply disappear from the market, many products could no longer be shipped using reusable solutions due to the lack of suitable packaging, and investments and innovations that companies have already made would be wasted. It is important to bear in mind that the investment in terms of time and money required by retailers in order to switch to reusable solutions should not be underestimated. This is because costs arise not only from the purchase of the packaging and the switchover of or adjustments to the logistics process, including returns, inspection and cleaning. Added to this is the considerable effort involved in the IT changeover, given that it must already be determined during the ordering process whether shipping with reusable packaging is possible at all, especially when orders are bundled (see p. 44). Co-operation with utility companies must also be established, otherwise the disposal of reusable packaging can prove to be quite problematic (see p. 45). Policymakers should therefore support and encourage retailers to switch to reusable packaging and not undermine it with well-intentioned but overly hasty minimum requirements in the EU Packaging Regulation. Furthermore, policymakers should also ensure that consumers are suitably informed. There must be a willingness to pay more for reusable shipping solutions and consumers must also be prepared to participate in a suitable deposit system. Despite consumers being generally in favour of reusable shipping, their willingness to bear some of the additional costs has so far been relatively low (see p. 44).

The study sees another means of reducing packaging volume by using product packaging as shipping packaging. Larger products in particular are already being shipped in their product packaging where possible, but solutions for shipping smaller products in that way are also currently being developed. However, product packaging must be designed in such a way that it can withstand shipping. The study calculates a savings potential of 18-24% of the total packaging volume in e-commerce through "ships-in-own-container" or "ships-in-product-packaging" solutions (see p. 45). This packaging option should therefore be promoted and supported by policymakers. As shipping in product packaging aims to reduce packaging, and shipping in additional reusable packaging does not offer any environmental added value, the EU Packaging Regulation must equate shipping in product packaging with shipping in reusable packaging. Policymakers can also promote dialogue between manufacturers and retailers and conduct further studies to ensure that product packaging is designed in such a way that it is also suitable for shipping where this can be easily implemented. To improve the recyclability of packaging, policymakers should also promote cooperation between packaging manufacturers and waste disposal companies (see p. 48).

Consumers are also crucial, as the choice of packaging also depends on their preferences and their willingness to contribute to higher costs if necessary. This can be supported by policymakers through awareness campaigns in schools on the topics of reusable packaging, plastics, waste separation, shipping in product packaging and bundling orders and shipments (see p. 51). Additional information on material composition, environmental impact and disposal instructions from retailers can only be effective if consumers have the right background knowledge and are aware of the effects of their own actions and behaviour. In order to encourage customers' decisions in favour of more sustainable packaging options, green nudging measures should continue to be permitted (see p. 51) and not be banned outright as so-called "dark patterns" that influence consumers (see sustainable consumption). 

3. Digital infrastructure

Even if the digital infrastructure only generates a small proportion of the emissions generated by online shopping (p. 55), emissions can be reduced on both the retailer and customer side by promoting the use of renewable energies. The focus here should be put on incentives and reducing bureaucracy (see logistics centres).

As possible reduction points, the study also identifies the sustainable use of end devices with increased energy efficiency and the ordering behaviour of the customer themselves, i.e. the number of search queries made or emails sent, etc. In addition, the Fraunhofer Institute identifies the use of energy-saving wired networks instead of mobile data, ordering via smartphone and the shared use of one device instead of the sporadic use of many devices as the most sustainable ordering option (see p. 62f.). Large-scale educational campaigns could help to make people aware of the consequences of their own behaviour and show them where they themselves have the potential to make a contribution, albeit a small one, to reducing GHG emissions when shopping online. As the use of mobile data causes more emissions than cable-based options, the nationwide expansion of fibre optics should also be pushed forward by policymakers in the interests of increased environmental sustainability - as should the expansion of the more energy-efficient 5G network for the use of mobile data (see p. 64).

It also makes sense for retailers to take these aspects into account and share servers and clouds with others. This is something that policymakers can support. In addition, policymakers should create incentives for the use of energy-efficient and durable IT solutions in companies.

4. Logistics centres

Logistics centres are most sustainable (see p. 72) when they generate the energy they need themselves. To this end, it is crucial that policymakers create standardised nationwide requirements for the installation of photovoltaic systems on roofs and facades and reduce the extensive bureaucratic hurdles. This is becoming increasingly important, especially as increasing levels of automation lead to higher energy requirements. Using self-generated energy (including waste heat) can reduce emissions significantly and may make the location carbon-neutral or even energy-plus. In addition, using electricity generated on-site in logistics centres can also reduce the load on the regional power grid.

Process efficiency in logistics centres also helps to reduce emissions (see p. 70f.). The measures mentioned above that support the reduction of returns can also help with this, as can a consumer information campaign that makes it clear to consumers that they themselves can also make a contribution to greater sustainability, for example by rethinking their own returns and ordering behaviour, using advice and information from retailers and bundling their orders.

5. New business models

Even if further research is required in this area, the study concludes that new business models have hardly any additional negative impacts on the environment or offset these at other points (see p. 86). At first, therefore, new digital business models should be supported by policymakers rather than impeded. On-demand production, in particular, has been identified by the Fraunhofer Institute as an interesting business area that driven by digitalization can stop overproduction and thus overstocking and wasting resources (see p. 83f). In general, however, the political starting points already mentioned above for “traditional” e-commerce also lead to emissions reduction here as well.

For example, offering instant delivery becomes more sustainable primarily by promoting the electrification of the last mile (see p. 77). In particular, ordering large baskets of goods is especially advantageous to save customer trips, as is bundling orders and optimising routes - i.e. delivering to as many persons as possible per trip. This means that larger delivery transport vehicles are needed. Policymakers should consider and set up the corresponding loading zones in urban planning (see delivery transport). Other delivery traffic would benefit from this as well and it would improve traffic flow (see p. 85f). Furthermore, this could save emissions since delivery services would no longer have to make unnecessary detours to look for parking spaces (see p. 110).

The above-mentioned policy measures in packaging and transport would also have environmental benefits for re-commerce business models, i.e. the sale of used products.  Especially in transport and logistics, this could offset the additional trips due to sending goods back to retailers for processing. Reusable packaging is especially interesting in this business model, as a purchase is also often linked to the sale of a used appliance.  This means that the customer can use the reusable packaging they receive to return the used appliance to the retailer (see p. 85). As this often involves electrical goods, it makes sense to use sturdy plastic boxes that provide better protection for appliances, but that cannot be adjusted to the size of the product.  For this to still be possible in the future, reusable packaging should be exempted from the 40% empty space ratio limit of the EU Packaging Regulation (see packaging).

In general, re-commerce models are considered environmentally beneficial, since used products remain in circulation. Policymakers should therefore promote this business model. This can be done by taking action in many different sub-areas: from the right to repair, product liability issues to questions of extended producer responsibility or green claims (see sustainable consumption). Care should be taken to consider re-commerce in the relevant legislative procedures and to ensure that this business model remains attractive to retailers and supports the circular economy.

In retail-as-a-service models (RaaS), shops are used to display goods and advise customers, but purchases are usually made online. To ensure RaaS has a low environmental impact, these showrooms must be in locations that are already well frequented, have high footfall and are easily accessible by public transport, on foot or by bike. This requires policymakers to continue to support and expand local public transport links and cycling, ensuring that people can get into the city centres in an emission-free way. In this way, RaaS can also contribute to the much-touted revitalization of city centres. 

6. Sustainable consumption

The study concludes that e-commerce can promote sustainable consumption, especially through greater product transparency and offering a wider range of used goods (see p. 96). However, this requires the right political conditions on the one hand, and consumers who understand and actually use the information provided on the other hand.

If, as the authors do, it is assumed that information helps consumers to overcome their attitude-behaviour gap, policymakers must ensure that retailers can and want to continue to advertise their sustainable products as such. If this becomes too complicated and there is legal uncertainty about which claims are allowed to be made in relation to sustainable product characteristics and which not, this could lead to retailers refraining from making such claims in the future. At the same time, it must also be considered what information retailers actually have and that their possibilities to check environmental claims are very limited. The EU legislation on green claims must take all of this into account so that sustainable products can continue to be advertised and labelled as such for consumers. Furthermore, there should be standardised EU-wide regulations for eco-labels and information for environmental properties. This makes it simpler for consumers on the one hand, and on the other hand, enables businesses to offer their goods on the entire single market without further registration or certification processes etc. Otherwise, the costs associated with cross-border sales are too high, especially for SMEs, making this option unattractive. This is why labels as well as the requirements and methods for providing information about environmental properties must be designed to be uniform across the EU as far as possible. As the study points out, harmonisation is essential here (see p. 88). To this extent, a green claims regulation instead of a directive would have been the only appropriate legal instrument. 

Policymakers should also have research conducted on how designing recycling fees along environmental lines (eco-fees) would affect consumers (see p. 88). However, it can be expected that making more environmentally harmful materials more expensive or at least bringing them into line with the prices of sustainable products will also lead to sustainable products appearing economically more attractive as well.

Personalisation and gamification approaches can also have positive effects on the sustainability footprint of consumer behaviour. Even if further research in this field on the cause-effect relationships should be targeted by policymakers, so that concrete recommendations can be made for the sustainable design of e-commerce (see p. 98), it should already be ensured today that legal plans in consumer and privacy protection do not rule out such approaches without exploiting their environmental potential.

This also applies to green nudging methods, which the study found to be highly promising. These approaches make consumers aware of the effects of their own activities, for example by drawing their attention to the behaviour of others as well as the positive environmental features of certain products, packaging and delivery options or by pointing out the negative impacts of their own returns behaviour. These approaches steer consumers towards making decisions in favour of an (environmentally) desirable option. Under the heading of “digital fairness”, this “influencing” of consumer behaviour is also often seen as “dark patterns”, especially in the context of the debate on revising EU consumer law.

As green nudging approaches use the same principles as the so-called dark patterns, they are legally classified in the same category, despite their environmentally positive intention.[3] Corresponding, rather generalised formulations in other existing laws strongly suggest that a general ban on “dark patterns” is tantamount to banning green nudging (e.g. Digital Services Act). Therefore, if green nudging is to continue to be used by businesses and to have positive environmental effects on consumer behaviour, policymakers must ensure that nudging is explicitly exempted from any bans, provided it is used for sustainability purposes. 

The points mentioned above relating to the other sub-areas that support further greening of e-commerce also help, directly or indirectly, to make online consumption more sustainable. This includes supporting the above-mentioned re-commerce business models, which can make an essential contribution to fostering sustainable consumption. The right legal framework conditions are needed for the re-commerce market to continue to grow.  This involves harmonising national rules across the EU to create a single market for used products that are intended for refurbishment, re-use or repair, as well as for recycled and secondary raw materials. This is the only way to strengthen cross-border trade in this field. Financial or (sales) tax incentives could also make second-hand products more attractive to consumers and make this market stronger. However, this also means that companies must be able to offer and advertise second-hand and refurbished products as sustainable even if there are products with better energy efficiency etc. available, since reusing products that are already in circulation offers significant environmental added value.

On the one hand, this overview of the starting points for greater environmental sustainability in online retail shows that there is still a lot to do. However, it also shows that measures and improvements can be clearly identified and, if implemented correctly in one area, often lead to improvements in another area and that, despite all the complexity or even because the individual sub-aspects are so intertwined, making even small adjustments can often lead to success. On the other hand, it is clear that neither retailers nor parcel service providers nor infrastructure providers nor consumers nor policymakers can manage the task of establishing a more sustainable economy and more sustainable consumption alone. Instead, all the relevant stakeholders must work together to create a more sustainable ecosystem for e-commerce and thus make online shopping even more environmentally-friendly. With this in mind - let’s all tackle this together!


[1]Cf. Ed. Prof. Dr. Gerrit Heinemann / Alien Mulyk (2023): bevh-Retourenkompendium, 2. Edition, chapter 5: Retailer perspective,

[2] Cf. Birkenfeld (2020): VAT assessment of the donation of goods to charities,

[3]Cf. Kühling/Sauerborn (2022): Legal framework conditions of so-called ‘Dark Patterns’,, p. 16f.