One of the most important regulatory changes affecting the European packaging market – PPWR
The Regulation entered into force on 11 February 2025 and, as a general rule, applies from 12 August 2026. At the same time, individual PPWR requirements will apply at different dates, and some detailed rules will be established in subsequent delegated and implementing acts. The Regulation repeals the existing Directive 94/62/EC.
The PPWR introduces new requirements concerning, among other things, packaging design, packaging minimisation, recyclability, labelling, documentation, and the obligations of individual entities involved in the supply chain.
For the paper and board industry, this is a particularly significant change. Board has for years been one of the main materials used to manufacture transport, grouped and sales packaging. Regular slotted cartons, die-cut boxes, separators, corner protectors, display packaging and large industrial packaging are present in almost every sector of the economy.
Does this mean that cardboard packaging automatically complies with PPWR requirements?
No.
The fact that packaging is made of paper or board may be a significant advantage from the perspective of recyclability and the circular economy. However, the material itself does not determine whether a particular package complies with all PPWR requirements.
In practice, factors such as the following will be important:
packaging design and construction,
type and weight of the materials used,
sorting and recycling possibilities,
coatings used,
adhesives,
inks and varnishes,
laminates and other additional components,
packaging weight and volume,
the relationship between the material used and the packaging’s function,
as well as the availability of appropriate documentation.
Therefore, a compliance assessment should always relate to the specific packaging, its intended use and the role of the individual entities in the supply chain, rather than solely to the material from which the packaging is made.
PPWR – why was the new Regulation introduced?
One of the main objectives of the PPWR is to reduce the negative environmental impact of packaging and packaging waste, reduce the amount of waste, increase reuse and recycling rates, and support the circular economy. The Regulation covers all types of packaging, regardless of the material used, including paper and cardboard packaging.
The PPWR covers different stages of a package’s life cycle – from its design and manufacture, through its making available or placing on the market, to the management of the resulting waste.
One of the important directions of the changes is designing packaging with its subsequent recycling in mind.
This means a change in the way packaging design is approached.
Until now, the basic questions have often been:
Is the packaging sufficiently strong? Does it protect the product? Can it be manufactured efficiently?
In the context of PPWR, it is also worth asking:
Can the amount of material used be reduced without compromising functionality?
Does the packaging design support recycling?
Can the individual components be easily separated?
Do the additives used interfere with sorting or recycling?
Can the packaging be appropriately classified according to future recyclability assessment criteria?
Is documentation available regarding the materials and components used?
This is precisely why the role of packaging manufacturers may extend beyond the production of cartons in the coming years.
Is cardboard a “PPWR-compliant” material?
This is one of the questions increasingly being asked in the industry.
Paper and cardboard are materials widely used in the circular economy and can be recycled. However, this does not mean that every package made of cardboard automatically meets all PPWR requirements.
The Regulation provides for the assessment of the recyclability of a specific package, rather than merely its primary material. From 2030, recyclability will be assessed in accordance with Design for Recycling criteria, and the detailed rules for this assessment will result, among other things, from relevant delegated and implementing acts.
Therefore, when designing packaging, it is worth analysing not only the type of board, but also:
the type and grammage of the material,
packaging construction,
adhesives used,
inks and varnishes,
protective coatings,
laminates and films,
tapes,
windows,
staples,
components made of other materials,
the closure method,
the possibility of separating individual elements,
and the behaviour of the entire package during sorting and recycling.
In practice, this means that the term “paper packaging” is not, in itself, sufficient to assess compliance with the PPWR.
Design for Recycling – designing packaging with recycling in mind
One of the important elements of the PPWR is the approach known as Design for Recycling (DfR), meaning designing with recycling in mind.
Packaging should be designed not only with regard to manufacturing and use, but also with consideration of what will happen to it after its useful life ends.
The PPWR provides for recycling performance grades A, B and C.
It is worth emphasising, however, that this does not mean a simple obligation to independently assign a percentage recyclability value to every carton according to one universal formula.
The PPWR provides for detailed criteria and methodologies to be established through delegated and implementing acts. The manufacturer will assess the recyclability of the packaging on the basis of these rules.
As a general rule, from 1 January 2030, taking into account the mechanism concerning the entry into force of the relevant delegated acts, packaging may be placed on the market if it meets the requirements corresponding to classes A, B or C.
From 1 January 2038, the requirements will become stricter – packaging will have to meet requirements corresponding to at least class A or B. This is why it is already worth taking the direction of these changes into account when designing new packaging.
What does PPWR mean in practice for a cardboard packaging manufacturer?
The PPWR may change the way packaging manufacturers and their customers cooperate.
A packaging manufacturer will no longer be seen solely as a supplier of a product with specified dimensions.
Information concerning the following may become increasingly important:
material,
construction,
weight,
components,
recyclability,
coatings and additives used,
technical documentation,
as well as information required by the customer to fulfil its own obligations.
The PPWR defines, among other things, the concept of a “supplier” as an entity that supplies packaging or packaging materials to a manufacturer. Article 16 provides for an obligation to provide the manufacturer with the information and documentation necessary to demonstrate compliance of the packaging or packaging materials with the requirements of the Regulation.
This means that the quality and completeness of information passed along the supply chain will become increasingly important.
Packaging manufacturer vs. product manufacturer – who is responsible for PPWR?
At this point, it is particularly important to distinguish between the terminology used in the PPWR.
The Regulation uses terms such as manufacturer, producer, supplier, importer and distributor. The roles of these entities and the obligations associated with them do not always correspond to the common understanding of the term “manufacturer”.
Therefore, it cannot be assumed as a universal rule that all PPWR obligations are the responsibility of the company that physically manufactured the carton.
Depending on the type of packaging, how it was manufactured, labelled and made available or placed on the market, specific obligations may rest with different participants in the supply chain.
Specific rules also apply where an importer or distributor makes packaging available under its own name or trademark or modifies the packaging in a way that may affect its compliance with the requirements of the Regulation.
Therefore, for every project, it is worth establishing first:
What is the role of our company and our customer under the PPWR, and what obligations arise from that role?
This approach helps avoid situations in which the packaging manufacturer and its customer have different expectations regarding the scope of responsibility and documentation.
Documentation – an increasingly important element of cooperation
One of the practical aspects of the PPWR will be appropriate documentation.
Depending on the type of packaging and the scope of obligations of the relevant entity, it may be necessary to carry out an appropriate conformity assessment procedure, prepare technical documentation and – in cases provided for by the Regulation – an EU declaration of conformity.
At the same time, the supplier of packaging or packaging materials should provide the information and documents required by the manufacturer to demonstrate compliance.
Depending on the type of product and its intended use, the following may be relevant:
material specifications,
information on composition,
data concerning the weight of individual components,
information on coatings,
information on adhesives used,
information on inks and varnishes,
declarations or information received from raw material suppliers,
food-contact documentation, where applicable,
information concerning packaging properties,
technical documentation,
results of relevant tests or assessments.
This does not mean that every carton will require an identical set of documents.
The scope of the required documentation depends on the type of packaging, its intended use, the role of the relevant entity and the requirements applicable to the specific solution.
The key principle, however, is simple:
Information concerning packaging should be suitable for use and transmission throughout the supply chain.
Packaging minimisation – less material, but not at any cost
Another important element of the PPWR is reducing the weight and volume of packaging to the minimum necessary to ensure its functionality.
Article 10 establishes requirements concerning the minimisation of packaging weight and volume, taking its function into account. The Regulation also provides for additional criteria concerning certain design features that may increase the perceived volume of packaging without functional justification.
In practice, this may lead to greater interest in:
lighter constructions,
more material-efficient die-cut designs,
optimised dimensions,
constructions requiring less material,
solutions reducing the number of unnecessary components,
packaging tailored to the product.
At the same time, minimisation does not mean:
“the thinner the board, the better.”
Packaging must still fulfil its basic function – protecting the product.
If reducing the grammage or dimensions results in product damage, an increase in complaints, the need for additional protective measures or greater losses during transport, such a solution will not necessarily be optimal from the perspective of the entire supply chain.
Optimisation should therefore always take the function of the packaging into account.
Empty space in packaging – another element of PPWR
The PPWR also addresses the problem of excessive empty space in packaging.
Under Article 24, by 1 January 2030 or three years after the entry into force of the relevant implementing acts – whichever is later – economic operators filling grouped packaging, transport packaging or e-commerce packaging will be required to ensure a maximum empty-space ratio of 50%.
Importantly, this obligation applies to entities that fill specified types of packaging. It does not automatically mean that the manufacturer of an empty carton is responsible for ensuring that the customer’s packaging complies with this limit.
At the same time, packaging design is important for reducing empty space.
In practice, it is worth analysing the entire process:
product → primary packaging → grouped packaging → transport packaging → pallet → transport.
Well-designed packaging can simultaneously:
reduce board consumption,
reduce empty space,
improve pallet utilisation,
reduce transport costs,
reduce the amount of warehouse space required.
The PPWR may therefore further increase the importance of cooperation between packaging design and logistics.
Cardboard recycling – why does packaging construction matter?
Cardboard is a material widely used in paper and board recycling systems. At the same time, the effective recovery of a specific package may also depend on its construction and the components used.
Therefore, when designing packaging, it is worth paying attention to:
Adhesives
The type of adhesive used may affect the properties of the entire package and its behaviour during processing.
Inks and varnishes
Printing is an important element of many packages, but it should also be analysed in the context of the properties of the overall solution and its subsequent processing.
Laminates and coatings
Additional material layers may affect packaging properties, so their use should be appropriately assessed during the design process.
Additional components
Windows, tapes, handles, plastics, staples and other components may affect the properties of the entire package.
For this reason, the term “paper packaging” does not always mean packaging made exclusively from a single material.
Mono-material packaging – is it always the best solution?
The packaging industry is increasingly talking about mono-material solutions.
The idea is relatively simple: limiting the number of different materials may make it easier to design packaging with its subsequent processing in mind.
This does not mean, however, that every package should be completely free of additional components.
Packaging must still fulfil its primary function: protecting the product and enabling its safe storage and transport.
For products requiring protection against moisture, grease, mechanical damage or other factors, appropriate material solutions may be justified.
Therefore, the right question is not always:
“How can we remove all additional components?”
A better question is:
“How can we design packaging that provides the required functionality with the lowest possible material complexity?”
This approach may become increasingly important in packaging design.
Recycling at scale – the next stage of requirements
The PPWR also provides for the development of the approach known as “recycled at scale.”
In simple terms, this means moving beyond simply assessing whether packaging has been appropriately designed for recycling to assessing whether a particular type of packaging is actually being recycled on an adequate scale.
Under the PPWR, the recycled-at-scale element is intended to become relevant from 2035, with the detailed rules and thresholds to be established through the relevant implementing acts.
Two important stages can therefore be distinguished:
2030 – greater importance of Design for Recycling criteria;
2035 – additional importance of actual recycling at scale.
For paper and cardboard, this is particularly interesting given the existing collection and recycling systems for these materials.
However, this does not mean that every cardboard package will automatically meet all future criteria.
Does PPWR require the use of recycled paper?
This is another topic that is often oversimplified.
The PPWR introduces specific minimum recycled-content requirements primarily for plastic packaging.
This does not create an analogous universal obligation to use a specified percentage of recycled fibres in all paper and cardboard packaging.
At the same time, increasing the share of secondary raw materials and reducing the use of virgin raw materials is one of the directions of European circular-economy policy.
For cardboard packaging, factors that may be relevant include:
availability of recovered paper,
fibre quality,
raw material source,
technical parameters of the board,
strength requirements,
intended use of the packaging.
For a packaging manufacturer, the key is to find the right balance between functionality, quality, safety and efficient use of resources.
Packaging labelling – what will change?
The PPWR provides for the introduction of a more harmonised packaging labelling system.
Under Article 12, from 12 August 2028 or 24 months after the entry into force of the relevant implementing acts – whichever is later – certain packaging will be required to carry harmonised labelling indicating its material composition, with the aim of facilitating proper sorting.
It is important to remember, however, that the PPWR provides for exceptions and specific rules concerning certain types of packaging. In particular, the requirement does not apply in the same way to all transport packaging; the Regulation provides for specific exemptions in this area, including an exception for e-commerce packaging.
Therefore, detailed labelling requirements for a particular product should be analysed taking into account its type and intended use.
PPWR and exports of cardboard packaging
For Polish manufacturers supplying packaging to Germany, France, the Czech Republic, the Netherlands, Italy or other EU countries, the harmonisation of regulations is highly significant.
One of the objectives of the PPWR is to harmonise packaging requirements within the EU internal market and reduce barriers arising from differences between individual national markets.
This does not mean, however, that all packaging-related obligations will be completely harmonised.
In particular, obligations related to Extended Producer Responsibility (EPR) continue to have a significant national dimension.
Companies exporting products or packaging to different EU Member States should therefore analyse both the requirements arising directly from the PPWR and the obligations applicable in individual Member States.
Extended Producer Responsibility – EPR
The PPWR also regulates matters related to Extended Producer Responsibility.
In practice, this means obligations concerning, among other things, registration, financing certain costs of packaging waste management and fulfilling reporting obligations – in accordance with the rules applicable in the relevant Member State.
From the perspective of a cardboard packaging supplier, it may be important to provide the customer with appropriate packaging data, such as:
packaging type,
weight,
material,
share of individual components,
construction,
information required for proper reporting.
The better organised the data is on the supplier’s side, the easier it will be for the customer to use it when fulfilling its own obligations.
PPWR is not only about environmental issues – it is also about costs
One practical consequence of the PPWR may be a change in the way packaging costs are analysed.
Until now, the price of a carton has often been assessed primarily in terms of:
price per unit + price per kg + transport cost + production cost.
In the future, the broader cost of the packaging solution may become increasingly important.
The total cost may be affected by:
packaging weight,
material type,
construction,
components used,
optimisation opportunities,
documentation requirements,
EPR-related obligations,
labelling requirements,
the possibility of using a given solution in a particular market.
Therefore, the cheapest carton at the time of purchase will not necessarily be the cheapest solution across the entire supply chain.
Why is it worth optimising packaging now?
The PPWR introduces requirements with different application dates.
Some provisions apply from 12 August 2026, while others will become applicable in subsequent years. For some requirements, the exact dates also depend on the adoption of the relevant delegated or implementing acts.
This means that companies do not have to wait until the last minute to analyse their packaging.
Packaging design is a long-term process.
If a company uses dozens or hundreds of different cartons, changing the entire portfolio within a short period may be costly and organisationally difficult.
A sensible approach may therefore be to gradually analyse existing solutions already today.
How can a company prepare for the PPWR?
A good first step may be an audit of the packaging currently in use.
Identify all packaging used
It is worth creating a list of:
cartons,
die-cut boxes,
grouped packaging,
transport packaging,
separators,
corner protectors,
e-commerce packaging,
other packaging components.
Determine the material composition
For each solution, it is worth knowing:
what type of board is used,
its grammage,
what additional components are present,
whether laminates or coatings are used,
which adhesives and inks are used.
Analyse the possibility of reducing material use
It is worth checking:
whether the die-cut area can be reduced,
whether the grammage can be optimised,
whether the number of components can be reduced,
whether the amount of additional components can be reduced.
Check the construction
Is the packaging appropriately matched to the product?
Does it contain unnecessary empty space?
Can the construction be changed without reducing product protection?
Collect the documentation
It is worth organising:
specifications,
declarations,
technical data sheets,
raw-material information,
test results,
composition data.
Talk to your packaging supplier
A good packaging manufacturer should be able to discuss with the customer not only:
“Can we manufacture this carton?”
but also:
“Can we optimise the construction of this packaging in terms of material consumption, functionality and future recycling requirements?”
Packaging manufacturer as a transformation partner
The PPWR can be viewed as an additional regulatory obligation.
However, the new rules can also be seen as an impetus to modernise packaging.
A well-designed carton can simultaneously mean:
lower material consumption,
lower weight,
lower transport costs,
better use of warehouse space,
reduced waste,
better fit to the product,
easier preparation of appropriate documentation.
In this context, a packaging manufacturer can act not only as a supplier but also as a technical partner in optimising packaging and the supply chain.
What does PPWR mean for transport packaging?
For transport packaging, the appropriate combination of strength, weight, construction and functionality may be particularly important.
Corrugated packaging is widely used in transport because it is:
lightweight,
relatively strong,
easy to fold,
stackable,
easy to label and print,
widely used in paper and board recycling systems.
At the same time, dimension optimisation is highly important for transport packaging.
If packaging is significantly larger than the product, this may result in an unnecessary increase in transport volume.
If it is too small or too weak, the risk of product damage may increase.
The optimal carton should therefore provide appropriate protection while making rational use of material and space.
What about large industrial packaging and octabins?
The PPWR also covers packaging used in industry.
For large cardboard packaging, such as octabins, large transport boxes, palletised grouped packaging or specialist industrial packaging, the following factors may be particularly important during design:
load-bearing capacity,
stability,
packaging weight,
transportability,
collapsibility,
dimensional optimisation,
reduction of unnecessary components,
the possibility of recovering the packaging after use.
In such applications, packaging design should take the entire logistics cycle into account.
Sometimes a small increase in board strength may make it possible to reduce the number of additional structural components. In another case, changing the geometry of the packaging may be the better solution.
Therefore, there is no single universal solution that will be optimal for every application.
Packaging should be individually matched to the product, the way it is used and the logistics conditions.
PPWR and packaging procurement – what questions should you ask your supplier?
Companies purchasing packaging can already include additional questions in their requests for quotations.
For example:
What material is the packaging made from?
What is the unit weight of the packaging?
Does the packaging contain additional materials or components?
Are coatings, films or laminates used?
What basic information is available regarding the recyclability of the packaging?
Can the supplier provide information and documentation concerning the materials and packaging properties to the extent required within the supply chain?
Has the construction been optimised in terms of material consumption?
Is it possible to reduce the packaging weight without compromising its protective function?
Can the construction be simplified?
Can the packaging be designed with greater consideration of future Design for Recycling criteria?
Such questions may become a standard part of the procurement process in the future.
Key PPWR dates
It is worth remembering several key dates.
11 February 2025
The PPWR entered into force.
12 August 2026
The Regulation generally starts to apply. This is a key date for the packaging market.
12 August 2028
As a general rule, from this date, taking into account the mechanism concerning the 24-month period following the entry into force of the relevant implementing acts, the harmonised labelling provided for in Article 12 will begin to apply to packaging covered by the relevant provisions.
2030
Another very important stage – requirements concerning the design of packaging with recycling in mind and the assessment of its recyclability according to classes A, B or C. The exact date on which some requirements will apply also depends on the entry into force of the relevant delegated acts.
2035
The assessment of recyclability will be supplemented by an element related to recycling at scale (“recycled at scale”), in accordance with the rules set out in the PPWR and the relevant implementing acts.
2038
The recyclability requirements will become stricter – as a general rule, packaging meeting the requirements of class A or B will be allowed to remain on the market.
Important: The PPWR timetable is not limited to these dates. Some detailed requirements will depend on the adoption of relevant delegated and implementing acts. Companies should therefore continuously monitor further legislative developments and European Commission guidance.
PPWR – obligation or opportunity?
For the packaging industry, the PPWR undoubtedly means new requirements and obligations.
At the same time, from a business perspective, it can also serve as an impetus for:
modernising packaging portfolios,
reducing raw material consumption,
improving logistics efficiency,
developing new designs,
reducing waste,
making better use of materials,
organising packaging-related documentation more effectively.
Companies that begin analysing their packaging sufficiently early may find it easier to prepare for the next stages of regulatory change.
For cardboard packaging manufacturers, this means developing not only production technology but also design, material and documentation expertise.
Summary – what does PPWR mean for cardboard packaging?
The PPWR is not a regulation directed against cardboard.
Paper and cardboard are materials widely used in the circular economy, and packaging made from these materials can fit well with the direction of European packaging policy.
At the same time, the new rules demonstrate that packaging compliance is determined not solely by the material from which the packaging is made.
The entire system matters:
material + construction + functionality + weight + components + recyclability + documentation + labelling.
For manufacturers and suppliers of cardboard packaging, this means a change in the way packaging is designed and in the way they cooperate with customers.
In the future, a customer may need more than:
“a carton measuring 400 × 300 × 200 mm.”
They may need a comprehensive packaging solution that:
protects the product,
is optimised in terms of material use,
meets the requirements of their supply chain,
takes the possibility of subsequent recovery after use into account,
has the appropriate information and documentation,
can be used on the EU market taking the relevant regulatory requirements into account.
That is why it is worth treating the PPWR not merely as a one-off legal change, but as a long-term change in the way packaging is designed, manufactured and purchased.
For board and packaging manufacturers, this means one thing:
The best packaging of the future will not necessarily be packaging made from the smallest possible amount of material.
Rather, it will be a solution that uses resources rationally, provides functionality appropriate to its application, limits unnecessary materials and is designed with its subsequent recovery in mind.
How can you prepare for the PPWR?
If your company uses cardboard packaging, it is worth analysing the following already today:
Material
What are your current packages made of?
Construction
Can the design be simplified or optimised?
Weight
Can the amount of material be reduced without compromising functionality?
Additional components
Are all the components used actually necessary?
Empty space
Are the packaging dimensions appropriately matched to the product?
Recycling
Are the construction and materials appropriately selected with their subsequent processing in mind?
Documentation
Does the company have information concerning materials, weight, construction and components used?
Supply chain
Can the information required by the customer be efficiently passed between the individual entities?
An appropriately early analysis can make it easier to prepare your packaging portfolio for the next stages of PPWR implementation.
Important legal information:
This article is intended for informational and educational purposes only. It does not constitute legal, tax or technical advice and does not constitute an individual assessment of the compliance of a specific package with Regulation (EU) 2025/40.
The requirements applicable to a specific package depend, among other things, on its type, construction, materials and components used, intended purpose, the manner in which it is made available or placed on the market, and the role of the individual entities in the supply chain.
Furthermore, some detailed PPWR requirements are linked to delegated and implementing acts, which establish, among other things, detailed criteria and methodologies for assessing recyclability, labelling and other requirements provided for by the Regulation.
When making decisions concerning the compliance of a specific package, we recommend carrying out an individual legal and technical analysis, taking into account the current wording of the PPWR and the relevant implementing acts, delegated acts and standards.
Information current as of: 14 August 2026
Sources and reference materials:
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) – full text of the legal act available on EUR-Lex.
European Commission guidance on the PPWR dated 10 June 2026 – a document concerning the interpretation of selected provisions of the Regulation. The Commission also states that the guidance is intended to support the uniform application of the PPWR but does not replace the Regulation itself.
European Commission – Packaging Waste / PPWR – information concerning the objectives and implementation of the Regulation.