EU PPWR: planning custom packaging for European markets
Reviewed 31 August 2026. Regulation (EU) 2025/40 is the EU Packaging and Packaging Waste Regulation (PPWR). It entered into force on 11 February 2025 and generally applies from 12 August 2026. Individual requirements have separate deadlines and conditions.
Review the complete pack, not only the outer box
For MSQ PACK projects, begin with the intended product, destination, distribution channel and protection requirements. A paper-based appearance does not establish recyclability or legal compliance.
- List board, wrap, coatings, laminates, inks, adhesives, windows, magnets, ribbons and inserts separately, with their weights and specifications.
- Review whether unnecessary layers or oversized cavities can be reduced while retaining the protection needed for the product.
- Evaluate separation and recycling implications of mixed materials. Confirm the applicable assessment criteria rather than assuming a paper box automatically passes.
- For food-contact projects, define contact conditions and obtain applicable substance and food-contact evidence. A gift-box description alone is not evidence of food-contact suitability.
Which requirements apply when?
- From 12 August 2026: check the applicable packaging and economic-operator obligations, including substance restrictions, traceability, technical documentation and an EU declaration of conformity where required. PPWR PFAS limits applicable from this date concern food-contact packaging, not every plastic product.
- 12 February 2028: the sales-packaging empty-space minimisation obligation applies, taking necessary functionality and protection into account.
- Harmonised sorting labels: 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later. Scope exclusions apply. Confirm the final applicable rules before printing artwork.
- Design for recycling: 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. Other recyclability, recycled plastic content and packaging restrictions have their own scope and phased deadlines.
- 50% empty-space ceiling: for grouped, transport and ecommerce packaging, 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later, with exemptions. This is not a blanket 2026 limit for every retail box.
Build an EU packaging brief
Include the destination Member State, intended placing-on-market date, product SKU, quantity, distribution channel, dimensions and proposed artwork in the RFQ. Identify the manufacturer, brand owner, importer and the party responsible for each obligation; these roles are not interchangeable.
- Component record: materials, weights and specifications for the complete packaging, including closures, accessories and inserts.
- Evidence: applicable substance information, supplier declarations and recycled-content evidence when a requirement or claim relies on it.
- Traceability and documentation: packaging identification, the applicable technical file and EU declaration of conformity, with the responsible issuer and covered configuration.
- Destination obligations: review packaging EPR registration, reporting and representative requirements for the particular supply chain. Do not assume one registration covers all EU Member States.
- Approval and changes: retain the approved packing sample and record material, artwork and structural changes after approval.
No blanket certification claim
Paper, recycled content, a removable magnet or a particular finish does not by itself establish PPWR compliance. This guide does not represent any packaging as PPWR-certified. Assessment must match the final pack, supply-chain role, destination and applicable date.
Confirm requested documentation and its availability for the specific order before purchase. This is general procurement information, not legal advice or an EU declaration of conformity. The regulation, subsequent acts and applicable national requirements take precedence; obtain qualified advice for project-specific legal decisions.
Include EU packaging requirements in your RFQ