Packaging rules in Europe are moving from broad sustainability ambitions to specific design, labelling and documentation requirements. Regulation (EU) 2025/40—the Packaging and Packaging Waste Regulation, usually shortened to PPWR—creates a common framework for packaging placed on the EU market.
For product brands, the practical question is not simply “Is our packaging sustainable?” It is whether the packaging has been designed, specified and documented in a way that supports compliance as the new rules begin to apply.
What is the PPWR?
The PPWR covers the full life cycle of packaging, including material use, recyclability, labelling, reuse, waste prevention and extended producer responsibility. It applies to packaging regardless of material or where the packaging waste originates.
The regulation entered into force on 11 February 2025 and generally applies from 12 August 2026. Some obligations have later deadlines because technical methods and implementing rules still need to be finalised. The European Commission’s packaging waste overview is a useful starting point, while the complete legal text is available through EUR-Lex.
Why packaging design decisions matter now
Packaging development can take months. A structural redesign may involve new tooling, print tests, transit testing and supplier qualification. Brands that wait until every technical detail is final may have too little time to adapt efficiently.
A better approach is to build flexibility into current packaging specifications. That means understanding which materials are used, how components are separated, whether the structure is larger than necessary and what evidence supports environmental claims.
Seven PPWR areas brands should review
1. Packaging minimisation
Packaging should use no more weight and volume than necessary to perform its functions. Protection still matters: a damaged product can create more environmental and financial loss than a carefully designed protective pack. The objective is right-sizing, not removing essential performance.
2. Recyclability by design
Material combinations, coatings, windows, adhesives, magnets and inserts can affect how easily a pack is sorted and recycled. Ask suppliers for a component-level material list rather than relying on a general description such as “paper packaging.” Our guide to reducing packaging waste without compromising quality explains how to simplify a pack while preserving function.
3. Empty space in transport and e-commerce packaging
The PPWR introduces a maximum empty-space ratio of 50% for grouped, transport and e-commerce packaging from 2030, subject to the final calculation method and relevant exceptions. Brands using oversized shipping boxes should begin collecting dimensional data and comparing box sizes with the products they actually ship.
4. Recycled content and responsible sourcing
Requirements differ by material and application. Paper-based packaging also needs credible sourcing information. If responsible fibre sourcing is part of the specification, confirm what documentation and chain-of-custody claims the supplier can provide.
5. Labelling and consumer information
Future harmonised labels are intended to help consumers sort packaging correctly. Avoid filling artwork with speculative symbols before the applicable format is confirmed. Instead, reserve suitable artwork space and keep packaging files easy to update.
6. Substances of concern
Inks, coatings, laminations and adhesives are part of the packaging specification, not decorative afterthoughts. Request declarations for relevant restricted substances and make sure changes in finishes are reviewed by the same compliance process as changes in board or plastic.
7. Documentation and supplier responsibilities
Keep approved specifications, bills of materials, test results, supplier declarations and artwork versions together. Clear records make it easier to demonstrate why a packaging choice was made and to update it when delegated or implementing rules change.
A practical PPWR packaging audit
- List every packaging component, including labels, tapes, inserts and closures.
- Record material, weight and supplier for each component.
- Measure the packaged product and calculate avoidable empty space.
- Identify components that consumers may struggle to separate.
- Review environmental statements on artwork and product pages.
- Confirm which test reports and declarations are available.
- Prioritise high-volume packaging formats for redesign first.
Choosing packaging formats with compliance in mind
Different formats solve different problems. Folding cartons can offer efficient material use and strong print coverage. Corrugated boxes provide transport protection and can be right-sized for distribution. Custom rigid boxes support premium presentation, but their components and end-of-life route require careful specification.
What should brands do in 2026?
Start with information rather than assumptions. Map packaging components, involve procurement and compliance teams early, and ask suppliers specific questions about materials, recyclability and documentation. The best outcome is packaging that protects the product, communicates the brand clearly and can adapt as detailed PPWR requirements develop.