Manufacturers must demonstrate packaging conformity
Before placing packaging on the market, the packaging manufacturer must carry out a conformity assessment, draw up technical documentation and issue an EU declaration of conformity in accordance with Annexes VII and VIII to the PPWR. The documentation must demonstrate compliance with the applicable requirements laid down in Articles 5 to 12.
The technical documentation and the EU declaration of conformity must be retained for five years in the case of single-use packaging and for ten years in the case of reusable packaging. The packaging, or a document accompanying it, must bear information identifying the manufacturer and provide the manufacturer’s contact address, as well as an identifier enabling the packaging to be traced. Corresponding obligations also apply to importers and distributors, as appropriate.
In this context, a “manufacturer” is an entity that manufactures packaging, or has packaging designed or manufactured, and markets it under its own name or trademark. This term must not automatically be confused with a “producer” responsible for extended producer responsibility.
PFAS in paper-based food-contact packaging
From 12 August 2026, food-contact packaging must not be placed on the market if it contains PFAS at or above any of the limits laid down in Article 5(5):
- 25 ppb for any PFAS measured using targeted PFAS analysis, with polymeric PFAS excluded from quantification;
- 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, with polymeric PFAS excluded from quantification; or
- 50 ppm for PFAS, including polymeric PFAS.
If the total fluorine content exceeds 50 mg/kg, the manufacturer, importer or downstream user must, upon request, provide evidence of the amount of fluorine measured as the content of either PFAS or non-PFAS substances.
For the paper industry, this rule is particularly important for grease-resistant and water-resistant papers, takeaway food packaging, bakery papers, trays, bowls and pizza boxes. The European Commission expressly lists these applications among the relevant examples in its information published on 11 August 2026.
The combined concentration limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium present in packaging or packaging components also continues to apply.
Recyclability from 2030
From 1 January 2030, all packaging must be designed for material recycling. Packaging will be classified into the following recyclability performance grades:
- Grade A — at least 95% recyclable by weight;
- Grade B — at least 80% recyclable by weight;
- Grade C — at least 70% recyclable by weight.
Packaging with a recyclability rate below 70% will be considered technically non-recyclable and may not be placed on the market. From 2035, the requirement for packaging to be recycled at scale will also apply. From 2038, Grade C will no longer be sufficient; as a rule, only packaging meeting Grade A or Grade B will be permitted to remain on the market.
Detailed criteria for the individual packaging categories will be established through secondary legislation. For paper-based packaging, it will therefore be necessary to consider not only the fibre itself, but also adhesives, printing inks, coatings, plastic or aluminium barriers, closures and the manner in which the individual components can be separated. The PPWR does not support the assumption that every predominantly paper-based package is automatically recyclable.
Composite packaging and recycled plastic
The mandatory recycled-content shares under Article 7 apply to plastic packaging and the plastic parts of packaging, not to paper fibre. An exemption also applies to packaging where the plastic component represents less than 5% of the total weight of the packaging unit.
This threshold does not, however, constitute a general exemption from the PPWR. Paper-based packaging with a thin plastic barrier must still comply with the applicable requirements concerning chemical substances, packaging minimisation, recyclability, documentation and labelling.
Compostability is not a universal alternative
By 12 February 2028 at the latest, permeable tea, coffee or other beverage bags and single-serve units, as well as sticky labels attached to fruit and vegetables, must be compatible with industrially controlled composting conditions. They must also comply with the relevant composting standards.
Other packaging, including packaging made from biodegradable plastic polymers, must generally be designed for material recycling. The designation “biodegradable” does not in itself replace the need to demonstrate recyclability or compostability under the PPWR.
Less material and a maximum empty-space ratio of 50%
From 1 January 2030, manufacturers must reduce the weight and volume of packaging to the minimum necessary to ensure its functionality. Marketing considerations or an intention to create the impression of a larger product do not, in themselves, justify excessive packaging. The Regulation expressly restricts features such as double walls, false bottoms and unnecessary layers unless they are necessary to meet the relevant performance criteria.
For grouped packaging, transport packaging and e-commerce packaging, the empty-space ratio must generally not exceed 50%. Space filled with paper cuttings, air cushions, foam or other filling materials is also considered empty space.
Reuse: cardboard boxes have a specific status
From 2030, the PPWR establishes reuse targets for several types of transport and grouped packaging. Cardboard boxes are, however, expressly excluded from certain reuse targets applicable to transport packaging.
This is not a general exemption for paper and board. Cardboard boxes remain subject to the requirements concerning packaging minimisation, recyclability, chemical substances, documentation, labelling and extended producer responsibility.
Labelling and waste sorting
The PPWR introduces harmonised material-composition labelling for packaging and corresponding labelling for waste receptacles. The practical design of the system and the precise timetable depend on implementing acts to be adopted by the European Commission. According to the Commission’s current implementation information, the harmonised labelling system is to begin applying from 2028.
Until the relevant implementing acts and graphical specifications have been adopted, businesses should not create their own symbols and present them as official PPWR labelling.
Extended producer responsibility remains a national obligation
A producer making packaging or a packaged product available for the first time within the territory of a Member State must participate in that Member State’s extended producer responsibility scheme. This includes registration, reporting the quantities placed on the market and paying financial contributions. The fees are also to be progressively differentiated according to the recyclability of the packaging.
The PPWR harmonises the basic framework but does not establish a single central register covering the entire EU. A business selling packaged products in several Member States must therefore continue to monitor the registration and reporting requirements of each Member State concerned.
What paper-industry companies should do now
Companies should determine their role in relation to each product — packaging manufacturer, material supplier, importer or producer for EPR purposes.
The PPWR may benefit well-designed and readily recyclable fibre-based solutions, but it does not provide an automatic advantage to every package described as paper-based. Compliance will depend on the demonstrated functionality of the complete packaging system, its material composition and its behaviour within existing recycling streams.
Information current as of 12 August 2026. This article is based on Regulation (EU) 2025/40, the European Commission’s implementation information, the Commission’s guidance document and the Commission’s FAQs published on 3 August 2026. For each specific product, its category, function and all applicable exemptions must be assessed individually.
