PPWR-Oriented Sustainable Packaging

The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40), known as the PPWR, is the most significant change to European packaging rules in decades. It entered into force in February 2025, and its first major wave of obligations has applied across every EU member state since 12 August 2026.

If you buy packaging for beauty, food, drinks or wellness brands sold in the UK and Europe, the way you source, document and design that packaging now has to adapt. This guide sets out what applies today, what is coming next, and the questions worth putting to your supply chain.

This article is for general information only and does not constitute legal advice. Please confirm your own obligations with your legal and compliance teams.

In effect now: since 12 August 2026

The transition period is over and the first set of PPWR requirements is enforceable law.

• Declaration of Conformity and technical documentation. Packaging placed on the EU market needs an EU Declaration of Conformity, supported by a technical file covering design specifications, material composition and test results. The declaration is drawn up by the manufacturer of the packaging; the importer or brand placing it on the market must verify that it exists and keep a copy — five years for single-use packaging, ten for reusable.
• PFAS and heavy metal limits. For food-contact packaging the thresholds are strict: 25 ppb for any individual PFAS measured by targeted analysis, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS. Total fluorine at 50 mg/kg acts as a screening gate — below it, a sample can generally be treated as compliant without further targeted testing. Separately, the combined concentration of lead, cadmium, mercury and hexavalent chromium must stay below 100 mg/kg in all packaging.
• Extended Producer Responsibility. Producers — usually the brand or importer first making a packaged product available in a national market — must be registered in the EPR system of each member state where they sell. These national registers are being brought into operation on member-state timetables following the EU implementing acts, so check the status and the deadline in each market you supply rather than assuming a single date.
• Operator identification. Packaging must carry the name, registered trade name or trademark and a postal address for the manufacturer and, where applicable, the importer, so that it can be traced.

Next: harmonised labelling

From 12 August 2028 — or 24 months after the relevant implementing acts take effect, whichever is later — packaging will need standardised labels showing material composition and giving consumers clear sorting instructions. The aim is to remove the confusion at the recycling bin and align waste streams across member states.

Then: design, recyclability and minimisation

The design requirements arrive in steps rather than all at once, and the direction of travel matters more than any single date:

• From 1 January 2030, packaging must be designed for material recycling and reach at least a Grade C recyclability rating, meaning at least 70% recyclable. Grade B is 80% and Grade A is 95%. Packaging that cannot reach Grade C may not be placed on the market.
• From 1 January 2035, packaging must also be recyclable at scale through established collection and sorting infrastructure — a higher bar than design alone.
• From 1 January 2038, Grade C is no longer enough: packaging will need to achieve Grade A or B.
• From 1 January 2030, the empty space ratio in e-commerce, transport and grouped packaging must not exceed 50%. This targets oversized boxes filled with void-fill material.

One caveat worth keeping in mind: a substantial number of delegated and implementing acts are still outstanding, and the detailed design-for-recycling criteria have not been finalised. The dates and grades are set; some of the technical detail behind them is still being written. Build in headroom rather than designing to the minimum.

1. “Can you supply a full technical file?” You need detailed specifications, material breakdowns and weight data. Without them you cannot validate a Declaration of Conformity.
2. “Are your materials tested against the PPWR substance limits?” For food and wellness products in particular, ask for confirmation on PFAS and heavy metals.
3. “How does this design affect our empty space ratio?” Ask for dieline adjustments that contour to your product, so you stay well below the 50% threshold.
4. “Is the supply chain traceable and certified?” Chain-of-custody certification such as FSC® shows the paperboard comes from responsibly managed forests.
5. “Do you understand the difference between manufacturer and producer?” A supplier who follows the distinction will support your EPR reporting with accurate weight and material data instead of leaving you to work it out.

Who is responsible for the Declaration of Conformity?

Under the PPWR the declaration is drawn up by the manufacturer of the packaging, while the importer or brand placing it on the EU market must verify that it exists and retain a copy. Exactly where that responsibility sits in a given supply chain depends on how the packaging is purchased, branded and imported, so it is worth confirming with your own compliance advisers.

What we commit to is the part we control. For every order we can provide the underlying product data your documentation is built on: material composition and grammage, component breakdown and weights, dimensions and dieline specifications, and the FSC® chain-of-custody reference for the paperboard. If your compliance team needs a particular statement or format from us to complete your technical file, tell us what you need and we will work with you to supply it.

What is the PPWR empty space ratio rule?

From 2030, e-commerce, grouped and transport packaging may contain no more than 50% empty space. It is aimed at the practice of shipping small items in oversized boxes padded out with void fill. Right-sizing — for example a form-fitting cylinder tube around a bottle — is one of the more effective ways to manage it.

Are paper tubes affected by the PFAS limits?

Yes, where the tube is used as food-contact packaging. The limits that have applied since August 2026 are 25 ppb for any individual PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS, with total fluorine used as an initial screening measure.

Does ArtasPack produce square rigid boxes to match the tubes?

No. We specialise exclusively in cylindrical packaging. Our motto is “Paper Tube Manufacturer”, and all of our engineering and production capability goes into cardboard tubes and luxury rigid cylinder boxes.

Can ArtasPack guarantee that my brand is PPWR compliant?

No manufacturer can guarantee a brand’s compliance, because legal responsibility for market placement, EPR registration and final conformity sits with the brand or importer. What we can say is that ArtasPack products are designed to meet the requirements of the EU’s PPWR, and that we provide the material data, design support and documentation input you need to meet your own obligations.