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PPWR has been widely discussed lately, and important deadlines are approaching for companies across the packaging value chain. Although its impact on paper and carton packaging is more limited, it is still important to understand which requirements also affect paper-based packaging.
This article explores the key PPWR dates and requirements from the paper and carton perspective and was prepared in cooperation with Taavi Tikk from Pack-Craft.
Why PPWR also matters for paper and carton packaging
Let’s start with the official legal basis: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. It entered into force on 11 February 2025 and will apply step by step from 12 August 2026.
The main objective of the regulation is to prevent the generation of packaging waste by creating a unified set of requirements across the European Union, regulating the entire value chain and everything that happens during the life cycle of packaging. Through technical requirements, it specifies what types of packaging may be placed on the EU market in the future, encourages investment in innovative technologies by creating regulatory certainty, and increases the value of packaging waste by promoting its reuse. In short: A sustainable and competitive circular economy through harmonised requirements.
The PPWR is also linked to the goals outlined in the European Green Deal and the Circular Economy Action Plan, which aim for recyclable packaging by 2030. The Single Use Plastics Directive (SUPD) is also connected to the PPWR and complements/supports it. The PPWR covers all types of packaging. It primarily concerns plastic packaging but also partly applies to paper and carton packaging.
This is particularly relevant for packaging with polymer surface coatings or laminated polymer layers that may not fall within future recyclability classes (e.g., beverage cups, food containers and bowls, and other moisture- and grease-resistant bags and containers). Below is an overview of key deadlines affecting paper and carton packaging.
Key PPWR dates to keep in mind in 2026 and 2027:
labelling, PFAS, documentation and packaging minimisation
The first key PPWR requirements affecting paper and carton packaging include labelling, PFAS, documentation, packaging minimisation and empty space rules.
On 12.08.2026, harmonised labelling requirements will be introduced across the EU. These include principles for determining packaging material composition through labelling and address future digital labelling technologies.
On the same date, a ban on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging becomes highly significant. If PFAS content exceeds or equals the established limit value, such packaging may no longer be placed on the EU market. PFAS compounds have long been used in paper and carton packaging as moisture and grease barriers. There are alternatives available and you can read about them here: https://kroonpak.com/pfas-free-food-packaging-whats-all-the-fuss-about
In addition, manufacturers must prepare a Declaration of Conformity (DoC) for each packaging type and keep it available with technical documentation for 5 years after placing single-use packaging on the market and for 10 years after placing reusable packaging on the market. The PPWR adds certain documentation management obligations mainly for packers rather than packaging material manufacturers.
On 12.02.2027, a standard for establishing a methodology for calculating packaging minimisation will be introduced. It is expected to define maximum appropriate mass and volume limits and, where possible, wall thickness and maximum empty space.
Key PPWR dates in 2028:
recyclability classes, reuse in HORECA and empty space requirements
01.01.2028 will be one of the most important PPWR milestones. Structural design criteria for recyclability will be introduced for different packaging materials, including paper and carton. Recyclability will be defined by classes A, B, and C, which will be used to assess whether packaging is suitable for being placed on the market. These classes correspond to recyclability rates of 90%, 80%, and 70%, respectively.
By 12.02.2028, distributors operating in the HORECA sector, who provide takeaway cold or hot drinks or ready-made food within a Member State must offer consumers the option to receive these products in reusable packaging that is a part of a deposit-return system. From 2030 onward, final distributors will aim to offer 10% of their sold products in reusable packaging. This is not an overly strict requirement, as the official wording says “aim,” but nevertheless steps toward implementation will need to be taken.
By 12.02.2028, a methodology for calculating the empty space ratio will be established. Companies filling sales packaging must ensure that empty space is reduced to the minimum necessary for essential functionality and product protection. Air or protective gases inside the packaging that are needed to protect food or other products are not considered empty space.
From 12.08.2028, all packaging placed on the EU market must carry a harmonised label containing information about the material composition of the packaging. The label must be pictogram-based and easy to understand. This requirement does not apply to transport packaging or packaging included in a deposit-return system.
Key PPWR dates from 2029 onwards:
recyclability performance grades and future marketability requirements
From 12.02.2029, all reusable packaging must bear a label informing users of its reusability. The label may be a QR code or another approved digital solution. In addition, reusable sales packaging must be clearly identifiable and distinguishable from single-use packaging at the point of sale.
By 01.01.2030, companies filling grouped, transport, or e-commerce packaging must ensure that the empty space ratio inside the packaging does not exceed 50%. This refers specifically to empty space inside the packaging, not to minimising packaging materials.
From 01.01.2030, all packaging placed on the EU market must be designed so that its mass and volume are reduced to the minimum necessary to ensure functionality, taking into account the packaging shape and material. This concerns minimising the packaging itself, not just empty space inside it.
Most important point:
From 01.01.2030, packaging that does not fall within the recyclability performance classes A, B, or C may not be placed on the EU market. From 01.01.2038, only packaging with a recycling class A and B may be placed on the market. Innovative packaging will receive a five-year grace period, although the definition and criteria for innovative packaging are not yet known.
After these dates, nothing fundamentally new will be introduced – only stricter versions of the same requirements.
Summary and references
As noted above, paper and carton packaging is not subject to a minimum recycled content requirement. Instead, it is regulated mainly through recyclability requirements (A, B, C), limits on empty space, packaging material minimisation, the PFAS ban, labelling requirements, and in some cases additional reuse obligations.
Companies must also strive to reduce the greenhouse gas emissions associated with their activities by thoroughly mapping the full life cycle of their packaging and products and systematically reducing their impact.
Helpful links and references
- PPWR – overview
https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en - PPWR – official document
https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng - The European Green Deal – overview
https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal_en - The European Green Deal – official document
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52019DC0640 - First circular economy action plan – overview
https://environment.ec.europa.eu/topics/circular-economy-topics/first-circular-economy-action-plan_en - First circular economy action plan – official document
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52020DC0098
Stay informed with us
PPWR will introduce important changes over the coming years, also for paper and carton packaging. We are following these developments closely and will continue to cover relevant updates and practical topics here on the blog. Kroonpak supports customers with food-safe and sustainable packaging solutions as well as the necessary product documentation, including Declarations of Conformity (DoC) where applicable.
If you need help with packaging documentation, Declarations of Conformity or choosing suitable packaging solutions in light of PPWR, feel free to contact us here.
