Packaging Regulation (PPWR): What do you need to know?
The European Union Packaging and Packaging Waste Regulation (PPWR) is a directly applicable EU legal act aimed at reducing packaging waste, using resources more efficiently, strengthening the circular economy, and ensuring that packaging placed on the EU market is safe and meets specified recyclability requirements.
Although the regulation officially entered into force on February 11, 2025, most of its requirements will start to apply on August 12, 2026. Additional requirements and transitional deadlines will come into effect in subsequent years.
The regulation applies to all packaging materials; however, specific technical and legal requirements are imposed on cardboard and corrugated cardboard packaging, which must be ensured by the packaging manufacturer.
1. Material Safety and Restriction of Chemical Substances
Cardboard and corrugated cardboard packaging are subject to strict material safety requirements.
PFAS restriction in food contact packaging. In packaging that comes into direct contact with food, the concentration of PFAS (per- and polyfluoroalkyl substances) cannot exceed the limit values set by the PPWR.
Restriction of heavy metals. The sum of Pb, Cd, Hg, and Cr(VI) levels cannot exceed 100 mg/kg (100 ppm).
2. Recyclability Requirements
The PPWR mandates that packaging must be designed in a way that allows it to be efficiently recycled on an industrial scale.
When designing cardboard and corrugated cardboard packaging, it is important that its structure, as well as the glues, inks, varnishes, plastics, and other materials used, do not unreasonably hinder the recycling of the main material.
Compliance with recyclability requirements is evaluated according to the criteria established by the PPWR and the applicable technical documentation. Relevant European standards and technical specifications, such as EN 13430:2004, may also be used for the evaluation when appropriate for the specific assessment.
3. Optimization of Packaging Weight and Volume
The PPWR requires that packaging weight and volume be no greater than necessary to protect, transport, and deliver the product to the consumer.
The goals when designing packaging are to:
- use only as much material as necessary for product protection;
- avoid excessive structural elements;
- optimize packaging dimensions for logistics and warehousing.
For certain packaging categories, including e-commerce and transport packaging, the PPWR establishes additional requirements regarding the reduction of excessive empty space. However, in cases where a larger packaging format is necessary to protect the product, the regulation provides for exemptions.
Responsibility for selecting the packaging design and dimensions depends on who designs the packaging. If the packaging is manufactured according to the structure, dimensions, or other design specifications provided by the customer, the customer is responsible for selecting these parameters. When MAZUS designs the packaging based on a product or design task provided by the client, the PPWR packaging minimization requirements are taken into account during the design process.
4. Declaration of Conformity (DoC)
Under the PPWR, before placing packaging on the EU market, the manufacturer must perform a conformity assessment and draw up technical documentation. Once compliance with the applicable PPWR requirements is demonstrated, an EU Declaration of Conformity (DoC) is prepared.
The declaration must clearly identify the specific packaging or group / family of packaging to which the declaration applies, ensuring its traceability.
The Declaration of Conformity is based on technical documentation that stores information about the packaging design, materials used, and other documents substantiating its compliance.
MAZUS Commitment
MAZUS issues PPWR declarations of conformity to its customers for packaging for which we have sufficient technical information and documentation substantiating PPWR compliance from raw material and component suppliers.
Suppliers' technical documentation is collected for the raw materials and components we use, and specific packaging data and information supporting its compliance are stored in the MAZUS technical documentation.
If packaging was legally placed on the European Union market before the start of the applicable PPWR requirements, it does not need to be disposed of or replaced simply due to the PPWR requirements applied later. Therefore, packaging previously purchased from MAZUS that has already been placed on the EU market can continue to be used and distributed in accordance with the transitional provisions applicable to it.
It is important to understand that the application of the PPWR transitional provisions is determined by the date the packaging was placed on the EU market, rather than solely by the date of its manufacture or use. The application deadlines for individual PPWR requirements vary, so the compliance of a specific packaging product must be evaluated according to the requirements applicable to it at that time.
If you have any doubts regarding a specific MAZUS packaging product, please contact our specialists – we will help assess the situation and the available documentation.
Generally, no.
If packaging was legally placed on the European Union market before the start of the applicable PPWR requirements, there is no need to retroactively prepare a new PPWR Declaration of Conformity (DoC) simply due to the new PPWR requirements.
Such packaging can continue to be used and distributed in accordance with the transitional provisions applicable to it.
However, your customers or trading partners may request additional information regarding the composition, materials used, or compliance of the packaging. Such requests may arise from their internal quality or supplier assessment procedures.
If you purchased packaging from MAZUS and require additional technical information, please contact our specialists. We will evaluate the specific packaging and our available technical documentation.
Yes. MAZUS issues PPWR declarations of conformity for packaging for which we have all the required technical information and documentation substantiating PPWR compliance from raw material and component suppliers.
The declaration identifies the specific packaging or packaging family and provides information regarding its material composition and compliance with applicable PPWR requirements.
If you or your trading partners require a PPWR Declaration of Conformity for a specific MAZUS packaging product, please contact our team.
Recycled content indicates what portion of the packaging material is made using recycled raw materials. For example, if a corrugated board manufacturer states that their supplied raw material contains 80% recycled fiber, we can use this information when evaluating the composition of packaging made from this material.
MAZUS does not determine the recycled content at its own discretion – in our declarations, we use data provided by raw material and component suppliers, backed by technical documentation.
Important: recycled content and packaging recyclability are two different things.
No.
80% recycled fiber means that the raw material contains 80% recycled material. It does not indicate what portion of the final packaging can be recycled.
Packaging recyclability depends on its design and all materials and components used – for example, paperboard, corrugated board, paper, plastic, adhesives, coatings, metal, or textiles.
Therefore, a high recycled content does not automatically imply the same recyclability rate for the packaging. The PPWR also regulates these concepts separately – recyclability in Article 6, and minimum recycled plastic content in Article 7. (EUR-Lex)
This depends on the specific packaging and the technical documentation available to MAZUS.
A PPWR declaration of conformity must be based on data proving that the packaging complies with applicable requirements. Therefore, the mere fact that packaging was previously manufactured by MAZUS does not automatically mean that we can issue a PPWR declaration for it.
If we have sufficient data regarding the packaging design, raw materials, and components used, as well as supplier documentation supporting their compliance, we can evaluate the possibility of preparing a declaration.
A PPWR declaration of conformity is not just an informational document – it must be supported by technical documentation.
MAZUS must have information regarding the specific packaging design, material composition, and the raw materials and components used in its production. Part of the required information is obtained from our suppliers of raw materials and components.
Therefore, if we do not yet have all the necessary supplier documents or technical data, we first collect and evaluate them before we can prepare the PPWR declaration of conformity.
The PPWR requires that before placing packaging on the market, the manufacturer must perform a conformity assessment and draw up technical documentation, and upon demonstrating compliance, issue an EU declaration of conformity. (EUR-Lex)
Not every change automatically means that a new declaration is needed, but it must be assessed whether the modification could affect the packaging's compliance with the PPWR.
This is particularly relevant if the following change:
- packaging design;
- main raw material;
- material composition;
- use of plastic, metal, textile, or other components;
- other characteristics on which the previous compliance was based.
If the change can affect the packaging's compliance, MAZUS performs a re-assessment and updates the PPWR declaration when necessary.
The PPWR directly requires the manufacturer to take into account changes in packaging design or characteristics and, if they may affect compliance, carry out a re-assessment of conformity. (EUR-Lex)
The PPWR does not establish a simple principle that a declaration is valid for, for example, one or two years.
The declaration must be kept continuously up to date and updated if the packaging, its characteristics relevant to compliance, or other circumstances on which the declaration was based change. Article 39 of the PPWR lays down that the EU declaration of conformity shall be continuously updated. (EUR-Lex)
It is important not to confuse the validity of the declaration with the document retention period. The manufacturer must keep the technical documentation and the EU declaration of conformity for single-use packaging for 5 years after the packaging has been placed on the market, and for reusable packaging – for 10 years. (EUR-Lex)
Yes, provided that all packaging covered by the declaration can be clearly identified and their characteristics relevant to PPWR compliance are properly assessed.
For example, packaging of the same construction, dimensions, and material composition may be produced with several different print designs. Such products can be grouped into a single declaration if they are clearly identified in the declaration and their traceability is ensured.
If a specific design alters not only the graphics but also the packaging materials, coatings, or other properties relevant to PPWR compliance, an additional assessment must be performed.
Not necessarily.
If only the graphic design changes, while the packaging construction, dimensions, raw materials, components, and other characteristics relevant to PPWR compliance remain the same, a change in print design alone does not necessarily require a new declaration.
However, if the inks, varnishes, laminates, foils, plastic elements, or other packaging properties change along with the design, it must be evaluated whether this modification could affect PPWR compliance.
We recommend keeping it.
The PPWR declaration of conformity issued by MAZUS is part of the documentation supporting packaging compliance and traceability. It may be required for your internal quality system, customers, trade partners, or other parties in the supply chain.
The PPWR establishes specific obligations for manufacturers to store declarations and technical documentation, as well as certain document availability duties for other economic operators. MAZUS stores its documents as a manufacturer in accordance with the timeframes specified by the PPWR.
Therefore, we practically recommend that the customer save the declaration received from MAZUS together with the documentation for the specific packaging or supplier.