The European Union’s new Packaging and Packaging Waste Regulation (PPWR) has entered a major implementation stage.
Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026, replacing the previous EU packaging framework with a directly applicable regulation across EU Member States.
For brands, importers and packaging buyers selling products in Europe, this represents more than another regulatory update. It signals a long-term change in how packaging should be designed, sourced and evaluated.
For buyers of paper boxes, folding cartons, rigid boxes and other paper-based packaging, the key question is therefore:
How should packaging purchasing decisions change under the PPWR?
1. Recyclability Is Becoming a Packaging Design Requirement
One of the central objectives of the PPWR is to make packaging placed on the EU market recyclable.
The regulation introduces a recyclability framework under which packaging will eventually be assessed according to recyclability performance grades. From 2030, packaging will generally need to meet the required recyclability criteria to remain on the EU market, subject to the detailed implementation timeline and delegated rules.
For paper packaging buyers, this means recyclability should increasingly be considered during packaging development rather than after the box has already been designed.
A paper box may look recyclable because its main material is paperboard, but its complete construction matters.
For example, buyers may need to pay greater attention to:
- Plastic windows and laminated films
- Plastic or foam inserts
- Magnets and other non-paper components
- Adhesives and coatings
- Metallized decorative materials
- Complex multi-material structures
- Components that are difficult to separate during recycling
The direction of travel is clear: simpler, easier-to-separate packaging structures are likely to become increasingly valuable.
2. “Paper Packaging” Does Not Automatically Mean “Compliant”
Switching from plastic packaging to paper packaging can support sustainability goals, but simply using paper does not automatically make a package compliant with the PPWR.
The regulation looks at packaging as a complete system.
A rigid gift box, for example, may contain greyboard, coated paper, adhesive, magnets, ribbons, plastic trays and decorative finishes.
Each component can potentially influence how easily the finished packaging can be collected, sorted and recycled.
This creates an important change in the relationship between packaging buyers and suppliers.
Instead of asking only:
“Can you make this box from paper?”
buyers should increasingly ask:
“Can this packaging structure be designed for recycling?”
That difference may influence material selection, structural engineering and finishing choices throughout the packaging development process.
3. Less Packaging and Less Empty Space Will Matter
Another important direction of the PPWR is packaging minimisation.
The EU wants businesses to reduce unnecessary packaging material and excessive empty space. The goal is not simply to replace one packaging material with another, but to reduce packaging waste overall.
For buyers, this may encourage more efficient structural design.
Oversized luxury boxes, unnecessary secondary layers and packaging designed primarily to create additional volume may face increasing scrutiny.
This does not mean premium packaging will disappear.
Instead, premium packaging design may gradually move toward material efficiency.
A well-designed box can still provide excellent product protection and a premium unboxing experience while using less material.
For example, packaging engineers can optimise:
- Box dimensions according to the actual product size
- Paperboard thickness
- Insert structures
- Shipping efficiency
- Material combinations
- Structural strength with lower material consumption
In the coming years, “premium” may increasingly mean better engineering rather than simply more material.
4. Paper-Based Inserts Could Become More Attractive
Many packaging projects currently use EVA foam, EPE foam, plastic trays or thermoformed inserts because they provide excellent product protection.
Under a regulatory environment focused increasingly on recyclability and material separation, however, buyers may want to reconsider whether these materials are necessary for every project.
Paper-based alternatives can sometimes provide similar functions.
Examples include:
Die-cut paperboard inserts Suitable for cosmetics, electronics, bottles and many lightweight products.
Corrugated inserts Useful when additional cushioning or structural strength is required.
Moulded fibre inserts Increasingly popular for products that require protection while maintaining a predominantly fibre-based packaging system.
The objective should not necessarily be to eliminate every non-paper component.
Instead, buyers should evaluate whether a simpler material combination can achieve the same packaging performance.
5. Decorative Finishes Need More Careful Consideration
For premium paper packaging, visual appearance remains extremely important.
Hot foil stamping, embossing, debossing, spot UV, specialty coatings, lamination and other finishing processes are widely used to create differentiation.
The PPWR does not simply mean that brands must stop using premium finishing.
However, packaging buyers should increasingly evaluate how decorative elements affect the recyclability of the complete package.
A practical approach is to ask suppliers during the design stage:
Can we achieve a similar visual result with fewer materials or a recycling-friendly construction?
For example, instead of relying heavily on plastic film or complex multi-material decoration, a brand may consider greater use of structural design, embossing, carefully selected paper textures or reduced-area decorative effects.
Sustainability and premium appearance do not necessarily have to conflict.
6. Food Packaging Buyers Should Pay Particular Attention to PFAS
The PPWR also introduces restrictions concerning certain substances of concern.
One important area highlighted by the new rules is PFAS in food-contact packaging. These substances have sometimes been used to provide grease, oil or moisture resistance.
For businesses purchasing paper packaging for food, bakery products, confectionery, takeaway products or other food-contact applications, material specifications will therefore become increasingly important.
Buyers should communicate the intended application clearly to their packaging suppliers and confirm whether relevant coatings, inks and materials are appropriate for food-contact use and applicable regulatory requirements.
Documentation and material traceability will become increasingly important parts of packaging procurement.
7. Packaging Buyers Should Start Building Better Material Documentation
Under the new regulatory environment, packaging purchasing will increasingly involve more than approving artwork and confirming dimensions.
Brands and importers may need clearer information about what their packaging actually contains.
For new packaging projects, buyers should consider maintaining documentation covering:
- Main packaging material
- Paper or paperboard specifications
- Coatings and laminations
- Printing inks
- Adhesives
- Inserts
- Plastic components
- Decorative components
- Material weights where required
- Supplier declarations or supporting documentation
This information can make future compliance assessments significantly easier.
For international buyers sourcing packaging from outside the EU, communication with manufacturers will therefore become increasingly important.
8. Do Not Wait Until 2030 to Redesign Packaging
Some of the PPWR’s major recyclability requirements will become more important toward 2030 and beyond.
However, packaging development takes time.
Brands may use the same packaging design for several years, while changing box structures, suppliers, production tooling and filling processes can require significant investment.
The European Commission is also continuing to develop detailed technical criteria and implementing measures under the regulation.
For this reason, companies selling products in Europe should not view 2030 as the year to start thinking about recyclable packaging.
It should be viewed as a deadline that businesses need to prepare for well in advance.
Packaging projects developed in 2026, 2027 and 2028 should already consider the direction of future requirements.
What Should Paper Packaging Buyers Do Now?
For brands and importers sourcing paper packaging, there are several practical steps worth taking today.
Review existing packaging structures. Identify unnecessary plastic components, oversized packaging and difficult-to-separate materials.
Discuss recyclability during packaging development. Do not wait until production is complete to evaluate whether a structure is suitable for recycling.
Consider paper-based alternatives. Where technically appropriate, paperboard, corrugated board and moulded fibre can replace certain plastic or foam components.
Reduce unnecessary packaging. Optimising dimensions and structural design can reduce material consumption while also lowering shipping volume.
Request better material information from suppliers. Clear specifications can support internal compliance reviews and future regulatory requirements.
Follow upcoming PPWR implementation rules. Some technical requirements will continue to be clarified through delegated and implementing acts, so packaging specifications should remain adaptable.
PPWR Is Changing the Role of Packaging Suppliers
Perhaps the biggest long-term change created by the PPWR is that packaging suppliers will increasingly need to become more than manufacturers.
Traditionally, a buyer could send a box design to a factory and ask the supplier to reproduce it.
Going forward, packaging development may require much closer cooperation between brands, designers, packaging engineers and manufacturers.
Questions such as these will become increasingly common:
Can we remove this plastic component?
Can this insert be made from paper instead?
Can the box use less material without losing strength?
Can the packaging be separated easily after use?
Can we achieve the same premium appearance with a simpler material structure?
For packaging buyers, asking these questions early can reduce the cost and complexity of redesigning packaging later.
Final Thoughts
The PPWR represents a significant change in European packaging policy.
For paper packaging buyers, however, it should not be viewed only as a compliance challenge.
It is also an opportunity to rethink packaging.
The next generation of paper packaging will need to balance product protection, branding, cost, material efficiency and recyclability.
Paper and fibre-based packaging are well positioned for this transition, but material choice alone is not enough. Structural design, coatings, inserts, decorative elements and the overall packaging system all matter.
For brands selling into the European market, the best strategy is therefore simple:
Design for recyclability from the beginning, rather than trying to make packaging recyclable afterwards.
As the PPWR moves through its implementation timeline, buyers who begin adapting their packaging specifications today will be better prepared for the increasingly strict requirements expected toward 2030 and beyond.