PPWR Explained
What the EU Packaging and Packaging Waste Regulation means for packaging design
The EU Packaging and Packaging Waste Regulation (PPWR) introduces new requirements for packaging recyclability, waste reduction and circularity.
PPWR affects packaging decisions across the value chain, from design and procurement through to manufacturing and compliance. Understand what the regulation means for your packaging portfolio and how Sappi can help you prepare through compliant packaging solutions, technical expertise and the data needed to support your compliance journey.
Through active participation in industry initiatives and technical working groups, Sappi remains closely engaged with the evolving PPWR framework and its implementation requirements.
PPWR in 60 seconds
The Packaging and Packaging Waste Regulation (PPWR) will reshape how packaging is designed, manufactured, used and recycled in the European Union.
The Regulation generally applies from 12 August 2026. Over the coming years, the Regulation will continue to introduce requirements on packaging materials, recyclability, packaging reduction, reuse systems and compliance obligations across the value chain, with some detailed requirements to be confirmed through implementing and delegated acts.
PPWR milestones
Key PPWR milestones
| Obligation | Mandatory Compliance Timeline |
|---|---|
| Restriction on Substances of Concern & Declarations of Conformity | Aug 12 2026 |
| Mandatory labelling | 2028 |
| EPR fees modulated with recyclability performance | 2029 |
| Design for Recyclability criteria Mandatory recycled plastic content Packaging minimisation Bans on certain packaging uses Mandatory reuse targets | 2030 |
| Recycling at scale | 2035 |
| Higher recycled plastic targets/reuse targets | 2040 |
What PPWR means for packaging decision-makers
For brand owners
Rethink packaging at the design stage.
PPWR places increasing emphasis on designing packaging with its end-of-life destination in mind.
Key considerations include:
- Is the packaging compatible with existing recycling systems?
- Can complex material combinations be simplified?
- Are there opportunities to reduce packaging volume or weight?
- Will future recyclability requirements affect current packaging formats?
Packaging design decisions made today may influence future compliance and circularity performance.
For converters
Expect demand for redesign and substitution solutions
Converters face the challenge of balancing functionality, product protection and recyclability.
Areas likely to receive increased attention include:
- Material selection
- Barrier performance
- Design for Recycling criteria
- Packaging minimisation
- Documentation and compliance requirements
For retailers
Stronger responsibility across assortments and packaging waste
Retailers face growing pressure to reduce unnecessary packaging and improve packaging circularity across their supply chains.
Key focus areas include:
- Packaging optimisation
- Reduction of unnecessary packaging
- Recyclability performance
- Future reuse models
- Supplier collaboration
Understanding recyclability
Designing packaging for existing recycling systems
PPWR places strong emphasis on packaging that can be effectively collected, sorted and recycled.
For many packaging applications this may mean:
Simplifying material structures
- Reducing difficult-to-separate components
- Aligning packaging design with established recycling streams
- Considering recyclability from the earliest stages of development
Sappi actively participates in industry initiatives and technical working groups focused on recyclability, circularity and Design for Recycling. This engagement helps us stay close to evolving PPWR requirements and support customers with up-to-date technical guidance and compliance information.
How Sappi can support your PPWR journey
Preparing for PPWR requires balancing recyclability, performance, compliance and business objectives. Sappi works across the packaging value chain to help customers navigate these challenges.
Our fibre-based solutions can support mono-material packaging designs under PPWR, helping simplify packaging structures while maintaining the performance required for demanding applications.
Improve recyclability
- Paper-based packaging solutions compatible with conventional recycling processes
- Support for Design for Recycling considerations
- Technical expertise in recyclability assessments
Reduce packaging complexity
- Alternatives to complex material structures
- Opportunities for simplification and material optimisation
Increase renewable content
- Fibre-based solutions from renewable resources
- Certified woodfibre sourcing
Accelerate the transition to fibre-based packaging
Technical expertise to help evaluate and transition from fossil-based materials to paper-based packaging solutions while balancing performance, recyclability and compliance requirements.
PPWR-ready data
PPWR-ready data to support your obligations
Where we are a material supplier for packaging on the EU market, Sappi’s role is to provide the necessary information and documentation to support manufacturers in meeting the PPWR conformity obligations.
All required information will be made available in our products' Declaration of Compliance, providing a single, reliable source for information and technical documentation, helping simplify our customers' conformity assessment and reporting obligations.
Transport packaging
For the transport packaging used to ship our products, our current understanding is that Sappi should fulfill the role of manufacturer under PPWR.
We are preparing the required technical documentation and Declaration of Conformity in line with the Regulation. While the Declaration of Conformity is intended to be made available to competent authorities upon request rather than distributed to customers, Sappi can provide general information regarding its transport packaging and PPWR readiness.
Current PPWR compliance focus areas
In this first phase of PPWR implementation, the main compliance obligations relate to:
- Article 5(4): minimisation of substances of concern (heavy metals)
- Article 5(5): substances of concern in packaging (PFAS restrictions and analytical limits)
- Article 6: recyclability in accordance with EN 13430:2004 (requirements for packaging recoverable by material recycling)
Frequently asked questions
PPWR introduces recyclability requirements that will progressively apply to packaging placed on the EU market. By 2030, packaging will need to meet Design for Recycling criteria, with a recyclability performance grade between A and C. By 2035 packaging must also be recyclable at scale through established collection, sorting and recycling systems. From 2038, packaging should be at least grade B in order to be placed on the market.
Design for Recycling (DfR) criteria are used to assess the compatibility of a package design with collection, sorting and recycling.
Future DfR criteria will play an important role in determining recyclability performance grades under PPWR.
Paper-based packaging is generally well aligned with the Regulation's objective of increasing packaging circularity. Compliance ultimately depends on the complete packaging structure, including coatings, barriers, inks, adhesives and other packaging components.
However, all packaging formats will need to demonstrate compliance with applicable recyclability and other PPWR requirements.
Partner with us to create solutions for the future
At Sappi, we continually explore new possibilities for paper-based materials and packaging solutions. By working closely with customers across the value chain, we help turn packaging challenges into opportunities.
Get in touch to discuss how we can support your packaging goals.
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