You have likely heard of the Packaging and Packaging Waste Regulation (PPWR). The regulation aims to promote the widespread use of sustainable packaging through stricter legal requirements. At the same time, it aims to address the environmental impact of packaging waste. In this article, Tedpack will break down the key legal requirements of the PPWR. Our goal is to help you clearly understand the specific impact of the PPWR on your business.
What is PPWR?
PPWR is a unified regulatory system established by the European Union for packaging and packaging waste. The core purpose of this regulation is to promote greater standardization throughout the entire process of packaging, from design and production to use and recycling. At the same time, the regulation also aims to improve the recyclability, resource efficiency, and environmental performance of packaging.
- Packaging needs to meet more specific recyclability and Design for Recycling requirements.
- Plastic packaging needs to meet certain recycled material content requirements.
- Packaging reduction; reduce unnecessary packaging materials.
- Strengthen control over substances such as PFAS.
The PPWR’s impact extends beyond the packaging itself. The regulation encompasses a wide range of aspects, including packaging structure, printing, adhesives, accessories, transport packaging, recycling strategies, registration processes, and accompanying product documentation. It can be said that PPWR is a regulatory system that runs through the entire life cycle of packaging and supply chain management.
For brands, PPWR means that regulatory requirements must be taken into account as an indispensable part of making packaging decisions. In the future, environmentally friendly packaging will become the ticket for products to enter the European market.
Packaging and Packaging Waste Regulation 2025/40 (PPWR)
EU PPWR Timeline and Implementation Schedule
As of the date of this article’s publication (August 12, 2026), the PPWR has officially entered the phase of practical application. According to the regulation’s timeline, the rating standards will be further refined by 2028. By 2030, the regulation will formally implement recyclability grade thresholds, at which time packaging recyclability performance must reach at least Grade C. By 2035, the regulatory focus will expand from design-for-recycling to include large-scale actual recycling. 2038 is a critical year, when the minimum recyclability level will rise from C to B.
Grades A, B, and C represent the recyclability levels of the packaging. These grades reflect the proportion of materials in the packaging that can be effectively recycled in accordance with regulations.
- Grade A: ≥95%
- Grade B: ≥80%
- Grade C: ≥70%
How Does PPWR Affect Packaging?
The PPWR regulation will significantly impact the flexible packaging industry. The core challenge is that flexible packaging must be upgraded to a format that balances performance, recyclability, and compliance. For businesses, the future is not just about converting structures into a mono-material. They must also re-evaluate their entire packaging systems across multiple dimensions—including materials, structures, components, recycled content, food-contact safety, and technical documentation.
- Adjustments to material structures are required. Traditional multilayer composite structures such as PET/PE and PET/AL/PE have advantages in barrier properties and strength. However, the requirement for recyclable design is driving a gradual shift toward structures that are more conducive to recycling, such as Mono-PE and Mono-PP.
- Recyclability has become a core design consideration.In the future, we should focus not only on the main film of the bag, but also on components such as the barrier layer, ink, adhesive, zipper, nozzle, and cap, as these components will affect overall recycling performance.
- Recyclability ratings directly affect market access. Starting in 2030, packaging must achieve a minimum rating of Grade C. From 2038 onwards, this threshold will rise to Grade B. Flexible packaging structures require advance assessment and appropriate adjustment.
- The proportion of PCR (Post-Consumer Recycled) materials used will continue to rise.Some packaging types will gradually be required to add a certain proportion of recycled materials. Brands need to assess PCR’s impact on heat seal strength, mechanical properties, appearance, and food-contact safety.
- Food-contact packaging faces stricter regulatory controls.The regulations on restricted substances such as PFAS will place higher demands on the selection and testing of components such as films, inks, adhesives, zippers, and nozzles.
- Requirements for documentation and supply chain management are intensifying.Packaging companies must systematically prepare material specifications, test reports, technical documentation, declarations of conformity, and batch traceability data to facilitate the compliance processes of brand owners and importers.
The PPWR aims to drive the upgrading of the entire flexible packaging ecosystem. In the future, flexible packaging companies will need to find a better balance between product performance and recyclability, resource utilization efficiency, and compliance.
How to Prepare for PPWR: Start with Packaging
Earlier, we provided a brief overview of the regulations, but they still seem quite complex overall. Therefore, it might be helpful to start with the packaging itself—this could make things much clearer.
For Tedpack, PPWR does not require developing an entirely new packaging solution from scratch. A more practical approach is to analyze existing packaging structures against regulatory requirements item by item. By analyzing the data in this way, we can determine which structures are close to future packaging needs and which structures still need further optimization.
PPWR Recyclability Requirements for Flexible Packaging
In addition to the materials used for the bag body, factors such as barrier layers, inks, and adhesives also affect the final recyclability of packaging. Therefore, material structures primarily composed of mono-PE and mono-PP will become a key development direction in the flexible packaging industry.
For brands, a more reasonable approach is not to simply replace the existing packaging structure with Mono-PE or Mono-PP. The key is that brands need to assess whether the existing structure really needs to be adjusted, and whether the original packaging performance level can still be maintained after the adjustment.
PPWR Recycled Content Requirements for Flexible Packaging
The regulations mention the requirements for the use of PCR materials. When many brands first read the regulations, they often interpret them as requiring a certain proportion of PCR materials in the packaging. However, the actual selection process involves much more than this. You need to clearly determine what type of product it is, what PCR ratio is required, and whether the material is suitable for the current product. For Tedpack, PCR is a type of material choice for packaging, rather than a separate bag type.
PFAS Requirements for Food-Contact Packaging Under PPWR
For food-contact packaging, recyclability is not the only consideration; compliance with restrictions on substances such as PFAS is also mandatory.
Depending on the packaging structure and intended use, supporting documentation may include test reports or declarations regarding PFAS or total fluorine content, applicable Declarations of Compliance (DoC) for food contact, and evidence of migration compliance.
The scope of assessment covers the main body of the packaging and extends to relevant components such as zippers, spouts, caps, valves, inks, and adhesives.
Food packaging requires a balance between product protection, food-contact safety, and design for recyclability.
Liquid and Functional Packaging Requirements
For liquid and functional packaging, this type of packaging usually includes not only the bag body, but also accessories such as spouts, valves, and caps. Therefore, for this type of packaging, four aspects need to be considered simultaneously:
- Main material
- Functional components
- Material compatibility
- Related supporting documents
This is somewhat similar to the requirements for food packaging. That is, within the framework of PPWR, the evaluation dimensions of the packaging have shifted from merely the bag itself to a comprehensive assessment of the entire packaging system.
PPWR Does Not Mean a One-Size-Fits-All Approach
Although the PPWR has entered the first phase of implementation, this does not mean that traditional multilayer composite packaging must immediately be withdrawn from the market. For brands and manufacturers, the more important approach is to first verify whether existing structures meet current requirements regarding materials, testing, and documentation, and then re-evaluate recyclability based on future timelines.
The overall approach can be summarized as follows: first, confirm the current situation, look to the future, evaluate and upgrade the portfolio, verify the packaging performance, and then make corresponding adjustments according to the timeline.
Tedpack’s PPWR Solutions
The PPWR is a regulation that gradually increases packaging requirements, rather than requiring all flexible packaging to adopt the exact same structure. Different products have different packaging needs. Therefore, Tedpack will provide a more targeted solution, with the basic path being: confirm the existing packaging structure, confirm whether the existing packaging meets the requirements, assess the recyclability and PCR gap by 2030, and finally determine the packaging adjustment plan.
We aim to help our clients answer more than just one question—”Does this packaging conform to PPWR?”—but a more systematic set of questions: “Where is this packaging currently positioned? What’s the next step? And when do adjustments need to be made?”
PPWR Documentation Requirements
PPWR’s documentation requirements for flexible packaging projects can generally be categorized into the following five types: DoC, Technical Documentation, Supplier Declarations, Test Reports, and Packaging Specifications & Traceability Records.
PPWR Declaration of Conformity (DoC)
The EU Declaration of Conformity (DoC) is a document used to declare the applicable PPWR requirements for packaging. This document is used to declare the PPWR requirements applicable to the packaging and must be completed before the packaging is placed on the market. The main uses of a DoC include filing by importers, customer verification, and regulatory review.
PPWR Technical Documentation
This document forms the core of the PPWR file system. It includes packaging descriptions, technical drawings, Bill of Materials (BOM), specifications, risk analyses, packaging weight reduction assessments, recyclability evaluations, and relevant test reports and compliance certifications.
PPWR Supplier Declarations
This declaration provides basic compliance information on raw materials and components—such as material composition, the proportion of recycled materials, REACH/SVHC status, heavy metals, and PFAS. It acts as a foundational document that supports technical documentation and subsequent compliance assessments.
PPWR Compliance Test Reports
The test report is prepared based on the packaging structure, application, and risk profile, providing corresponding testing documentation. Commonly included are evaluations for Heavy Metals, PFAS restrictions, PCR material content, and other supporting tests—all serving to demonstrate that the packaging complies with applicable regulatory requirements.
PPWR Packaging Specifications & Traceability Records
This document includes packaging drawings, material specifications, the Bill of Materials (BOM), packaging weights, labeling information, and a revision history. This information needs to be consistent with the actual mass-produced packaging. The document should also be updated whenever there are changes to materials, suppliers, or the packaging structure.
A Practical PPWR Compliance Pathway for EU Market Entry
Preparing the required documentation is only one part of the process. For products entering the EU market, compliance needs to be checked at different stages—from packaging confirmation and customs clearance to final market placement.
1. Before Import
Before shipment, the first step is to confirm the product application, destination market, food-contact conditions, and the roles of the relevant EU economic operators.
TedPack will then confirm the packaging specification, including the material structure, components, weight, and batch identification.
The available compliance evidence should also be reviewed. For food-contact applications, applicable PFAS-related information, Food Contact Declarations of Compliance (DoCs), and migration test documentation should be checked against the intended use.
The goal at this stage is to complete an approved packaging specification and the applicable compliance file before import.
2. During Customs Clearance
During customs clearance, the shipment records should match the actual goods.
This includes the invoice, packing list, product code, batch information, and manufacturer and importer identification, while ensuring that the applicable compliance documentation can be readily accessed.
If customs or other regulatory authorities request supporting evidence, the importer or customs broker should be able to provide the relevant documents and resolve any discrepancies before the goods are released.
3. Before Market Placement
Before the packaged product is placed on the market, the responsible economic operator should confirm any applicable EPR requirements, verify that the packaging remains suitable for its actual use, and approve the required labelling and traceability information.
Any outstanding compliance issues should be resolved before internal release, with the relevant records retained for future verification.
In simple terms, the pathway can be summarized as:
Approved Packaging & Compliance File → Matched Shipment & Traceability → Market-Ready Packaging
How Tedpack Will Help You Prepare for PPWR
After reading through the article, you may still feel unsure about what the requirements mean for your packaging. Don’t worry — our team can provide a more efficient and practical approach to help you prepare for PPWR.
For flexible packaging, the main focus is on packaging structure, PCR, material reduction, performance validation, and compliance evidence.
Recyclability Redesign for PPWR
For packaging that needs improved recycling compatibility, TedPack provides Mono-PE, Mono-PP, and high-barrier mono-material structures.
For Mono-PE, available structures can include MDO-PE/PE and PE/EVOH-PE, with PE-compatible zippers or spouts where technically feasible. For Mono-PP, options can include OPP/CPP and high-barrier CPP, suitable for applications with different requirements for transparency, stiffness, or heat resistance.
For high-barrier applications, EVOH or barrier coatings can be used to balance shelf-life requirements with recyclability goals.
Beyond structural changes, the packaging also needs further validation of its barrier performance, sealing performance, and actual filling performance, ensuring that the new structure can still deliver the performance required from the original packaging.
PCR Materials for PPWR Packaging
For projects involving recycled materials, PCR-PE laminated film structures are one of our key development areas.
In selected laminated structures, a PCR-PE layer can be introduced according to product application, food-contact requirements, and performance validation. The printing layer, barrier layer, and PCR-PE layer can then be optimized around four key areas: barrier performance, sealing performance, filling performance, and shelf life.
At the same time, TedPack evaluates the food-contact suitability of PCR materials, material-source traceability, and potential performance impacts, while providing corresponding PCR content documentation and traceability records.
Packaging Reduction for PPWR Compliance
In addition to material transition, reducing the amount of material used in packaging is also a key area of optimization for TedPack.
Through downgauging and layer optimization, we can reduce virgin-material use and overall packaging weight while maintaining packaging performance. The results can then be verified through packaging structure specifications and performance records.
Looking Beyond the Pouch: Evaluating the Complete Packaging BOM for PPWR Compliance
Packaging assessment should not focus only on the pouch that directly contains the product.
A complete packaging system also includes secondary packaging, transport packaging, and functional components attached to or integrated into the package. For this reason, TedPack evaluates projects from a Packaging BOM perspective, taking different packaging levels and functional components into account.
This includes:
- Primary Packaging: pouches, spout pouches, sachets, rollstock, and bag-in-box inner bags;
- Secondary Packaging: cartons, display boxes, dividers, and shrink-group packaging;
- Transport Packaging: outer cartons, pallets, stretch film, straps, edge protectors, and protective bags;
- Functional Components: zippers, spouts, caps, valves, labels, adhesives, tapes, and handles.
TedPack focuses on reviewing the complete Packaging BOM material by material, component by component, and packaging level by packaging level.
Each part is assessed according to its material, function, application, and supporting documentation.
For example, even seemingly minor transport packaging can contain several separate elements.A shipping carton may include corrugated board, printing ink, and adhesive, while a shipping label may include label paper, ink, and adhesive. The same principle applies to sealing tape and other ancillary packaging materials: the actual material construction should be matched with the applicable supporting evidence.
For transport packaging, TedPack can provide supporting four-heavy-metal test reports for sealing tape, outer cartons, edge protectors, wooden pallets, PE inner liner film, shipping marks/carton labels, stretch wrap film, and PP straps, helping ensure that smaller packaging elements are not overlooked.
For TedPack, this means reviewing the packaging as one complete system:
Complete Packaging BOM → Material by Material → Component by Component → Packaging Level by Packaging Level → Applicable Evidence
Advancing Materials, Testing, and Documentation for PPWR Compliance
Every packaging adjustment should be supported by evidence that corresponds to the actual product being supplied.
Depending on the packaging structure and application, TedPack can provide supporting documentation such as Heavy Metal Test Reports, PFAS Test Reports, Technical Specifications, PCR Material Certificates, and relevant traceability records.
- For the pouch itself, the product-specific technical specification can cover material layers and thicknesses, inks, adhesives, accessory materials and models, intended use, and applicable test standards.
- Product / purchase order (PO) identification and batch traceability records can also be maintained to connect the technical documentation with the packaging actually delivered.
- For food-contact packaging, TedPack can provide PFAS-related evidence, applicable Food Contact Declarations of Compliance (DoCs), and migration compliance documentation.
- For recyclable structures, we combine mono-material redesign with barrier, sealing, and processing-performance validation.
- For PCR-containing packaging, supporting evidence can include PCR content documentation, material traceability records, and food-contact suitability assessments.
Our goal is to keep packaging structure, performance validation, testing, and documentation closely connected throughout the project:
Current Structure → Performance Validation → Test Evidence → Technical Documentation → Traceability
Preparing Different Packaging Solutions for Different PPWR Stages
TedPack does not view packaging transition as a one-time material replacement. A more practical approach is to prepare different packaging solutions according to the regulatory timeline, product requirements, and the maturity of available recycling routes.
During 2026–2029, existing high-performance structures such as PET/PE, PET/NY/PE, PET/AL/NY/PE, and PET/AL/NY/RCPP can continue to be evaluated according to product-performance requirements. At the same time, transition structures such as MDO-PE/PE, BOPE/PE, and BOPP/CPP can be developed in parallel, creating a dual-track approach: “current packaging solution + 2030 recyclability-ready solution.”
- By 2030, the focus moves more clearly toward Mono-PE and Mono-PP structures. Where higher barrier performance is required, options such as MDO-PE/EVOH-PE/PE and OPP/CPP can be considered.Where technically feasible, the compatibility of components such as spouts, caps, and zippers with the main polymer family of the pouch should also be evaluated.
- By 2035, packaging assessment needs to move beyond theoretical recyclability. Packaging structures should also be evaluated against the actual collection, sorting, and recycling systems available in the destination market.
- By 2038, the focus shifts further toward structural simplification. Higher-performing Mono-PE and Mono-PP solutions should be prioritized, while materials and components that may reduce recycling compatibility—such as aluminium foil, PA, PET, paper-plastic laminates, and incompatible inks, adhesives, or components—should be reassessed where technically feasible alternatives are available.
- Toward 2040, the focus can shift further toward higher PCR content within Mono-PE and Mono-PP structures, while maintaining any necessary food-contact-safe layer and ensuring that packaging performance remains suitable for the intended application.
Through this staged approach, PPWR preparation does not need to be treated as a last-minute material replacement. Instead, packaging solutions can be progressively assessed, tested, and adjusted as future requirements become more demanding.
In summary, Tedpack’s solution pathway regarding the PPWR is as follows:
Why Start Preparing for PPWR Now?
Although the main provisions of the PPWR are not set to take effect until 2030, waiting until the last minute to act could result in significant losses.
Material transitions typically involve a complex series of steps, including structural development, prototyping, filling trials, performance validation, approvals, and documentation updates.
The later the process begins, the more difficult it becomes for brands to simultaneously test alternative solutions without disrupting their existing supply chains, making the timeline and costs increasingly difficult to control.Early action also creates opportunities to leverage proven packaging improvements—such as lightweighting, recyclable structures, and verified recycled content—into credible, evidence-based sustainability communications.Packaging transformation does not need to happen overnight, but preparations should begin early to ensure that all changes are thoroughly tested, validated, and implemented at the appropriate stages.
Need a More Detailed PPWR Reference?
TedPack has prepared a complete PPWR guide for brands and packaging teams preparing for the EU market.
The guide includes more detailed information on packaging requirements, documentation, Packaging BOM review, recyclable material options, PCR strategies, and transition planning.
Contact our team to request the full document and discuss how these requirements may apply to your packaging.
