PPWR (EU) 2025/40: What It Means for Transit Packaging

Last reviewed 23 October 2026 · Written by HuanCheer New Protection Material, Jiangsu, China

A practical reading of Regulation (EU) 2025/40 for people who specify protective packaging — what is already law, what is staged to 2030 and 2038, and what it means for the cushioning inside a carton.

1. What PPWR is, and why it is different from what came before

Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — was published in the Official Journal in January 2025 and entered into force on 11 February 2025. It replaces Directive 94/62/EC, which had governed EU packaging waste for close to thirty years.

The change in legal instrument matters more than it sounds. A Directive has to be transposed into national law by each member state, which produces twenty-seven versions with different timing and different enforcement. A Regulation applies directly and identically. There is no national transition period to wait out and no national interpretation to negotiate.

Its scope is deliberately exhaustive. It covers all materials — plastic, paper, board, metal, glass, composites — and all packaging functions: sales packaging, grouped packaging and transport packaging. If it protects, contains, presents or ships a product, it is in scope. That explicitly includes cushioning, void fill, mailers and the protective inserts inside a carton.

2. Timeline: what applies when

The gap between 2026 and 2030 is where most planning error happens. Compliance in August 2026 is not the finish line — it is the first gate. Anything being designed now has to survive the 2030 grading and, realistically, the 2038 one.

3. The heavy-metal limit

Article 5(4) caps the combined content of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg across the packaging unit. This applies to all packaging materials, with no material-specific exemption, and has been mandatory since 12 August 2026.

For paper packaging this is generally a comfortable limit, but "generally" is not a compliance position. The practical expectation is a test report against the equivalent 94/62/EC method on the base material, held on file and available to the buyer's compliance team. When you ask a supplier for this, ask for the date — a report older than two years is not much of a defence.

4. PFAS: narrower than most people think

Article 5(5) sets three thresholds for per- and polyfluoroalkyl substances in food-contact packaging: any single non-polymeric PFAS below 25 ppb; the sum of targeted non-polymeric PFAS below 250 ppb; and total fluorine, including polymeric PFAS, below 50 ppm. Above the fluorine threshold, the presence of PFAS is presumed and the burden of proof shifts to the producer.

5. Recyclability, and what changes in 2030

From 12 August 2026, packaging placed on the EU market has to be recyclable. From 1 January 2030 it has to meet a performance grade of A, B or C, meaning a design-for-recycling score of at least 70%. From 1 January 2038, only A and B — at least 80% — remain permitted.

This is where material choice starts to bite. Single-material construction scores well because there is nothing to separate. A kraft paper mailer with a honeycomb kraft core is one material in one stream. A plastic film laminated to paper, or a paper envelope with a plastic bubble layer bonded inside, is two materials that have to be separated before either can be recycled — and the grading system is built to penalise exactly that.

6. Minimisation: the void-space rule

Packaging weight and volume must be reduced to the minimum needed to function. False bottoms, unnecessary layers and artificially thickened walls are prohibited. For grouped, transport and e-commerce packaging the void-space ceiling is 50%, tightening to 40% for e-commerce packaging from 2030.

This is the clause most often missed by suppliers of cushioning. A mailer that replaces an outer bag, a layer of void fill and an inner box is not only a material reduction — it is a volume reduction, and from 2030 volume is explicitly regulated.

7. EPR and the declaration of conformity

Extended producer responsibility follows the principle that whoever first places packaging on a market finances its end-of-life management. In practice: registration in every member state where packaging is placed, payment of the relevant fees, and annual reporting.

Non-EU producers cannot register directly. They must appoint an authorised representative in each relevant member state. A Chinese manufacturer shipping to a German buyer is not the entity carrying the German EPR obligation — the buyer, or the importer of record, is. But the buyer will ask the manufacturer for the documentation that lets them register and declare. Suppliers who have that pack ready shorten their customer's compliance work; suppliers who do not become a problem to be solved.

The declaration of conformity is the document that ties it together: technical file, test reports, material declaration, and a signed statement that the packaging meets the Regulation. Customs authorities can ask for it, and marketplaces can require it before listing.

8. What this means for the cushioning inside the carton

Read together, the clauses point one direction for protective packaging:

1. Single material beats composite. The 2030 grading rewards packaging that enters one stream with nothing to separate.
2. Volume is now regulated. Cushioning that consolidates three functions into one part is favoured over three separate parts.
3. Documentation is part of the product. A test report with a current date is a deliverable, not a favour.
4. The 2026 gate is already behind us. Buyers are now working on the 2030 gate, which is a design question rather than a paperwork one.

9. Six questions to ask any cushioning supplier

1. Can I have the heavy-metal test report for the base material, and what is its date?
2. Is the product single-material, or is there a film or coating bonded to the paper?
3. Which recycling stream does it enter, and does the customer have to separate anything first?
4. What is the design-for-recycling position against the 2030 grading?
5. Does the product reduce the number of parts used per order, or add to them?
6. Is the PFAS testing you cite relevant to my application, or are you quoting a food-contact limit for a transport product?

A supplier who answers all six without hedging is worth keeping. One who answers three and changes the subject is telling you something.

10. Where paper fits, and where it does not

Honeycomb paper — kraft facings with an expanded kraft core — is single-material, enters the paper stream without separation, and consolidates the outer bag, void fill and inner box into one part. Against the 2030 grading that is a strong position.

It is not universal. Very heavy, very dense or sharp-edged products can exceed what paper cushioning protects against, and high-value fragile items sometimes need a moulded fitment that paper does not replicate. The honest version of the argument is not "paper replaces everything" — it is "for the majority of e-commerce and light industrial shipments, paper is now the lower-risk specification".