PPWR: What Companies Need to Know

Most companies in the timber and paper industry have spent the past two years focused on EUDR. That makes sense — the regulation is complex, the deadlines have shifted, and the compliance work is significant.

But while EUDR has dominated the conversation, another regulation has been moving through the EU legislative process with far less attention: the Packaging and Packaging Waste Regulation, or PPWR.

PPWR entered into force in February 2025, and its main obligations apply from 12 August 2026. For companies working with wood and paper products, this is not a distant concern. It directly affects how packaging is designed, documented, and placed on the EU market — and it applies to materials many of these companies already handle.

What PPWR Actually Requires

PPWR replaces the old Packaging and Packaging Waste Directive (94/62/EC). The shift from a directive to a regulation is significant: it applies directly in all EU Member States, with no national transposition needed. The rules are the same everywhere.

At its core, PPWR sets mandatory performance standards for all packaging placed on the EU market, covering recyclability, material composition, restricted substances, labelling, and documentation. From 12 August 2026, four obligations apply:

1. Declaration of Conformity

Every packaging type placed on the EU market must be covered by a signed Declaration of Conformity (DoC) — a legally binding self-declaration confirming that the packaging meets PPWR requirements. Without one, packaging cannot legally enter the market. The manufacturer is responsible for issuing it; importers must collect and retain it from their suppliers and produce it to authorities within 10 days on request. The retention period is 5 years for single-use packaging and 10 years for reusable packaging.

2. Restricted substances

PPWR bans PFAS in food-contact packaging above specific thresholds (25 ppb for any individual PFAS, 250 ppb for the sum, and 50 ppm total fluorine). For all packaging types — not just food-contact — heavy metals (lead, cadmium, mercury, and hexavalent chromium) must not exceed 100 mg/kg combined. There is no transitional period: packaging placed on the market after 12 August must comply, even if it was manufactured earlier.

3. Packaging minimisation

Packaging must be designed to reduce weight and volume to the minimum necessary. The regulation also introduces an empty-space ratio: transport, grouped, and e-commerce packaging cannot exceed 50% empty space relative to the product.

4. Manufacturer and importer identification

Packaging must bear the name and address of the manufacturer and, where applicable, the importer.

Several later milestones follow:

• By 2028 — harmonised EU-wide packaging labels and data carriers
• By 2030 — recyclability grades enforced on an A-to-E scale, recycled content targets begin, reuse quotas of 40% for transport packaging, and the overall packaging waste recycling target rises to 70%
• Between 2035 and 2040 — stricter recycled content and recyclability requirements phase in

Why This Matters for the Timber and Paper Sector

If you manufacture, import, supply, or place paper-based packaging on the EU market, PPWR is likely to apply to you.

For many companies in this sector, PPWR and EUDR overlap on the same products. A company using paper packaging needs EUDR compliance for the fibre sourcing (where did the wood come from?) and PPWR compliance for the packaging itself (is it recyclable, properly documented, and free of restricted substances?).

The operational challenge is similar too. Both regulations require companies to collect data from suppliers — origin and geolocation for EUDR, material composition and substance testing for PPWR. Both require formal declarations (a DDS for EUDR, a DoC for PPWR). Both require document retention for years. Both require traceability.

Companies that are already building supplier documentation workflows for EUDR are, in many ways, building the same infrastructure they will need for PPWR.

Where Companies Will Struggle

The complexity of PPWR is less legal than operational.

Most companies do not maintain a centralised inventory of every packaging type they place on the market. Packaging decisions are often spread across procurement, product development, marketing, and suppliers, making it difficult to build a complete overview of materials, dimensions, and supplier information. For many businesses, simply mapping the packaging portfolio is the first major challenge.

Another difficulty is supplier data collection. Declarations of Conformity require information that many companies do not currently gather from packaging suppliers, including material composition, substance testing, and recyclability evidence. Obtaining this — especially from smaller or non-EU suppliers — requires time, coordination, and structured outreach.

Documentation management also becomes significantly more demanding. Each packaging type requires its own compliance documentation and Declaration of Conformity. For companies managing dozens or hundreds of packaging types, this quickly becomes a traceability and document-management challenge that calls for a structured system rather than manual spreadsheets.

On top of this, obligations phase in progressively between 2026 and 2040. Companies therefore need visibility not only over current requirements, but also over which future obligations may require packaging redesigns, additional documentation, or changes to how supplier information is collected.

What to Do Now

If you place wood-based or paper-based packaging on the EU market, there are already practical steps worth taking ahead of 12 August 2026.

A good starting point is building a clear overview of your packaging portfolio. Many companies do not yet have a centralised view of every packaging type they place on the market, including material composition, format, and use case. Without this visibility, assessing PPWR obligations becomes difficult.

It is also worth reviewing what information is currently available from packaging suppliers. Many companies will need additional data — material composition details, substance testing results, and recyclability information — to support future compliance documentation.

Companies should also start thinking about how Declarations of Conformity will be managed internally: who will be responsible for preparing them, what information needs to be included, and how documentation will be stored and maintained over time. Manual processes may work initially, but often become difficult to manage across larger packaging portfolios.

For companies already preparing for EUDR, there may also be opportunities to reuse existing compliance workflows. Supplier outreach processes, documentation management systems, and recurring supplier data collection mechanisms built for EUDR can support parts of PPWR implementation too.