Getting ready for the PPWR: six steps that make your shipping compliant by design
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has been in force since 11 February 2025, its general application date is 12 August 2026, and further stages phase in up to 2030. Our explainer set out what changes. This article answers the more practical question: what should you actually do now so your shipping packaging meets the requirements, instead of retrofitting at greater cost later?
We went through the European Commission's official guidance and turned it into a short checklist for shipping and cold-chain operators.
1. Map your packaging types
For every type of packaging you use, you need an EU declaration of conformity and technical documentation once it is placed on the market (Article 16). Separate components, such as straps, wraps or pallet collars, are assessed separately and need their own declarations. So the first step is simply an overview: which formats do you ship, for what, and who places them on the market?
2. Make recyclability provable, not just theoretical
The core of the regulation is provable recyclability (Article 6). The result of the recyclability assessment has to sit in your technical documentation before the packaging is placed on the market. From 2030, the binding design-for-recycling performance criteria apply, and the recyclable-at-scale assessment rests on an EU recycling target of 55 percent per packaging category. Packaging that is recyclable in theory but ends up in residual waste in practice does not meet this standard.
This is exactly where we start. Our packaging is made from more than 97 percent recycled waste paper, produced in a patented dry process without added water or chemicals, and can be disposed of entirely in the paper bin, with nothing for your customers to separate. The recyclability is independently verified by the Papiertechnische Stiftung (PTS).
3. Check food contact and PFAS
From 12 August 2026, limits for PFAS in food-contact packaging apply (Article 5(5)). For chilled food shipping, that means checking the inner layers, coatings and printing inks of your packaging against the requirements. Ask your suppliers for the necessary information, because without it you cannot draw up a clean declaration of conformity.
4. Bring empty space below the 50 percent cap
The regulation caps empty space in grouped, transport and e-commerce packaging at an empty-space ratio of 50 percent (Article 24). Note that filling material such as paper cuttings, air cushions or bubble wrap counts as empty space, not as filling. Anyone who fits shipments to the actual product now has nothing to correct later. In cold-chain shipping this has a double effect: less internal volume means less area to cool, and therefore less coolant.
5. Prepare your labelling
The PPWR introduces harmonised sorting labels for packaging (Article 12). Prepare to label your packaging so customers can see at a glance which collection stream it belongs to. With a mono-material paper solution, that message is simple: into the paper bin, without separating.
6. Substantiate your environmental claims
Environmental claims on packaging are only permitted if they can be substantiated beyond the legal minimum. Check every claim made on or about your packaging for its basis. A claim that needs a footnote to hold up is not a robust claim. Material origin, verified recyclability and a working disposal route are provable; a green logo alone is not.
In short
The general application date is 12 August 2026, and further requirements such as the binding recyclability grades, recycled-content quotas for plastic and format bans follow from 2030. The cheap route today is rarely the cheap route across the coming years. Whoever aligns their packaging early on provable recyclability, the right size and clean documentation meets the coming requirements by design.
Want to run your packaging formats against the PPWR requirements? We will go through them with you. Get in touch: https://www.supaso.eu/kontakt