REGULATORY UPDATE | EU PACKAGING
PPWR is here: turning regulatory requirements into a practical packaging brief
The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, is now applying in phases. For buyers sourcing paper bags, gift boxes and food-contact packaging, the immediate task is to connect each packaging specification with its intended use and supporting evidence.
Rather than treating sustainability as a material label alone, procurement teams should examine the complete pack: paper, coatings, inks, adhesives, handles and other components.
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Bonroy PPWR technical presentation: a material-by-material approach.
1. Understand the implementation timeline
| Milestone | What buyers should understand |
|---|---|
| 11 February 2025 | The regulation entered into force. |
| 12 August 2026 | General application began, with specific obligations introduced in stages. |
| Later implementation stages | Check the relevant article, exemptions and implementing measures for each packaging format. |
Procurement takeaway: a single implementation date does not mean every recyclability, labelling or recycled-content requirement applies to every product immediately.
2. Start with a clear product and material specification
A useful PPWR review starts before a purchase order is placed. Define the target market, packaging function, dimensions, weight, material structure and expected disposal route. For coated or laminated paper packaging, assess the whole structure rather than assuming that a paper appearance proves recyclability.
Paper bags: review paper grade, handles, reinforcement, printing and adhesives.
Gift and retail boxes: review inserts, laminations, magnets and the ability to separate components.
Food-contact packaging: specify the food type, temperature and contact duration, alongside applicable substance restrictions and food-contact requirements.
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Printing-process image from Bonroy’s PPWR presentation. The presentation discusses soy-based offset inks and water-based flexographic inks.
3. Give food-contact applications specific attention
PPWR includes PFAS concentration limits for food-contact packaging from 12 August 2026. Buyers should request evidence appropriate to the actual material and intended application. A broad environmental claim cannot replace a review of a defined sample, test method and applicable limit.
PPWR review also needs to sit alongside applicable food-contact legislation. Evidence for one requirement should not be presented as proof that all regulatory obligations have been met.
4. Build an evidence file that matches the supplied pack
For a productive technical discussion with Bonroy, share the packaging drawing, intended use and destination market. A structured review can then identify the documents and tests needed for that specific project.
Identify the pack: record the product reference, material layers and intended use.
Check the evidence: compare the tested sample and reported scope with the proposed specification.
Control changes: review changes to coatings, inks, adhesives and construction before repeat production.
Maintain traceability: retain the applicable technical documentation and declarations for the responsible economic operator.
From the technical file: paper test evidence
Bonroy’s supplied PPWR presentation includes test-report pages for paper, printing inks, varnish and other packaging components. The paper-test excerpt below records ND for the listed metals and a Pass conclusion for the reported assessment. ND means not detected at the stated method detection limit; it does not mean absolute absence.
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Source: Bonroy PPWR presentation, page 4. Report and sample identifiers, stamps and contact details are excluded. Results relate only to the tested sample and reported scope.
5. Make the next packaging brief more precise
Professional packaging sourcing connects presentation, function and compliance evidence. When discussing a paper packaging project with Qingdao Bonroy Packaging Co., Ltd., include the target market and intended use as early as the artwork and size requirements. This helps focus the review on the actual pack being purchased.
Planning a packaging project for the EU?
Prepare your dimensions, material preferences, intended use and destination market for a specification-based discussion with Bonroy.
Official references
Regulation (EU) 2025/40 - official legal text
European Commission - packaging waste and PPWR implementation
This article provides general procurement information. Product-specific compliance depends on the packaging, intended use, applicable obligations and supporting documentation.