If you sell into the European Union, packaging is no longer just a buying decision — it is a compliance one. The EU Packaging and Packaging Waste Regulation, known as PPWR and published as Regulation (EU) 2025/40, has applied since 12 August 2026. It replaced the nearly thirty-year-old Packaging and Packaging Waste Directive 94/62/EC, and unlike a directive it applies directly in all member states without national transposition.
What changed, in one sentence
The old directive left member states free to choose how to meet common targets; the new regulation sets binding requirements that apply identically across the EU. For a buyer, this means fewer national variations to track — but also far less room to argue that a requirement does not apply to you.
Four requirements that affect paper boxes
Heavy metal limits. The sum of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg. For paper board and most water-based coatings this is rarely a problem, but it can bite with certain pigments, metallic inks and recycled content of unknown origin.
PFAS restrictions in food-contact packaging. Per- and polyfluoroalkyl substances — long used for grease and water resistance — are restricted in packaging intended to contact food. Thresholds are set for PFAS as a group and for specific substances. If your box carries unpackaged food, or food that may contact the surface, this needs checking at material selection stage.
Recyclability and design-for-recycling. Packaging must meet recyclability performance grades, and the regulation pushes design toward materials and structures that can actually be sorted and recycled in practice. In box terms, this favours single-material construction and penalises mixed laminates and heavy plastic coatings.
EPR registration and the declaration of conformity. Producers must be registered in extended producer responsibility schemes in each member state where they place packaging, and must hold a declaration of conformity supported by technical documentation. Registration is per country — a single EU-wide registration does not exist.
| Requirement | What it sets | Practical effect on a paper box |
|---|---|---|
| Heavy metals | Sum ≤ 100 mg/kg | Check metallic inks, pigments, recycled content |
| PFAS | Restricted in food contact | Avoid fluorinated grease barriers, check coatings |
| Recyclability | Performance grading | Favour mono-material, limit laminates and plastic |
| EPR and DoC | Per-country registration | Register in each market, keep technical file |
What this means for how a box is specified
Three specification decisions now carry compliance weight. Lamination: a plastic film laminated onto paper makes recycling harder, so water-based varnish is increasingly the safer default. Inserts: plastic trays and foam are problematic in a design-for-recycling assessment, while moulded pulp and paperboard inserts are not. And mixed materials: a box that combines board, plastic, metal and fabric in one unit is difficult to grade well regardless of how it looks.
None of this means a premium look is impossible. Foil stamping and embossing remain workable because the quantities involved are small relative to the whole pack, but large-area plastic lamination and heavy mixed-material builds are where problems start.
FSC: what it does and does not say
FSC certification concerns where the fibre came from, not whether the finished pack is recyclable. An FSC claim means the paper can be traced back through a chain of custody to responsibly managed forests. That is a sourcing claim, and it is entirely separate from PPWR recyclability grading — having one does not give you the other.
If you need to make an FSC claim on your packaging, ask your supplier for a valid chain-of-custody certificate and keep the claim scope clear. Vague references to "eco paper" without certificate numbers are increasingly challenged by regulators and by retailers.
A buyer's self-check before shipping to the EU
| Check | What to confirm |
|---|---|
| Market list | Which member states you place packaging in |
| EPR status | Registered in each of those countries |
| Material declaration | Board grade, coatings and insert materials named |
| Heavy metal test | Available for inks and coated materials |
| Food contact | Whether PFAS-free coatings are used |
| Documentation | Declaration of conformity and technical file held |
At GDF we build export orders around mono-material board, water-based coatings and paper-based inserts by default, and we flag any specification that is likely to cause a recyclability or PFAS problem before it reaches production. For binding legal confirmation on your specific market and product, please check the latest official text of the regulation and confirm with your own compliance adviser.
Related reading: Volume Weight / Packaging Inserts / Rigid Box vs Folding Carton
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