How is VPK aligning its packaging design and materials with PPWR requirements, such as recyclability, recycled content targets, and packaging minimization?
PPWR
The new Packaging and Packaging Waste Regulation (PPWR) aims at reducing the increasing volume of packaging waste and preventing its further growth by 2030. It entered into force on 11 February 2025 and will apply generally from 12 August 2026, with longer transition periods applying to certain requirements.
It applies to all economic operators, from manufacturers, suppliers and importers to distributors and fulfilment service providers. According to FEFCO’s current understanding, corrugated packaging companies are typically considered either manufacturers (B2C, or web-sales to end customers) or suppliers (all standard corrugating plants: B2B). The requirements in PPWR for reporting are much higher for manufactures (mainly our customers: brands, retail, traders, …) then for suppliers (the standard corrugated box plants). However, to accurately identify the specific obligations that apply, each company must assess its role within the supply chain and consult with internal operational and legal departments.
PPWR is a vast regulation, and this summary aims to capture essentials impacting the relation between VPK and its customers. Major milestones are 2026 regarding PFAS, Heavy Metals (HM) and Bisphenols; 2027 requests compliancy on Extended Producer Responsibility (EPR) and 2028 compliance on packaging labelling. Across all these milestones, the Commission expects manufacturers of packaging goods to increase efforts on packaging reduction and recycling.
On the topic of microplastics within PPWR:
- VPK has done its due diligence across its supply chain and manufacturing processes.As an outcome, only certain inks (more specific: the extenders) used in the printing process of corrugated packaging might have micro-plastics.As a conclusion, VPK requested all its ink suppliers to comply with PPWR and as a consequence, micro-plastics in inks/extenders will be substituted by eco-extenders complying with PPWR.VPK will comply by October 2026 on that target.
On the topic of conformity claim:
- The target date is set at August 2026 and is the duty of the filler (company using the packaging products: brands, retail, traders, …).This means the filler needs to comply with a “Conformity Document” that needs to be made per material. Yet, no definition has been established on the definition on what a material might be.On the content of the “Conformity Document”, PPWR refers to Annex 7.PPWR does not make a distinction between primary, secondary and tertiary packaging and all type of packaging should be considered.VPK wants to support its customers (as being mainly the fillers according to PPWR) in establishing the Conformity Document. Therefore, it has started to verify what data needs to be added and guarantee extraction of this data to be provided to the fillers.
It is expected to have this ready during Q2 2026.
What measures does VPK have in place to ensure compliance with restrictions on hazardous substances in packaging, including heavy metals and per- and polyfluoroalkyl substances (PFAS)?
Heavy metals and PFAS
On the topic of heavy metals (HM)
- Two aspects need to be considered: in what way heavy metals are added in the production process and the level of heavy metals that can be found in VPK’s products.On the first part, VPK does not add intentionally heavy metals in its production process. On the second part, VPK conducts currently several tests.Paper being the main component of a corrugated box, analysis has been conducted at VPK Paper on heavy metals. Results have shown compliance with European regulations. FEFCO has done similar tests on corrugated boxes and is coming to the same result. Hence – and within the EU – each country can request stricter thresholds and/or different measuring processes. Sample tests on corrugated boxes are being conducted to confirm compliance.
On the topic of per- and polyfluoroalkyl substances (PFAS):
- PFAS is a common abbreviation used for a complex group of synthetic chemicals and are often called “forever chemicals”.PFAS takes an important point of attention within the PPWR, hence we need to be careful.
- PFAS restrictions apply exclusively to Food Contact Materials (FCM). However, since FCM is defined as “materials in direct physical contact with food or in indirect contact through the gas phase,” the majority of our food packaging falls within the scope.
- At first, the Commission (through PPWR) has stated the maximum thresholds per categories of PFAS (25ppb, 250 ppb and 50 ppm depending on the type of PFAS), but due to the high number of PFAS-types, this is complex.
Second, the Commission (through PPWR) has not stated the way PFAS needs to be measured.
As a consequence, this makes it pretty difficult for manufacturers to identify how its PFAS-performance complies with PPWR requirements. Hence the commission has recently approved the test proposal by RISE, formal validation & publication still needs to happen.
- VPK does not add intentionally PFAS in its production process of paper nor of corrugated packaging. Its suppliers have confirmed the same approach.When it comes to bisphenol A & B, same approach: not intentionally added in the production process.
- VPK conducts every second year some PFAS analysis on a selection of categories with an ISO-certified (17025 & 22000) laboratory Eurofins.Results over time show stable values below the PPWR thresholds and new tests are being performed in Q4 2025.
How is VPK preparing to meet Extended Producer Responsibility (EPR) obligations under the PPWR and related national schemes, including data reporting?
Extended Producer Responsibility
On the topic of Extended Producer Responsibility:
- Extended Producer Responsibility (EPR) by making producers fully financially and organizationally responsible for packaging waste management, covering costs like collection, sorting, and recycling.The PPWR mandates eco-modulated fees based on recyclability, requires producers to register and report detailed data in each Member State.It enters into force as from August 2026.First reporting will have to be done in August 2027.
- Hence, some countries might already meet the EPR target by being organized through a PRO: Producer Responsibility Organization.VPK is member of these PROs amongst most of countries of it operates (i.e. Norway, Sweden, Denmark, Belgium, Ireland, Germany, Romania, Italy, Hungary, The Netherlands, etc.).The Government in Denmark decided to set up a separate system to meet the EPR’s requirements.VPK Denmark did adapt to it. VPK will comply by August 2026 on that target.
- Standard corrugated box plants will only be required to report EPR data to the PROs for the transport packaging materials we use to “package” our own products: pallets, straps, wrap, bottom sheets, top sheets, interlayers, and bundle straps. This reporting must be carried out in each EU Member State and responsibility depends on the following scenarios:
- If the manufacturer is located in the same Member State where the packaging becomes waste, the manufacturer is considered the producer and is responsible for reporting.
- If the manufacturer is not located in the Member State where the packaging becomes waste, the producer is another company established in that Member State (e.g. distributor, importer, or unpacker), which then takes care of the reporting.
- 3) For online sales to the end-consumer, the making available on the market is in the Member State where the end-user is located.
- We will support customers by providing the required data (weight, recyclability, recycled content, etc.).
How is VPK aligning its packaging design and materials with PPWR requirements, such as recyclability, reuse targets, labelling, and packaging minimization?
Other remaining targets on the longer term within PPWR:
- Recyclability: Corrugated packaging shall be recyclable by 2030 and respect the recyclability assessment criteria currently elaborated under the secondary legislation.This is no issue for VPK Corrugated, except for PE-coated products.
- Minimisation of packaging and empty space ratio: The regulation promotes the design of packaging that minimises material use and ensures grouped packaging; transport-, grouped packaging or e-commerce packaging should have a maximum empty space ratio of 50 % from 2030. Sales packaging will have the 50 % restriction from 2028.This is included in VPK’s box design process with customers.
- Reuse targets: Corrugated boxes are exempted, but other transport packaging types are in the scope. Companies will have to comply with the reuse targets for their own packaging or logistic system. By 2030, 40% of pallets will be required to be reused (for example, through a pooling or return system). Straps and wraps will be exempt from the reuse requirement.
- Labelling: as of 12 August 2028, all packaging that reaches final customers must carry a specific, defined label indicating recyclability, substances of concern, compostability, and other required information.
