The Packaging and Packaging Waste Regulation (PPWR) introduces new requirements for packaging placed on the European market. As the regulation gradually comes into force, many companies have questions about their responsibilities, compliance obligations and the practical impact on their packaging. In this FAQ, we answer the most common questions about PPWR, including Declarations of Conformity (DoC), Extended Producer Responsibility (EPR), recyclability, labelling requirements and upcoming regulatory changes.

1. General understanding of PPWR

What is PPWR? 

The Packaging and Packaging Waste Regulation (PPWR) aims to reduce the growing volume of packaging waste and prevent further increase by 2030.  The regulation entered into force on 11 February 2025 and will generally apply from 12 August 2026, with longer transition periods applying for certain requirements.

For which companies does PPWR apply to? 

PPWR applies to all economic operators involved in the packaging value chain. These include: 

• Producers (manufacturers, distributors and importers) 
• Suppliers
• Authorised representatives 
• Fulfilment service providers

Which economic operator catogory applies to VPK?

As a packaging company, VPK is generally considered a supplier under PPWR. In certain specific situations, VPK may also be considered as a manufacturer, for example when:

• Delivering packaging directly to consumers through B2C or web-sales
• Delivering packaging to micro-enterprises
• For our own transport packaging: pallets, straps and wraps

What are the key topics within PPWR?  

The main topics to address in the short term (2026) are: 

• Substances of Concern (SoC) 
• Declaration of Conformity (DoC) 
• Extended Producer Responsibility (EPR)

From 2028 onwards, additional requirements will gradually become applicable, including: 

• Packaging minimization
• Empty space ratio requirements
• Labelling requirements 
• Design for recycling

What actions does VPK take to fulfil its responsibilities as a supplier?

VPK provides customers with technical information relating to the packaging references supplied to them. To address the requirements on Substances of Concern (SoC), VPK has established an evidence-based compliance statement based on:

• Supplier declarations
• Assessments of its own production processes 
• Historical test reports

What are the responsibilities of a supplier? 

A supplier must provide the manufacturer with relevant technical information for the packaging supplied. In addition, the supplier must provide available test reports on Substances of Concern (SoC).

What are the responsibilities of a Manufacturer? 

A manufacturer uses the information provided by suppliers to prepare the Declaration of Conformity (DoC) for the it places on the EU market. The manufacturer is responsible for ensuring that the packaging complies with the applicable PPWR requirements.

What is a Declaration of Conformity (DoC)? 

A Declaration of Conformity (DoC) is a document that demonstrates compliance with the applicable PPWR requirements and allows packaging to be placed on the EU market.

The DoC:

• Must be made available to market surveillance authorities upon request
• Combines compliance information for all packaging components and materials (for example, a cardboard box and a plastic bag) 
• Must be retained for at least five years by the responsible economic operator
• Does not need to be shared with other economic operators unless required

As a customer of VPK, can I ask VPK to prepare or sign my DoC? 

In most cases, VPK acts as a supplier and is therefore not responsible for preparing or signing the Declaration of Conformity for packaging placed on the market by its customers.

The responsibility for preparing and signing the DoC remains with the manufacturer placing the packaging on the EU market.

What is an Extended Producer Responsibility (EPR)? 

Extended Producer Responsibility (EPR) is a financial responsibility for the management of packaging waste, including the costs of collection, sorting and recycling.

Producers, such as manufacturers, distributors and importers, are responsible for paying EPR fees in the countries where they place packaging on the market.

2. Requirements applicable at a later stage

Are there additional PPWR requirements that companies should prepare for?

Yes. Several PPWR requirements will become applicable in the coming years. VPK continuously monitors the development of secondary legislation and technical specifications expected between 2026 and 2030.

Which PPWR requirements will apply to pallets? 

From 2030 onwards, a 100% reuse target will apply to pallets used for transport within the same Member State, subject to the conditions defined in the regulation.

Which recyclability requirements will apply under PPWR? 

The detailed recyclability criteria and performance grades have not yet been published. Greater clarity is expected through a delegated act by 1 January 2028. The new requirements are expected to become applicable 24 months after publication.

What should I know about the EU-wide labelling system? 

PPWR introduces harmonised labels for different packaging materials to help consumers sort and recycle packaging correctly. These labels will only apply to consumer packaging, meaning packaging that enters household waste streams. The labelling requirements are expected to apply from 12 August 2028.

How can I comply with the new packaging minimisation requirements? 

The detailed packaging minimisation criteria are not yet available. Additional guidance is expected by 12 February 2027, with the requirements becoming applicable from 1 January 2030.

How can I measure the empty space ratio of my packaging? 

The methodology for calculating the empty space ratio has not yet been defined. Further clarification is expected through an implementing act in 2027, with the requirements becoming applicable from 1 January 2030.

Can I continue using physical labels on my packaging, or must I switch to digital data carriers? 

From 2027, PPWR explicitly allows the use of digital data carriers, such as QR codes, to provide certain mandatory packaging information.

However, mandatory labelling elements cannot be provided exclusively in digital format. Physical labels will remain mandatory for harmonised sorting information.

The manufacturer or producer remains responsible for the digital content and must ensure that the information is accessible, accurate and available for the required period.

PPWR Expert Annex

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 annex complements the FAQ section. It 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 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 and latest test results are expected in September 2026.

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 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 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 during summer 2026.

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 be required to report EPR data in case we are seen as the manufacturer under PPWR. 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.
• 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, 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.