EU Packaging Regulation (PPWR): what changes for paper packaging and exporters?

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied directly across the EU since 12 August 2026. It covers all packaging regardless of material, so paper is not exempt. However, the recycled-content mandate and the Annex V bans apply only to plastic, and part of the reuse targets does not apply to cardboard boxes.

Key facts

Timeline: what starts when?

Some obligations start on a fixed date or a set period after the relevant Commission act enters into force, whichever is later. The dates below are the earliest possible.

Rules that apply to paper packaging

• Substances: the heavy-metal limit has applied to all packaging since 12 August 2026; PFAS limits apply only to food-contact packaging.
• Recyclability: paper and cardboard packaging will also be graded A/B/C. Paper-specific design criteria have not yet been published (the Commission is expected to adopt them by 1 January 2028).
• Minimisation and empty space: paper void fill and paper wrapping count as empty space (Article 24(3)); see the 50% empty space guide.
• Labelling: e-commerce boxes will carry the harmonised sorting label; the label itself has not yet been defined.
• Environmental claims: claims such as "recyclable" must go beyond the Regulation's minimum requirements and be documented in the technical documentation (Article 14). We explain what each claim rests on in the environmental claims guide.

Rules that do not affect paper

• Recycled-content mandates (Article 7) apply to plastic packaging only. The Commission will review other materials by 12 February 2032.
• Annex V bans target single-use plastic formats. According to Commission guidance, paper composites containing 5% or more plastic by weight can fall under some of these bans.
• Reuse targets (Article 29) do not apply to cardboard boxes (29(4)(d)). Pallets, non-cardboard boxes and crates are in scope.

So a mono-material paper pack is caught by fewer rules than a pack containing plastic, but saying "paper is exempt from PPWR" is wrong. A paper pack built from a corrugated box, Protack® kraft paper tape and SafePak® removes the mixed-material problem.

The role of a Turkish supplier

The Regulation reaches non-EU companies through the operators on the EU market. A company that makes packaging is normally the "manufacturer" when the packaging does not carry the customer's brand. The manufacturer must prepare technical documentation, draw up an EU declaration of conformity and respond to an authority's request within 10 days (Article 15). The EU importer checks these documents (Article 18). Extended producer responsibility (EPR) registration and fees fall on the "producer" that first makes the packaging available in a Member State, which in most cases is the EU customer. For a step-by-step list see the EU export checklist.

Do certificates prove compliance?

No. FSC® or ISO certificates are valuable in supplier assessment, but the Regulation does not recognise them as proof of conformity. PPWR compliance is shown through technical documentation and the EU declaration of conformity. We explain what FSC® covers in this guide.

The framework in Türkiye

In Türkiye, packaging waste is governed by the Regulation on the Control of Packaging Waste published in the Official Gazette of 26 June 2021, No. 31523; companies placing packaging on the market register in the Packaging Information System and report annually. The Deposit Management System initially covers single-use glass, PET and aluminium beverage packaging; paper protective packaging is not in scope. Complying with Turkish rules does not replace PPWR: packaging entering the EU must comply with PPWR.

Common mistakes

• "PPWR has been postponed": No, it has applied since 12 August 2026. What is late is some of the secondary legislation (labelling, producer register format).
• "Paper void fill lowers the empty space ratio": No, Article 24(3) counts fill as empty space.
• "We must print the label now": No, the harmonised label has not been defined yet; the earliest date is 12 August 2028.
• "The 40% reuse target applies to all packaging": No, only to the formats listed in Article 29(1) and to use within the EU; cardboard boxes are excluded.

Sources

• Regulation (EU) 2025/40, EUR-Lex
• European Commission, packaging waste page and PPWR guidance C(2026) 3702
• Regulation on the Control of Packaging Waste, Turkish Official Gazette 26.06.2021

This guide is for information only and is not legal advice. Dates and articles were checked against the official text as of 27 October 2026 and will be updated as secondary legislation is adopted.