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 frequently asked questions about PPWR, including the Declaration of Conformity (DoC), Extended Producer Responsibility (EPR), recyclability, labelling requirements and future regulatory changes.
What is PPWR?
The Packaging and Packaging Waste Regulation (PPWR) aims to reduce the growing volume of packaging waste and prevent further increases by 2030. The regulation entered into force on 11 February 2025 and is generally applicable from 12 August 2026, with longer transition periods for certain requirements.
Which companies does PPWR apply to?
PPWR applies to all economic operators within the packaging value chain. This includes:
· Producers (manufacturers, distributors and importers)
· Suppliers
· Authorised representatives
· Fulfilment service providers
Which category of economic operator applies to CRT:
As a packaging company, CRT is generally considered a supplier under PPWR. In certain specific situations, CRT may also be considered a manufacturer, for example when:
· Packaging is supplied directly to consumers through B2C or online sales
· Packaging is supplied to micro-enterprises
· For our own transport packaging: pallets, straps and films
What are the key topics within PPWR?
Key short-term topics (2026):
· Substances of Concern (SoC)
· Declaration of Conformity (DoC)
· Extended Producer Responsibility (EPR)
From 2028, additional requirements will gradually become applicable, including:
· Packaging minimisation
· Empty-space ratio requirements
· Labelling requirements
· Design for recycling
What actions is CRT taking to fulfil its responsibilities as a supplier?
CRT provides customers with technical information about the packaging references supplied. To comply with the requirements relating to Substances of Concern (SoC), CRT has prepared an evidence-based Declaration of Conformity 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 about the packaging supplied. In addition, the supplier must provide available test reports concerning Substances of Concern (SoC).
What are the responsibilities of a manufacturer?
A manufacturer uses information from suppliers to prepare the Declaration of Conformity (DoC) for the packaging placed 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 demonstrating that packaging complies with the applicable PPWR requirements and allowing it to be placed on the EU market.
The DoC:
· Must be made available to market surveillance authorities upon request
· Combines conformity information for all packaging components and materials (for example, a cardboard box and a plastic bag)
· Must be retained by the responsible economic operator for at least five years
· Does not have to be shared with other economic operators unless required
Can I, as a customer, ask CRT to prepare or sign my DoC?
In most cases, CRT acts as a supplier and is therefore not responsible for preparing or signing the DoC for packaging placed on the market by customers.
Responsibility for preparing and signing the DoC lies with the manufacturer placing the packaging on the EU market.
What is 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.
Requirements That Will Apply at a Later Stage
Are there additional PPWR requirements that companies should prepare for?
Yes. Various PPWR requirements will become applicable over the coming years. CRT continuously monitors the development of secondary legislation and technical specifications expected between 2026 and 2030.
What PPWR requirements will apply to pallets?
From 2030, a 100% reuse target will apply to pallets used for transport within the same Member State, subject to the conditions set out in the regulation.
What recyclability requirements will apply under PPWR?
The detailed criteria and performance levels for recyclability have not yet been published.
Further clarification is expected through a delegated act by 1 January 2028. The new requirements are expected to become applicable 24 months after publication.
What do I need to know about the EU-wide labelling system?
PPWR introduces harmonised labels for different packaging materials to help consumers correctly sort and recycle packaging.
These labels apply only to consumer packaging, i.e. packaging that enters household waste streams.
The labelling requirements are expected to become applicable from 12 August 2028.
How can I comply with the new packaging minimisation requirements?
The detailed criteria for packaging minimisation are not yet available.
Additional guidance is expected by 12 February 2027, with application from 1 January 2030.
How can I measure the empty-space ratio of my packaging?
The method for calculating the empty-space ratio has not yet been defined.
Further clarification is expected through an implementing act in 2027, with application from 1 January 2030.
Can I continue using physical labels, or do I need to switch to digital data carriers?
From 2027, PPWR explicitly permits the use of digital data carriers, such as QR codes, to provide certain mandatory information.
However, mandatory labelling elements may not be provided exclusively digitally. 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 reporting requirements under PPWR are significantly higher for producers (primarily our customers: brands, retailers, traders, etc.) than for suppliers (the standard corrugated board manufacturers). In order to correctly determine the specific obligations, each company must assess its role within the supply chain and consult with its internal operational and legal departments.
PPWR is a comprehensive regulation, and this annex supplements the FAQ section. Its purpose is to outline the key elements affecting the relationship between CRT and its customers. Key milestones are 2026 for PFAS, heavy metals (HM) and bisphenols; 2027 for compliance with Extended Producer Responsibility (EPR); and 2028 for compliance with packaging labelling requirements. Across all these milestones, the Commission expects producers of packaged goods to increase their efforts towards packaging reduction and recycling.
Microplastics within PPWR
CRT has examined its entire supply chain and production processes. This shows that only certain inks (more specifically, the extenders) used in the corrugated board printing process may contain microplastics. CRT has therefore already asked all its ink suppliers to operate in compliance with PPWR. As a result, microplastics in inks/extenders will be replaced by eco-extenders that comply with PPWR. CRT will meet this obligation by October 2026.
Declaration of Conformity
The target date is August 2026 and responsibility lies with the filler (the company using the packaging: brands, retailers, traders, etc.). This means that the filler must comply with a “Declaration of Conformity” that must be prepared for each material. However, there is currently no definition of exactly what is considered a material. For the content of the Declaration of Conformity, PPWR refers to Annex 7. PPWR makes no distinction between primary, secondary and tertiary packaging: all packaging must be included.
CRT wants to support its customers (primarily the fillers under PPWR) in preparing this document. CRT has therefore started identifying the required data and ensuring that this data can be supplied. This is expected to be ready by Q2 2026.
Measures Relating to Hazardous Substances: Heavy Metals and PFAS
Heavy Metals (HM)
Two aspects need to be considered:
- Whether heavy metals are added during the production process
- The level of heavy metals that may be present in CRT products
Our manufacturing partners do not add heavy metals during its production process. They are currently conducting various tests. Paper is the main component of a corrugated cardboard box, and analysis show that the values comply with European regulations. FEFCO has conducted similar tests on corrugated packaging and reached the same conclusion.
Within the EU, individual countries may apply stricter threshold values or different measurement methods. Therefore, samples of corrugated packaging are being tested to confirm compliance. The latest test results are expected in September 2026.
PFAS
PFAS is a collective term for a complex group of synthetic chemicals, often referred to as “forever chemicals”. PFAS is an important area of focus within PPWR.
PFAS restrictions apply exclusively to Food Contact Materials (FCM). As FCM is defined as “materials that are in direct physical contact with food or indirectly through the gas phase”, the majority of our food packaging falls within this scope.
The Commission has established threshold values for each PFAS category (25 ppb, 250 ppb and 50 ppm, depending on the type of PFAS), but the large number of PFAS variants makes this complex. Furthermore, the Commission has not yet determined how PFAS should be measured. This makes it difficult for producers to assess their PFAS performance. Recently, the Commission approved the test proposal from RISE; formal validation and publication are still pending.
Our manufacturing partner does not add PFAS during the production of paper or corrugated board. Suppliers confirm the same approach. The same applies to bisphenol A & B: these substances are not added during the production process. They conduct PFAS analyses every two years on selected categories through the ISO-certified laboratory Eurofins (17025 & 22000). The results remain consistently below the PPWR thresholds. New tests will be carried out in summer 2026.
Extended Producer Responsibility (EPR)
EPR makes producers fully financially and organisationally responsible for the management of packaging waste, including the costs of collection, sorting and recycling. PPWR requires eco-modulated fees based on recyclability and requires registration and detailed reporting in each Member State. The regulation takes effect from August 2026; the first reporting is scheduled for August 2027.
Some countries already comply with EPR through a PRO (Producer Responsibility Organisation). Our manufacturing partner is a member of PROs in most countries where it operates (including Norway, Sweden, Denmark, Belgium, Ireland, Germany, Romania, Italy, Hungary, the Netherlands, etc.). The Danish government has established a separate system; our partners have adapted to this. CRT will be compliant by August 2026.
Standard corrugated board manufacturers must report EPR data when they are considered producers under PPWR. Responsibility depends on three scenarios:
- The producer is located in the same Member State where the packaging becomes waste: the producer reports.
- The producer is not located in that Member State: another company (distributor, importer, unpacker) becomes responsible.
- Online sales to end consumers: the placing on the market takes place in the Member State where the end user is located.
- CRT will support customers by providing all required data (weight, recyclability, recycled content, etc.).
Alignment of Packaging Design with PPWR: Recyclability, Reuse, Labelling and Minimisation
Recyclability
Corrugated board must be fully recyclable by 2030 and comply with the assessment criteria being developed through secondary legislation.
Minimisation & Empty Space
PPWR encourages packaging design that minimises material use. Transport, grouped and e-commerce packaging may contain a maximum of 50% empty space from 2030. Sales packaging must comply with this 50% rule from 2028. This has been integrated into our design process with customers.
Reuse
Corrugated cardboard boxes are exempt. Other transport packaging is subject to the reuse targets. By 2030, pallets must be reused (e.g. through pooling or return systems). Straps and wraps are exempt.
Labelling
From 12 August 2028, all packaging that reaches the end customer must carry a specific, defined label containing information about recyclability, Substances of Concern, composability and other requirements.