Two European Union regulations enter force in the second half of 2026 that fundamentally change procurement criteria for non-food packaging buyers: the Packaging and Packaging Waste Regulation (PPWR) applies from 12 August 2026 under Regulation (EU) 2025/40, and the EU Deforestation Regulation (EUDR) applies from 30 December 2026 under Regulation (EU) 2023/1115. Both regulations impose new compliance obligations on brands placing packaging on the EU market, requiring verifiable recyclability performance documentation, supplier due diligence statements tracing fibre origin, and new design restrictions that eliminate waste at source.
The Packaging and Packaging Waste Regulation (PPWR) replaces the 1994 Packaging and Packaging Waste Directive with a single EU regulation that applies directly in all member states without national transposition. PPWR establishes legally binding recyclability targets: fibre-based packaging must achieve at least 70 per cent recyclability by 2030 and 80 per cent by 2038, measured under EN 13430 methodology. Packaging that fails to meet these thresholds cannot be placed on the EU market after the respective deadline dates. PPWR also introduces design-for-recycling requirements that prohibit certain material combinations, limit empty space in transport packaging, and mandate recycled content in specific packaging categories.
The EU Deforestation Regulation (EUDR) prohibits placing products containing forest-risk commodities on the EU market unless operators can demonstrate the raw material was not sourced from land deforested or forest-degraded after 31 December 2020. For pulp and paper used in molded fibre packaging, this means every shipment entering the EU must be accompanied by a Due Diligence Statement containing geolocation coordinates of harvest plots, legality documentation proving compliance with the laws of the country of harvest, and a risk assessment classifying the supply chain as negligible, low, or standard risk. The regulation applies to both virgin fibre and recycled fibre when the recycled content includes post-consumer material that re-entered the supply chain after 29 June 2023.
PPWR creates a tiered recyclability classification system with grades A through E. Grade A represents packaging that meets the highest recyclability standards under EN 13430 and qualifies for reduced Extended Producer Responsibility (EPR) fees, while Grade E indicates packaging that fails minimum recyclability thresholds and may face market restrictions or higher fees. Member states must modulate EPR fees according to these grades by 2028, creating direct financial incentives for procurement teams to specify higher-performance packaging materials. Molded fibre packaging produced from single-material pulp without plastic coatings or laminations typically qualifies for Grade A or B classification, provided the design avoids features that contaminate paper recycling streams.
PPWR empty space restrictions target protective packaging used in e-commerce and consumer electronics shipments. From 2030, the ratio of empty space to product volume in transport packaging must not exceed 40 per cent, forcing brands to redesign protective inserts that currently use air cushions or oversized cavities. Molded fibre protective packaging allows tighter product nesting through custom-tooled cavity geometry, enabling compliance while maintaining drop-test performance under ISTA 2A and ISTA 3A protocols. This design constraint applies to the complete packaging system — outer carton, protective insert, and product — not to individual components in isolation.
EUDR compliance depends on verified traceability back to forest harvest location. For virgin pulp, this requires geolocation data at plot level (latitude and longitude coordinates with at least four decimal places). For recycled pulp, the regulation exempts pre-consumer waste but includes post-consumer recovered paper when that material re-entered circulation after the June 2023 cut-off date. Most molded fibre suppliers cannot yet provide plot-level geolocation for recycled content streams because waste paper aggregates material from thousands of collection points across multiple regions. FSC chain-of-custody certification provides partial compliance support by documenting legal harvest and sustainable forest management, but it does not replace the EUDR Due Diligence Statement requirement.
PPWR labelling requirements mandate harmonised material identification symbols on all packaging by 2028, enabling consumers and waste management operators to correctly sort packaging at end of life. These labels must appear directly on the packaging surface or on an inseparable component, not solely on outer shipping cartons that are discarded before consumer use. For molded fibre packaging serving as primary or secondary packaging for cosmetics, consumer electronics, or fashion accessories, this means the label must be printed, embossed, or applied as a permanent marking on the molded component itself. The European Commission will publish detailed labelling specifications in delegated acts expected during 2027.
Corporate Sustainability Reporting Directive (CSRD) requirements intersect with PPWR compliance obligations for large companies and listed SMEs. Under CSRD, brands must report packaging material composition, recyclability performance, and waste generation data within their annual sustainability statement using European Sustainability Reporting Standards (ESRS). This reporting must include packaging-level disclosure showing the mass of packaging placed on the market by material type and recyclability grade, creating new documentation requirements for procurement teams. Suppliers unable to provide EN 13430 test reports, EPR fee classification letters, or EUDR Due Diligence Statements block the buyer's ability to complete mandatory CSRD disclosures, shifting supplier selection criteria toward documentation capability alongside technical performance.
| Regulatory aspect | Previous framework (Directive 94/62/EC) | PPWR + EUDR (2026 onwards) |
|---|---|---|
| Legal instrument | Directive requiring national transposition | Regulation with direct effect in all member states |
| Recyclability | Voluntary design guidelines | Legally binding targets (≥70% by 2030, ≥80% by 2038) |
| Traceability | Not required | Geolocation to harvest plot + legality documentation mandatory |
| EPR fees | Modulation optional for member states | Mandatory fee modulation by recyclability grade from 2028 |
| Empty space | No restriction | Maximum 40% empty space in transport packaging from 2030 |
| Labelling | National schemes vary by country | Harmonised EU-wide labelling from 2028 |
| Supplier documentation | General Declaration of Conformity | EN 13430 test reports + EUDR Due Diligence Statement per shipment |
Procurement teams specifying packaging for cosmetics, consumer electronics, audio equipment, fashion accessories, and wine and spirits secondary packaging must now verify supplier compliance capability as part of the qualification process. This verification extends beyond requesting certifications to auditing the supplier's ability to deliver three critical documents: EN 13430 recyclability test reports demonstrating performance above the 70 per cent threshold, EUDR Due Diligence Statements containing geolocation and legality proof, and EPR classification letters assigning the packaging to a specific recyclability grade under the member state's fee schedule. Suppliers unable to provide these documents in the required format create compliance risk that transfers directly to the brand as the operator placing the packaging on the market.
The economic impact of PPWR compliance manifests through EPR fee structures. Packaging classified as Grade A or B under the recyclability assessment benefits from reduced fees, while Grade D and E packaging faces premium rates that can exceed baseline fees by 20-30 per cent in member states that have published initial modulation schedules. For brands placing significant packaging volumes on multiple national markets, the cumulative EPR cost difference between high-recyclability and low-recyclability materials can reach six-figure annual amounts. Molded fibre packaging produced as single-material pulp without plastic coatings qualifies for favourable EPR treatment, but only when the supplier provides documentary evidence of recyclability performance in the form of an accredited test report following EN 13430 methodology.
EUDR risk assessment introduces supply chain complexity that many packaging buyers have not previously managed. The regulation classifies countries and regions into risk categories, with EU member states designated as low-risk and certain non-EU regions classified as standard-risk requiring enhanced due diligence. Pulp sourced from EU forests simplifies compliance because the risk assessment can rely on existing EU legal frameworks, while pulp sourced from non-EU regions requires additional legality verification and increases the administrative burden per shipment. Brands sourcing molded fibre packaging should evaluate supplier pulp origin as part of the RFQ process, prioritising suppliers that source primarily from EU low-risk regions or that have already implemented plot-level traceability systems for non-EU virgin fibre.
The 2030 empty space restriction requires design intervention now for packaging programs with long tooling lifecycles. Protective packaging tooling typically remains in service for 5-7 years before wear or product redesigns force replacement. Tooling commissioned in 2026 will still be in use when the empty space rule takes effect in 2030, meaning procurement teams must specify PPWR-compliant cavity geometry immediately to avoid mid-lifecycle tooling write-offs. This design constraint favours molded fibre over expanded polystyrene or polyethylene foam because fibre tooling can incorporate tighter nesting features, ribs, and corner reinforcements that reduce void space while maintaining structural performance under ISTA testing protocols. The compliance calculation includes the complete packaging system, so optimising the protective insert alone may not achieve compliance if the outer carton remains oversized relative to the product dimensions.
TRIDAS sources pulp primarily from EU low-risk regions and provides EUDR-compliant Due Diligence Statements per shipment under Regulation (EU) 2023/1115, simplifying customer compliance programs compared to suppliers relying on non-EU virgin fibre or recycled content streams lacking traceability documentation. The company's FSC chain-of-custody certification supports legality verification within the Due Diligence Statement but does not replace the geolocation and risk assessment components that EUDR mandates. TRIDAS operates both wet press and dry press molded fibre production technologies under one roof, enabling technology selection based on whether the application prioritises premium surface finish for cosmetics and consumer electronics packaging or higher impact absorption for protective inserts meeting ISTA 3A requirements under the PPWR empty space constraint. In-house tooling design and manufacture delivers typical tooling lead times of approximately four weeks from order, substantially shorter than market-average 12-plus-week lead times, allowing faster design iteration when packaging programs require geometry changes to meet the 40 per cent empty space threshold before the 2030 deadline.
PPWR applies from 12 August 2026 under Regulation (EU) 2025/40. EUDR applies from 30 December 2026 under Regulation (EU) 2023/1115. Packaging placed on the EU market after these dates must comply with all applicable requirements, including traceability documentation and recyclability thresholds where specified. Some PPWR provisions phase in later: the 70 per cent recyclability target for fibre-based packaging takes effect in 2030, EPR fee modulation by recyclability grade becomes mandatory in 2028, and harmonised labelling requirements also apply from 2028.
Fibre-based packaging must achieve at least 70 per cent recyclability by 2030 and 80 per cent by 2038, measured under EN 13430 methodology. These are minimum legal thresholds; packaging failing to meet them cannot be placed on the EU market after the respective deadline. Higher recyclability performance within these thresholds determines EPR fee classification, with Grade A packaging qualifying for reduced fees. Single-material molded fibre without plastic coatings or laminations typically exceeds the 70 per cent threshold, but formal EN 13430 testing is required to document compliance.
EUDR applies to both virgin and recycled fibre when the recycled content includes post-consumer material that re-entered the supply chain after 29 June 2023. Pre-consumer waste recovered during manufacturing before first commercial sale is exempt. For most molded fibre suppliers using post-consumer recycled content, geolocation back to harvest plot is not feasible because waste paper aggregates material from thousands of collection points. Virgin fibre sourced from EU low-risk regions or from suppliers with plot-level traceability systems offers more straightforward EUDR compliance paths for packaging buyers.
From 2030, transport packaging must not contain more than 40 per cent empty space relative to product volume. This rule applies to e-commerce shipments, consumer electronics packaging, and other transport packaging where protective inserts create void space around the product. The compliance calculation includes the complete packaging system — outer carton, protective insert, and product — not individual components in isolation. Molded fibre protective inserts allow tighter product nesting through custom cavity geometry, enabling compliance while maintaining drop-test performance under ISTA protocols.
Suppliers must provide three critical documents: an EN 13430 recyclability test report from an accredited laboratory demonstrating performance above the 70 per cent threshold, an EPR classification letter assigning the packaging to a recyclability grade (A through E) under the member state fee schedule, and technical specifications showing cavity geometry and material thickness for empty space calculations. If your company is subject to CSRD reporting, you will also need mass data showing packaging placed on the market by material type and recyclability grade to complete annual sustainability disclosures under ESRS.
The EUDR Due Diligence Statement is a document required per shipment that contains geolocation coordinates of harvest plots (latitude and longitude with at least four decimal places), legality documentation proving compliance with the laws of the country of harvest, and a risk assessment classifying the supply chain as negligible, low, or standard risk. The packaging supplier provides this statement, but the supplier's ability to deliver it depends on pulp traceability upstream. Virgin pulp from EU forests simplifies compliance because EU member states are designated low-risk regions under EUDR. Non-EU virgin pulp requires enhanced due diligence and increases documentation complexity.
FSC chain-of-custody certification documents legal harvest and sustainable forest management, providing supporting evidence for the legality component of the EUDR Due Diligence Statement. However, FSC certification alone does not satisfy EUDR requirements because the regulation additionally mandates geolocation to harvest plot and a formal risk assessment covering deforestation cut-off dates. FSC-certified pulp simplifies the legality verification step within the broader Due Diligence Statement, but it does not replace the geolocation and risk assessment documentation that EUDR requires.
Harmonised labelling requirements apply from 2028. Labels must appear directly on the packaging surface or on an inseparable component, showing material identification symbols that enable consumers and waste management operators to correctly sort packaging at end of life. For molded fibre serving as primary or secondary packaging, this means the label must be printed, embossed, or applied as a permanent marking on the molded component itself, not solely on outer shipping cartons discarded before consumer use. Detailed labelling specifications will be published in European Commission delegated acts expected during 2027.
