09. 04. 2026
The Packaging and Packaging Waste Regulation (EU) 2025/40 introduces harmonised labelling requirements for all packaging placed on the EU market, with full implementation from 18 August 2028. Non-food packaging buyers must prepare for three mandatory label elements: material composition marking, recycling instruction pictograms, and waste stream identification symbols. Brand owners placing packaging on multiple national markets face a transition from fragmented national labelling schemes to a single EU-wide system, affecting procurement specifications, artwork approval processes, and supplier qualification criteria.
Regulation (EU) 2025/40 establishes the first EU-wide harmonised labelling system for packaging, replacing the current patchwork of national schemes. The regulation applies to all packaging placed on the EU market, including non-food categories such as cosmetics, electronics, audio equipment, fashion accessories, fragrance, wine and spirits secondary packaging, e-commerce protective packaging, and industrial components.
The labelling framework comprises three mandatory elements. Material composition marking identifies the primary packaging material using standardised abbreviations defined in the regulation's annexes. For fibre-based packaging including molded fibre, the marking uses PAP (paper and board) codes. Recycling instruction pictograms communicate disposal actions to end users through standardised symbols developed by CEN (European Committee for Standardization). Waste stream identification indicates whether packaging should enter household recycling, commercial waste streams, or return systems.
Implementation follows a staged timeline. By 18 August 2026, the European Commission must adopt delegated acts specifying detailed labelling formats, symbol designs, and minimum dimensions. Member states transpose these requirements into national law by 18 February 2027. Full compliance becomes mandatory for all packaging placed on the market from 18 August 2028. Packaging already in distribution channels before this date may be sold until stocks are exhausted, but new production runs must comply from the implementation date.
The regulation distinguishes between consumer-facing labels (visible at point of sale) and supply-chain labels (visible only during logistics and warehousing). Consumer-facing labels must meet minimum legibility requirements for character height, contrast ratio, and durability. Supply-chain labels may use simplified formats or digital identifiers. Non-food packaging typically requires consumer-facing labels, as most formats reach end users.
Label durability requirements align with packaging lifecycle. Labels must remain legible through normal handling, storage, and transport conditions without detaching or fading. For molded fibre packaging, this typically means integrated labelling methods rather than adhesive stickers. Acceptable integration methods include hot-foil stamping, flexographic printing, offset printing, and embossing. Digital printing on molded fibre requires UV-resistant inks to maintain legibility under warehouse and retail lighting conditions.
Procurement teams must update packaging specifications to include harmonised labelling requirements in supplier contracts issued after 18 February 2027. This affects three procurement workstreams: artwork specification, supplier qualification, and compliance verification.
Artwork specifications require explicit labelling zones for the three mandatory elements. For molded fibre packaging, buyers should allocate flat surface areas minimum 20 mm × 20 mm for pictogram placement and minimum 1 mm character height for material codes. Curved or textured surfaces reduce legibility, so flat zones must be identified during tooling design. Buyers procuring packaging for multiple EU markets benefit from harmonised labels by eliminating separate artwork variants for different national markets, reducing SKU proliferation and simplifying inventory management.
Supplier qualification criteria must verify labelling capability. For molded fibre suppliers, this means confirming in-house printing equipment can produce durable labels meeting legibility standards, or validating partnerships with approved label application contractors. Buyers should request sample labels demonstrating durability under simulated distribution conditions, including abrasion resistance testing and lightfastness validation per ISO 12040.
Compliance verification requires documented evidence that applied labels match PPWR requirements. Suppliers must provide label artwork approvals, material composition declarations (confirming PAP classification for fibre-based packaging), and recyclability verification per EN 13430. For molded fibre packaging containing coatings or barrier layers, suppliers must demonstrate that label printing inks and applied labels do not compromise the >70% recyclability threshold mandated by PPWR from 1 January 2030.
TRIDAS integrates labelling capability into molded fibre tooling design, allocating flat surface zones for harmonised PPWR labels during the tooling specification phase. Both wet press and dry press production technologies accommodate in-line printing or post-press label application. TRIDAS sources pulp primarily from EU low-risk regions and provides EUDR-compliant Due Diligence Statements per shipment under Regulation (EU) 2023/1115, supporting buyers' parallel compliance workstreams under both PPWR and EUDR. The facility in Valašské Meziříčí operates dedicated black molded fibre production lines launched in 2026, enabling label contrast optimisation for white or metallic print on black substrates.
