PPWR: What the EU regulation means for companies using industrial packaging

Your customers are starting to ask whether you comply with PPWR. Procurement managers are receiving sustainability questionnaires from parent companies about supply chain practices. Certification audits now include questions about packaging materials that weren’t on anyone’s radar two years ago. This EU regulation applies to you – even if you don’t manufacture consumer goods and have never thought of yourself as a “packaging company.”

This article will explain in detail:

• What PPWR specifically requires from industrial companies.
• What it does not require.
• How to answer the most common questions from customers and suppliers about PPWR.

If you’re looking for a definition of PPWR and a general overview of the regulation, you’ll find it in our PPWR glossary entry.

Industrial packaging and PPWR – what to actually focus on

PPWR does not apply to all packaging in the same way. It distinguishes three types – primary, secondary, and tertiary – and sets different obligations with different deadlines for each.

For industrial companies, tertiary packaging is the key priority: transport crates, pallets, grid boxes, KLT and KTP boxes, dividers, and inserts. These are the packaging types that protect goods during transport and handling between plants, warehouses, and customers.

Primary packaging – the kind consumers pick up from a shop shelf – is far less relevant to industrial logistics. If you don’t manufacture packaged consumer goods, you can afford to monitor the labeling and recyclability requirements for primary packaging from a greater distance, at least for now.

Three concrete obligations awaiting industrial companies

1. Void space – An end to oversized packaging

From 1 January 2030, empty space in transport packaging must not exceed 50% of the total volume. PPWR targets situations where a company ships a small component in an enormous box half-filled with air or cheap filler material.

What this means in practice: If your transport packaging has significant void space, you will need to either switch to smaller packaging or invest in filler material that is excluded from the calculation. The most elegant solution is packaging designed precisely to the dimensions of the transported part – eliminating void space through design rather than adding filler.

We explore this topic in greater detail in the article “An Empty Box Full of Problems: What PPWR Says About Unused Space in Packaging“.

2. Reuse – Industrial companies have a head start

PPWR does not require the immediate elimination of all single-use packaging. It does, however, set targets for the share of reusable packaging across different sectors – and industrial companies will not be exempt from these targets.

The good news is that companies already using returnable packaging in a closed logistics loop are naturally well-prepared to meet these requirements. A KLT box system circulating between a plant and its suppliers, or a pooled transport container service – these are precisely the models PPWR aims to support.

If you are still using single-use cardboard packaging for regularly recurring routes, switching to returnable packaging is the most direct path to PPWR compliance.

3. EPR – Extended Producer Responsibility changes the economics of single-use packaging

Companies placing packaging on the market will be required to contribute to Extended Producer Responsibility (EPR) schemes. In simple terms: for every piece of packaging that ends up as waste after use, you will pay a fee into a system that manages its collection and recycling.

For industrial companies, this has a direct financial impact: the cost of single-use packaging will rise as EPR fees become part of its price. Returnable packaging that is not discarded but returned to circulation comes out significantly better – either EPR fees do not apply at all, or they are considerably lower.

What PPWR does not require from industrial companies

A number of concerns about PPWR circulating in the industry are exaggerated or simply inaccurate. Let’s address them:

PPWR does not require the immediate abolition of all single-use packaging. The regulation works with phased targets and transition periods extending to 2040. Companies have time to prepare and transition gradually.

PPWR does not require certification of every individual piece of packaging. There is no such thing as a “PPWR packaging certificate” you would need to show customers. There are declarations of conformity and recyclability documentation – but these apply primarily to packaging manufacturers, not their customers.

PPWR does not apply retroactively to packaging already in circulation. New obligations apply to packaging placed on the market after the regulation’s entry into force.

PPWR is not only about plastic packaging. It covers all materials – cardboard, wood, metal, and plastic. A company that switches from plastic to cardboard on the grounds that “it’s more sustainable” will not necessarily perform better under PPWR – what matters is actual recyclability and void space, not the material itself.

Questions your customers and suppliers are probably asking right now

Procurement managers across Europe are receiving these questions with increasing frequency. Here are direct answers.

“Do you, as a packaging supplier, comply with PPWR requirements?”

The right answer is specific, not vague. State clearly what share of your packaging is reusable, whether you have a packaging tracking system (pool management), and whether your packaging is made from recycled content or is recyclable. Avoid answers like “yes, we’re working on it” – customers want numbers.

“Do you have PPWR compliance documentation?”

This question is aimed more at packaging manufacturers than at their customers. If you are a packaging buyer, ask your supplier for a declaration of recyclability for the material used, the recycled content share in the packaging, and the EPR scheme they contribute to. If your supplier cannot provide this data, that is a signal to reconsider the supplier relationship.

“What share of your transport packaging is reusable?”

This is a number you should know. Review the transport packaging used in regular logistics flows – what percentage of it is returned after delivery? If you don’t know, start tracking. Systems like LemmaTrack allow you to monitor packaging movements in real time and generate these figures automatically.

When to start and how to proceed

PPWR has entered into force, and direct enforceability runs from August 2026. Key milestones – from labeling obligations to void space rules – are summarized in our article PPWR Timeline: Overview of Key Dates and Obligations 2025–2030.

A practical approach for industrial companies looks like this:

1. Packaging portfolio audit – map which packaging you use, in which flows, and what void space it contains.
2. Identify single-use flows – find regular transport routes where you still use cardboard or other single-use packaging.
3. Transition assessment – for each identified flow, evaluate whether switching to returnable packaging makes sense (and when).
4. Documentation – prepare answers to customer and supplier questions before they arrive.

The simplest path to PPWR compliance

Transitioning to a system of returnable industrial packaging in a closed logistics loop is the most direct way for industrial companies to meet the key PPWR requirements in one move – void space is resolved by purpose-built packaging, reuse targets are met by packaging that circulates rather than gets discarded, and EPR costs are minimized because the packaging does not become waste after a single use.