Preparing for (EU) 2025/40: Strategic Packaging Adaptation for Global Retail and Foodservice Brands

If you’re exporting packaging to Europe, one of the most important questions you can ask your supplier right now is not simply: “What material should we switch to?”

A material change alone will not guarantee compliance with the EU Packaging and Packaging Waste Regulation (PPWR). What matters is whether your packaging meets the applicable requirements and whether you can provide the technical documentation to demonstrate it.

Regulation (EU) 2025/40 is already applicable as of August 12, 2026. Its requirements cover packaging design, recyclability, substance restrictions, recycled content, packaging minimization, labeling, and producer responsibilities. Some requirements apply now, while others will be introduced progressively through 2030 and beyond.

For brands, importers, distributors, and packaging procurement teams, waiting until 2029 to prepare is a risky strategy. Material selection, product redesign, supplier qualification, testing, and documentation all take time.

Here are five areas European packaging buyers should be reviewing with their suppliers today.

1. Packaging Design: Recyclability Is Becoming a Market Access Requirement

One of the most significant changes under PPWR concerns packaging recyclability.

Under Article 6, all packaging placed on the EU market must be recyclable. From 2030, packaging recyclability will be assessed through performance grades A, B, and C, based on design-for-recycling criteria. Packaging must achieve at least Grade C, corresponding to a recyclability performance of 70%, to meet the applicable threshold.

This is not simply a matter of choosing paper instead of plastic. Packaging structure, material combinations, coatings, adhesives, printing inks, and the separability of components can all influence recyclability.

For paper packaging manufacturers and buyers, this means reviewing the complete packaging construction rather than evaluating the main material alone.

Consider common packaging design decisions:

• Excessive Material Use: Oversized boxes, unnecessary inserts, and decorative layers can increase material consumption and packaging waste.
• Mixed Materials: Combining paper with non-separable plastic or metal components may complicate sorting and recycling.
• Surface Treatments: Certain coatings, laminations, and finishing processes may affect the recyclability of paper-based packaging.
• Packaging Structure: Structural design should balance product protection, presentation, material efficiency, and end-of-life considerations.

Brands should bring marketing, product development, and compliance teams into the same discussion. A premium appearance is still important, but packaging design must also account for its environmental and regulatory performance.

2. Annex V: Prepare for Restrictions on Specific Single-Use Packaging Formats

Another important part of PPWR is Article 25 and Annex V, which introduce restrictions on specific packaging formats and applications from January 1, 2030.

The listed formats include certain single-use plastic packaging used for grouped products, certain plastic packaging for fresh fruit and vegetables below 1.5 kg, and certain single-use plastic packaging used for food and beverages filled and consumed within premises.

These restrictions are specific to the formats and uses identified in Annex V. They should not be interpreted as a blanket ban on all plastic packaging or every food-service container.

For quick-service restaurants (QSRs), food retailers, and hospitality businesses, the practical challenge is understanding how packaging is used in different sales channels.

For example, packaging used for takeaway orders may be treated differently from packaging used for food and beverages consumed on the premises. Procurement teams should therefore review packaging formats against their actual applications rather than assume that one packaging specification works for every channel.

Before 2030, businesses should:

• Identify packaging formats that may fall within Annex V.
• Review the intended use of each packaging item.
• Check applicable exemptions and special conditions.
• Evaluate alternative packaging designs and materials.
• Coordinate packaging specifications across dine-in, takeaway, and retail operations.

Early evaluation gives businesses more time to test alternatives without disrupting their supply chains.

3. Documentation and Traceability: Can Your Supplier Prove What They Sell?

A fournisseur d'emballages en papier‘s sustainability claims are only useful when they can be supported by reliable evidence.

PPWR introduces requirements for technical documentation and an EU Declaration of Conformity. Depending on the applicable requirements and the role of each economic operator, manufacturers and importers need to establish appropriate documentation demonstrating that packaging meets the relevant regulatory requirements.

This makes supplier documentation an important part of packaging procurement.

For paper-based packaging, buyers may also have additional requirements concerning recycled fibre content, responsible sourcing, and forest certification.

Consider a supplier claiming that its paper bags contain 65% post-consumer recycled (PCR) fibre.

Instead of relying on a general marketing statement, ask:

• Can the supplier provide documentation supporting the claimed PCR content?
• Can the material composition be traced to the relevant production batch?
• Are supplier declarations and purchasing records available?
• If FSC-certified material is specified, does the FSC Chain of Custody certificate cover the relevant company, site, and product scope?
• Can the supplier provide applicable test reports and material specifications?

It is important to distinguish between these documents. FSC Chain of Custody certification supports the traceability of eligible certified forest-based materials. It does not, by itself, verify the PCR percentage of a paper product.

Likewise, PCR documentation and FSC certification should not be presented as universal PPWR requirements for every paper package. They are important procurement and sustainability verification tools when applicable to the buyer’s specifications.

A more effective procurement process should request relevant documentation before production begins, not after the goods have been manufactured.

4. Why Manufacturing Capability Matters More Than a Sustainability Brochure

Many packaging factories describe their products as environmentally friendly or PPWR-ready. However, a sustainability statement is not a substitute for production control, material traceability, testing, and technical documentation.

European buyers should look beyond product samples and unit prices when evaluating a packaging manufacturer.

A capable supplier should be able to discuss:

• Material Sourcing: The origin, specifications, and supporting documentation of paper and other packaging materials.
• Production Traceability: Records connecting incoming materials with production batches and finished products.
• Contrôle de la qualité : Inspection procedures for dimensions, appearance, printing, strength, and other relevant product characteristics.
• Testing Capability: Access to suitable laboratory testing and technical evaluation.
• Compliance Documentation: Support in preparing material declarations, test reports, and other relevant technical information.

For brands importing packaging into the EU, the ability to retrieve accurate production and material records can make supplier communication and compliance assessments much more efficient.

This is where manufacturing infrastructure becomes a competitive advantage.

5. Why Fujian Nanwang Is a Relevant Packaging Manufacturing Partner

Fujian Nanwang Environment Protection Scien-tech Co., Ltd. (Stock Code: 301355) focuses on paper-based packaging and environmentally oriented packaging manufacturing.

According to the company’s reported production and certification information, by the end of 2025, five of its domestic factories had obtained FSC Chain of Custody (FSC-COC) certification.

During 2025, the company used approximately:

Production and Material Indicator	Reported Figure
FSC-certified base paper consumption	21,000 tonnes
Regenerated kraft paper consumption	14,000 tonnes
Eco-friendly adhesives	Over 80%
Eco-friendly printing inks	Over 90%

These figures reflect the company’s reported material sourcing and production practices. They provide useful background for buyers evaluating its manufacturing scale and material management capabilities.

Nanwang also operates a CNAS-accredited laboratory, providing testing support for relevant product and material evaluations.

For European brands and packaging buyers, these capabilities can support supplier qualification, material verification, and the preparation of documentation required by individual customer specifications.

However, PPWR compliance must always be assessed against the specific packaging product, its intended use, applicable regulatory requirements, and the documentation available for that product. No factory certification or general sustainability claim automatically makes every packaging item compliant.

When evaluating a packaging supplier, buyers should ask not only what materials the factory uses, but also what evidence it can provide for the finished packaging.

6. What European Buyers Should Include in Their Packaging Procurement Checklist

Preparing for PPWR requires cooperation between packaging buyers, manufacturers, and compliance teams.

Before confirming a new packaging order, consider the following checklist:

Procurement Area	Questions to Ask Your Supplier
Material Specifications	What materials, coatings, adhesives, and printing inks are used?
Recyclabilité	Has the packaging structure been evaluated for relevant recyclability requirements?
Teneur en matériaux recyclés	Can the supplier substantiate any claimed recycled material percentage?
FSC Certification	Is the relevant factory and product within the certificate’s scope?
Chemical Compliance	Are applicable substance restrictions and declarations addressed?
Quality Testing	Are relevant material and finished-product test reports available?
Production Traceability	Can material and production records be linked to the relevant batches?
Technical Documentation	Can the supplier provide information needed for the applicable technical file and conformity assessment?
Packaging Design	Can the structure be adjusted to reduce unnecessary material and improve recyclability?

The sooner these questions are included in supplier evaluation, the easier it becomes to identify documentation gaps and redesign requirements before they affect commercial orders.

Conclusion: Build Your PPWR Supply Chain Before the Next Deadline

PPWR is changing how packaging manufacturers, importers, and brands approach the European market.

The challenge is no longer limited to finding an alternative material. Businesses need to consider recyclability, packaging design, substance restrictions, recycled content where applicable, production traceability, and technical documentation as part of a broader procurement strategy.

For European buyers, choosing a packaging supplier should involve more than comparing prices and reviewing samples. Manufacturing capability, material sourcing transparency, quality control, and access to reliable documentation are equally important.

Fujian Nanwang Environment Protection Scien-tech Co., Ltd. combines paper-based packaging manufacturing, certified material sourcing, production management, and laboratory testing capabilities to support customers developing packaging solutions for international markets.

Don’t wait until your next packaging audit to discover what your supplier cannot prove.

Contact our team to discuss paper packaging specifications, material traceability, custom manufacturing, and documentation support for your European packaging projects.