Do now: know what you have
Four steps, no material choices
The PPWR (Packaging and Packaging Waste Regulation) entered into force on 11 February 2025 and has been largely applicable since 12 August 2026; other obligations are being phased in. The current priority is not buying different packaging. It is understanding what you already have — work that will never be wasted, regardless of the final implementation.
Determine your role for each stream. Do you purchase within the EU, import directly or sell under your own brand? The obligations differ, and the role depends on the activity. See roles and responsibilities.
Inventory your packaging. Which boxes, tapes, films and void-fill materials do you use, in what volumes and from which supplier? Begin with the five that have the highest volume or use the most material.
Request the missing data. Material composition, weights and evidence supporting claims. The page on supplier information explains what to ask and why.
Record why your packaging is designed as it is. Stacking height, storage period, climate, transport method and the safety margin you apply. This is your supporting rationale, and recording it takes an hour now but a week later.
Already sensible: benefits you can rely on
Regardless of the final implementation
Some improvements can already be expected to deliver benefits because they save both material and money and do not depend on criteria that have yet to be developed. There are three:
- Address oversizing. Empty space in a box consumes board, void fill, film and loading metres at the same time. The method is described on the page about empty space and box ranges.
- Remove unnecessary material combinations. A window, label or coating that remains although nobody knows why is the easiest kind of improvement.
- Start measuring consumption. Grams of film per pallet and metres of tape per box. Until you have those figures, you cannot demonstrate a reduction — which is precisely what will be expected later.
These three measures have one thing in common: they reduce your costs even if the legislation were to disappear tomorrow. That makes them easy to justify, both internally and externally.
Monitor only: what is still being developed
Know that it is coming, but do not act on it yet
For part of the PPWR, the direction has been established but the method has not. For these subjects, be aware that requirements are coming and monitor developments, but do not yet base decisions on them.
- Design-for-recycling criteria and recyclability performance classes. The direction is clear, but the yardstick is not. See recyclability and packaging design.
- The method for measuring empty space. You can already measure using your own data, but you cannot yet claim a statutory percentage.
- Recycled-content obligations for plastic packaging. The percentages and years are set out in the Regulation, but the category definitions, exemptions and implementing rules determine whether they apply to your packaging. See stretch film and the PPWR.
- Labelling requirements. Which requirements apply and when varies by packaging type and is being phased in. Assess this for each product.
Do not do yet: four costly steps
Work you would have to repeat later
This section is included because most harm in this area is caused not by starting too late, but by doing the wrong thing too early. Four steps currently cost more than they deliver:
- Major material changes based on criteria that have not yet been finalised. Overhauling a range based on an expectation is expensive, and there is a real chance that part of the change will have to be reversed.
- Fixing claims in specifications or print. An environmental claim on a box or product sheet remains visible for years. Do not include anything you cannot substantiate today.
- Forcing suppliers to issue declarations the Regulation does not yet require. This produces meaningless paperwork and consumes goodwill that is better used later to obtain the data you genuinely need.
- Replacing material without analysing damage risk. A lighter box or thinner film that causes breakage or unstable pallets uses more material overall than it saves.
Frequently asked questions about the timeline
Brief, specific answers in plain English
Less serious than it feels, provided you start in the right place. The first step is not a material change but an inventory: which packaging you use, which role you have and which data you already hold. This takes days, not months, and provides the foundation for everything that follows.
No, and doing so would not be sensible. Some criteria are still being developed at European level. It is worthwhile addressing oversizing and unnecessary material combinations, because those benefits remain regardless of the final implementation.
Start with the packaging items that have the highest volume or use the most material. In most businesses, five packaging items account for the majority of packaging weight. They also offer the greatest savings, so your work pays for itself sooner.
Avoid making major material changes based on criteria that have not yet been finalised, fixing environmental claims in specifications or print that you may later have to withdraw, and forcing suppliers to issue declarations that the Regulation does not yet require. This costs money and creates work that must be repeated.
Sources and scope
What this guidance is based on
- EUR-Lex — Regulation (EU) 2025/40 — the text of the Regulation. Opens in a new window.
- RVO — EU legislation: packaging requirements (PPWR) — Dutch government information. Opens in a new window.
- Verpact — About the PPWR — the timeline and implementation in the Netherlands. Opens in a new window.
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