PPWR – what is it and what does it mean for packaging?

What is PPWR? PPWR in the context of paper bags

PPWR, that is Packaging and Packaging Waste Regulation, is Regulation (EU) 2025/40 on packaging and packaging waste. It entered into force on February 11, 2025, and its provisions are generally applicable from August 12, 2026. The regulation covers the entire packaging life cycle and is important, among others: for producers, importers, distributors and companies using packaging, including paper bags.

Table of Contents

1. What is PPWR?
2. Legal basis and terms of application
3. Purpose of the PPWR Regulation
4. Paper bags as packaging within the meaning of the PPWR
5. Substances in packaging – Art. 5 PPWR
6. Recyclability of packaging – art. 6 PPWR
7. Recyclate content – Art. 7 PPWR
8. Packaging Minimization – Art. 10 PPWR
9. Reusable packaging – art. 11 PPWR
10. Packaging labeling – Art. 12 PPWR
11. Void Space and Excessive Packaging – Art. 24 PPWR
12. Conclusions for paper bag manufacturers

1. What is PPWR?

PPWR is an abbreviation of Packaging and Packaging Waste Regulation, i.e. the regulation on packaging and packaging waste. The full name of the legal act is: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste.

The Regulation replaces the existing Directive 94/62/EC. This is a very important change because the directive required implementation into national law, while the regulation is directly applicable in all European Union member states. This means greater uniformity of regulations and less possibility of differences in interpretation between individual countries.

2. Legal basis and terms of application

PPWR was published as Regulation (EU) 2025/40. According to information from the European Commission, the regulation has entered into force February 11, 2025, and its provisions will, in principle, be applied from August 12, 2026.

However, later cut-off dates are particularly important for the packaging industry. One of the key dates is January 1, 2030when packaging placed on the EU market is required to meet design for recycling requirements. The next stage will be a year 2035, when not only the theoretical possibility of recycling will be important, but also recycling carried out on an appropriate scale.

3. Purpose of the PPWR Regulation

The main goal of PPWR is to reduce the amount of packaging waste and move to a circular economy model. The European Union wants packaging to be designed in such a way that it can be reused, recycled or reduces its impact on the environment.

In practice, the PPWR shifts the focus from the actual waste management stage to the packaging design stage. This means that the manufacturer of a paper bag should already take into account during the product design phase: the type of paper, grammage, inks, adhesives, handles, laminates, finishes, and the possibility of actual recycling of the finished packaging.

4. Paper bags as packaging under the PPWR

A paper bag It is considered packaging if it serves to store, protect, present, deliver, or carry a product. This means that typical printed paper bags, promotional bags, shopping bags, event bags, premium bags, and e-commerce bags will fall within the scope of the PPWR.

From the point of view of a paper bag manufacturer, the most important thing is that the PPWR does not prohibit the use of paper as a packaging material. On the contrary, paper may gain importance as a material that is easier to recycle than many plastics. However, this does not mean complete freedom. A paper bag with laminate, foil, metalization, a plastic handle or a difficult barrier coating may be assessed completely differently than a simple mono-material bag made of paper.

5. Substances in packaging – Art. 5 PPWR

Art. 5 PPWR addresses requirements related to substances present in packaging. This provision includes, among others: restrictions on heavy metals such as lead, cadmium, mercury and hexavalent chromium. Industry materials also point to the importance of PFAS restrictions, especially in relation to packaging that comes into contact with food.

For paper bag manufacturers art. 5 is especially important when the bags are intended for gastronomy, bakeries, confectioneries, cafes, food producers or brands packaging food products. Some grease-resistant coatings, barrier varnishes, impregnations, adhesives or chemical additives used in paper may be a problem.

In practice, a paper bag manufacturer should obtain declarations from suppliers regarding paper, paints, adhesives, varnishes and possible coatings. Simply saying that the bag is "paper" may not be enough. It will be crucial to confirm that all packaging meets the requirements for hazardous substances.

6. Recyclability of packaging – art. 6 PPWR

One of the most important regulations for the paper bag market is art. 6 PPWR, regarding the recyclability of packaging. Under this approach, packaging placed on the EU market is to be designed to be materially recyclable.

From January 1, 2030 packaging must meet the criteria of design for recycling, i.e. the so-called Design for Recycling. In practice, this means that a paper bag should be designed so that its material can be recovered and used as a secondary raw material.

Paper bag manufacturers will find particularly advantageous structures:

• made mainly of one material, paper,
• without foil laminate,
• without metallization,
• with paper handle,
• with limited painting surface,
• with paints and adhesives that do not hinder recycling.

The biggest challenge will be premium bags: laminated, refined, with soft touch foil, hot-stamping, UV varnish or plastic elements. Such packaging may require additional assessment, documentation or design changes.

7. Recyclate content – Art. 7 PPWR

Art. 7 PPWR refers to minimum recycled content. This provision is of greatest importance for plastic packaging. For paper bags, recyclate obligations will typically be less direct than for plastic packaging.

However, this does not mean that the topic of recyclate can be ignored. Business customers are increasingly asking whether a paper bag contains recycled fibers, whether the paper is FSC, PEFC certified or other confirmation of the origin of the raw material. Therefore, it is worth preparing separate product lines: kraft paper, recycled paper, certified paper and paper without laminate as a variant recommended for environmental requirements.

8. Minimization of packaging – art. 10 PPWR

Art. 10 PPWR introduces the principle of packaging minimization. The packaging should be designed so that its weight, volume and number of layers are limited to the minimum necessary to ensure the function of the packaging. This function may be product protection, transportation, hygiene, safety, user information or required durability.

For paper bag manufacturers, this means the need to rationally select the paper weight, bag size, type of bottom, reinforcements and handle. In practice, you should not design a bag larger, heavier or more complex than justified by the customer's needs.

Example: if a product requires a bag with standard carrying capacity, using very high-weight paper solely to achieve a "more luxurious" effect may require justification. Similarly, bags with additional layers, double walls, or unnecessary reinforcements may be assessed as not complying with the idea of minimization.

9. Reusable packaging — Art. 11 PPWR

Art. 11 PPWR refers to reusable packaging. In the case of standard paper bags, this regulation will not always apply directly, as many paper bags are designed as single-use or short-term packaging.

Despite this, the market may start expecting stronger paper bags from manufacturers, which the customer will use more than once. This may particularly apply to premium bags, bags for boutiques, clothing brands, trade fairs, conferences, and promotional events.

However, it is important not to overuse the term "reusable." If a bag is to be communicated as such, it should be sufficiently durable, designed for repeated use, and meet the system requirements provided for reusable packaging.

10. Packaging labeling — Art. 12 PPWR

Art. 12 PPWR concerns packaging labeling. The purpose of the new requirements is to facilitate the end user in correctly sorting packaging waste. In the future, the markings are intended to be more uniform throughout the European Union.

For paper bags, this means the need to prepare clear information about the material and how to handle waste. Examples of messages that may appear on bags include:

• "Paper packaging",
• "Discard into paper bin",
• "Recyclable",
• "Remove non-paper items before discarding" – if any.

Be careful with broad marketing claims such as “100% eco-friendly”, “completely environmentally neutral” or “fully biodegradable” when the manufacturer has no documentation to support them. PPWR is part of a wider trend towards restricting greenwashing.

11. Void Space and Excessive Packaging – Art. 24 PPWR

Art. 24 PPWR concerns excessive packaging and empty space. This is particularly important for e-commerce, transport and grouped packaging. European Commission materials indicate that the empty-space ratio is to be limited for certain packaging categories.

For paper bags, this provision is particularly relevant when the bag forms part of a shipment, a gift set or sales packaging that is much larger than the product. Even if a bag mainly serves an advertising purpose, its size should still be reasonably matched to the product.

For manufacturers, this means that the offer is worth promoting the selection of the bag format for actual use. An oversized bag, chosen purely for image reasons, may be harder to justify in the future.

12. Conclusions for paper bag manufacturers

PPWR is not a threat to the paper bag market itself. On the contrary, it may offer a major opportunity for manufacturers whose paper packaging is easy to recycle, properly documented and designed in accordance with the principle of minimisation.

Paper bags will be the safest in terms of regulations:

• without laminate,
• without plastic elements,
• with paper handle,
• with limited refinement,
• made of recyclable paper,
• with documentation from raw material suppliers.

The greatest attention is required for laminated and metallised bags, bags with barrier coatings or special varnishes, bags with handles made from other materials, and bags intended for food contact. These cases may require additional technical documentation and confirmation that the materials comply with PPWR requirements.

From a sales strategy perspective, paper bag manufacturers should already be preparing an offer identified as the recommended option for PPWR. In practice, this may mean a separate product category: laminate-free paper bags, mono-material, with paper handle, easier to recycle.

PPWR is changing the packaging market from one driven mainly by price and appearance into one that also depends on regulatory compliance, documentation and actual recyclability. Companies that adapt their products early enough may gain a significant competitive advantage.

Sources and further verification

• Regulation (EU) 2025/40 of the European Parliament and of the Council – EUR-Lex.
• European Commission Guidelines for the Application of PPWR (2026) – EUR-Lex.
• European Commission: new rules to apply from 12 August 2026..