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What Is PPWR? A Practical Packaging Guide for Manufacturers and Exporters to the EU

What Is PPWR? A Practical Packaging Guide for Manufacturers and Exporters to the EU

For companies exporting products to the European Union, or supplying businesses whose products are placed on the EU market, PPWR – the Packaging and Packaging Waste Regulation is becoming increasingly important.

PPWR should not be viewed as a regulation concerning only the “product box.” Companies should consider the Total Packaging System — from packaging directly surrounding the product to inner boxes, shipping cartons, cushioning materials, plastic bags and films, tapes, labels, protective materials, pallets and other transport packaging.

Instead of asking “Is our carton PPWR compliant?”, a more useful question is: “What does our entire packaging system consist of, what materials are used, how much packaging is used, how recyclable is it, are there substances of concern to consider, and where can unnecessary packaging be reduced?”

This guide provides a practical starting point for manufacturers and exporters preparing their packaging systems and data for PPWR.

1. What is PPWR?

PPWR stands for the Packaging and Packaging Waste Regulation, the European Union regulation covering packaging and packaging waste. It replaces the previous Packaging and Packaging Waste Directive (PPWD) framework and introduces a more comprehensive approach to packaging sustainability and circularity.

Important areas include packaging waste prevention, packaging minimisation, design for recyclability, efficient use of materials, recycled content where applicable, reuse requirements for certain packaging categories, restrictions relating to certain substances, labelling, and supporting compliance documentation.

PPWR should therefore not be viewed simply as a requirement to replace one packaging material with another. It encourages companies to look at how packaging is designed, used, documented, recovered and managed throughout its life cycle.

2. Start by Understanding Your Total Packaging

Before reviewing individual requirements, a company first needs to understand what actually constitutes the packaging system for each product.

For example:

Product → Plastic Bag → Inner Box → Cushioning → Master Carton → Tape → Label → Stretch Film → Corner Protection → Pallet

Together, these components form the product’s Total Packaging System.

A common challenge is that companies maintain specifications for their main cartons but have limited information about supporting materials such as tape, labels, adhesives, stretch film, cushioning, strapping and pallets. A practical first step in PPWR preparation is therefore to create a Packaging Material Map.

3. Create a Packaging Bill of Materials (Packaging BOM)

A useful tool for managing packaging information is a Packaging Bill of Materials (Packaging BOM).

Packaging ComponentMaterialWeightQty.
Inner BoxCorrugated Paper250 g1
Master CartonCorrugated Paper650 g1
PE BagLDPE20 g2
CushioningPaper80 g2
TapePlastic / Adhesive15 g1
Stretch FilmPlastic300 g1
PalletWood / Paper / Plastic8 kg1

The company should be able to determine how much packaging is used for each product or shipment, ideally separated by material category such as Paper / Plastic / Wood / Metal / Glass / Composite / Other Materials.

This information provides the foundation for packaging assessment, optimisation and future reporting.

4. Identify Unnecessary Packaging

One important concept under PPWR is Packaging Minimisation. Packaging should use only the amount of material necessary to perform its required functions while maintaining adequate product protection, safety and logistics performance.

Companies should review whether cartons are unnecessarily large, whether there is excessive empty space, whether cushioning is overused, whether material thickness or weight can be reduced, whether packaging layers duplicate the same function, and whether stretch film or other transport materials can be optimised.

However, packaging reduction should never compromise product protection. Effective optimisation requires a balance between Product Protection + Logistics Performance + Material Efficiency.

5. Review Packaging Recyclability

Simply stating that packaging is “made from paper” or “made from plastic” does not provide the complete picture regarding recyclability.

A paper-based package, for example, may also contain plastic lamination, coatings, tape, labels, adhesives, foam, metal staples or other combined materials that can affect sorting and recycling.

Companies should therefore understand what materials are used, whether different materials can be separated, whether coatings or laminations are present, what types of adhesives are used, and how the packaging is expected to enter the relevant recycling stream after use.

6. Chemicals and Substances of Concern

Chemical information is another important area when preparing packaging data. PPWR includes provisions relating to substances of concern in packaging, including requirements concerning certain heavy metals such as Lead (Pb), Cadmium (Cd), Mercury (Hg) and Hexavalent Chromium (Cr VI).

Another topic is PFAS. PPWR introduces specific restrictions concerning PFAS in food-contact packaging, subject to the conditions and thresholds defined by the regulation. This should not be interpreted as meaning that every type of packaging must automatically be tested for PFAS.

The same principle applies when customers ask about substances such as MOSH and MOAH. Laboratory testing should be determined according to the packaging material, application, food-contact status, customer requirements and applicable regulations.

A useful approach is to establish a Chemical Requirement Matrix: Material + Application + Food-Contact Status + Customer Requirement + Destination Market.

7. Not Everything Needs Laboratory Testing

Preparing for PPWR does not necessarily mean sending every packaging component to a laboratory for every possible chemical test. A more systematic approach starts with:

Identify Material → Identify Supplier → Collect Declarations → Review Chemical Risk → Review Legal & Customer Requirements → Determine Testing Requirements

Where reliable material specifications, declarations or relevant test reports are already available, these may form part of the supporting documentation. Additional testing can then be considered where information is insufficient, risks are higher, or a specific requirement calls for it.

This risk-based approach helps avoid unnecessary testing while maintaining appropriate compliance control.

8. What Packaging Documents Should Manufacturers Prepare?

Companies should consider establishing a Packaging Technical File for relevant products or packaging families. Typical information may include:

Packaging Specification – dimensions, weight, materials and construction
Packaging BOM – components and material composition
Material Specifications – technical information from suppliers
Supplier Declarations – material and chemical information
Chemical Compliance Documents – declarations, certificates or test reports where applicable
Recycled Content Information – where relevant
Recyclability Information – supporting recycling assessment
Packaging Weight Records – weight by component and material
Designs / Drawings – structural and technical details
Test Reports – compression, drop, transport or load testing as applicable
Risk Assessment – evaluation of applicable packaging risks and requirements

These records can support PPWR preparation and also make it easier to respond to customer packaging questionnaires.

9. Packaging Suppliers Will Become Increasingly Important

Most manufacturers do not produce every packaging component themselves. The quality of information available from suppliers therefore becomes increasingly important.

Purchasing and QA teams should consider requesting key information such as Material Composition, Material Specification, Packaging Weight, Recycled Content, Chemical Declarations, Relevant Test Reports, Recyclability Information and Change Notification.

Change Notification is particularly important. If a supplier changes the paper grade, plastic resin, printing ink, adhesive, coating or material source, the company should evaluate whether the change affects existing packaging specifications or compliance information.

10. Do Not Forget Ink, Adhesives and Coatings

A Packaging BOM should not simply state “Material: Corrugated Paper” when the actual packaging consists of Paper + Printing Ink + Adhesive + Coating + Tape + Label.

Good packaging data management should consider relevant constituent materials, particularly for printed, coated, laminated or multi-material packaging.

11. Pallets Are Also Part of the Total Packaging System

Transport packaging should also be included in the assessment. This may include pallets, stretch film, strapping, corner boards, top sheets, slip sheets and protective materials.

For example, if a company uses 10,000 pallets per year and each pallet weighs 15 kg, pallets alone represent 150,000 kg of packaging material per year.

Transport packaging can therefore represent a significant opportunity for optimisation. Depending on the application, companies may evaluate wood pallets, plastic pallets, paper pallets, slip sheets or reusable transport packaging. The appropriate solution should always be selected according to actual operational requirements rather than material type alone.

12. Build a Company-Wide Packaging Compliance Matrix

For companies managing many SKUs, a central Packaging Compliance Matrix can make packaging information easier to control.

SKUPackagingMaterialWeightSupplierRecycled ContentChemical DocsRecyclabilityStatus
A001Inner BoxPaper0.20 kgSupplier AAvailableAvailableReviewReview
A001Master CartonCorrugated0.65 kgSupplier BAvailableAvailableReviewReview
A001PE BagLDPE0.02 kgSupplier CReviewAvailableReviewReview
A001PalletPaper/Wood8 kgSupplier DReviewAvailableReviewReview

This makes it easier to identify what information is available, what is missing, which suppliers require follow-up, and which packaging components should be reviewed first.

13. Who Should Be Responsible for PPWR?

PPWR preparation should be a cross-functional responsibility, not a QA-only project. Sales/Customer Service collects customer requirements; R&D or Packaging Engineering manages design and optimisation; Purchasing obtains supplier information; QA/Compliance reviews requirements and evidence; Production and Logistics control actual materials, packing and transportation; and Management sets objectives and resources.

The goal is to create a Packaging Data Management System that allows the company to understand what its packaging consists of, where materials come from, what requirements apply and what evidence is available.

14. A Practical PPWR Packaging Checklist

A company can begin with these questions:

☐ Do we know every packaging component used for each product?
☐ Do we have a Packaging BOM and component weights?
☐ Do we know the material composition and supplier?
☐ Do we have material specifications and relevant declarations?
☐ Do we know which packaging is intended for food contact?
☐ Have relevant chemical risks been assessed?
☐ Do we have recycled-content information where applicable?
☐ Do we have information supporting recyclability?
☐ Can packaging size, weight or unnecessary layers be reduced?
☐ Have pallets, stretch film and other transport packaging been included?
☐ Do suppliers notify us when materials change?

If the answer to many of these questions is “we don’t have the information yet,” the first action may not be laboratory testing. A better starting point is often Packaging Mapping + Supply Chain Data Collection.

15. Summary: Start PPWR Preparation with Data

PPWR is changing the way companies need to think about packaging. The traditional question “How much does this box cost?” is increasingly being joined by questions such as:

What is it made from? How much material does it use? Is all of that material necessary? Can it be reduced? How can it be recycled? Are there substances of concern? Does the supplier have supporting information? Do we have sufficient evidence to answer our customers?

A practical PPWR preparation process can therefore follow:

Packaging Mapping → Packaging BOM → Material & Chemical Data → Risk Assessment → Recyclability Review → Packaging Minimisation → Testing → Documentation → Continuous Improvement

Companies do not necessarily need to redesign all packaging immediately. A good first step is to understand the Total Packaging System, identify information gaps, assess risks and determine where packaging can be improved.

T5 – Packaging Solutions Supporting Your PPWR Preparation

T5 provides industrial packaging solutions with a focus on the Total Packaging System. Our capabilities include corrugated packaging, packaging optimisation, material reduction, transport packaging and paper pallet solutions, depending on product and supply-chain requirements.

For companies preparing for PPWR, T5 can work with your team to develop packaging solutions considering product protection, logistics performance, material efficiency, recyclability and packaging information requirements.

If your company is reviewing packaging for PPWR, reducing packaging materials, improving packaging structures or evaluating alternative transport packaging, contact the T5 Sales Team to discuss your requirements and develop an appropriate packaging solution.

This article provides general information about PPWR and packaging preparation. Specific requirements may vary depending on packaging type, application, material, market and implementation timeline. Companies should review the applicable provisions of Regulation (EU) 2025/40 and related EU guidance when making compliance decisions.

T5 Paper Pallet Co., Ltd.

Thailand based and with global reach, T5 builds from a sturdy platform as the region’s premier designer and manufacturer of eco-friendly corrugated paper products.

T5 Paper Pallet Co., Ltd. has long been known for innovative as well as environmentally friendly ways to store, move, and package products. The Bangkok-based company’s well-earned reputation owes to design and manufacturing expertise in addition to outstanding support before and after every sale.

T5’s high regard is furthermore the result of advanced technological and logistical know-how enhanced with a human touch – a set of qualities fully setting apart T5 from conventional manufacturers and suppliers. Indeed T5 has the creative and service capabilities that lead to genuine relationships. Clients know they can rely on T5 to provide personalized consultation addressing their specific requirements, saving clients time and money. Thereafter, T5’s quick responses and helpful advice – including urgent, last-minute problem solving no matter the cause – further create a solid bond between T5 and clients. It’s all part of the company’s promise to clients and customers to get things right and keep them right.

Now with more than a decade of experience to draw from, T5 continues to expand its product and service range as well as business scope. From 2020, businesses and consumers within Thailand and beyond can expect a growing list of customized paper solutions designed, manufactured, and sold directly by T5 Paper Pallet Co., Ltd.

T5’s expanded range and scope is no transition to a different business model; rather, it’s a refinement of the company’s existing competencies. From its founding, T5 has served clientele as an all-round paper-product firm combining consultancy, design, and production components. This has allowed the company to provide from the outset of every relationship the kind of specialized consultation needed to fully determine a client’s requirements and preferences. From there, T5’s design team works closely with clients to transform prevailing concepts into working plans, before T5 manufacturing technologies are skillfully applied towards creating customized end products each made to precise specifications.

With upcoming advancement, however, remaining unchanged will be T5’s commitment to establishing genuine partnerships with business clients and to being a trusted friend among individual buyers. Whether a company looks to make a warehouse more efficient and cost-effective, or an individual homeowner wishes to make their residence more beautiful and functional, all who choose T5 place trust in an industry leader at the very top of the stack when it comes to inventive as well as eco-friendly paper-based products.

Ahead of the rest from page one

On its founding in 2008, T5 Paper Pallet Co., Ltd. became one of Thailand’s first manufacturers of corrugated-paper pallets for storing and transporting inventory. It likewise became first in the country to use specialized, precision machinery from Japan for producing paper pallets, which it installed at T5’s production site near Bangkok.

The material advance represented by paper-based pallets, or “ecopallets”, soon benefitted clients in important ways. Apart from being lighter (saves transport costs), cleaner (doesn’t require fumigation), safer (easier to handle), and less expensive on the whole, paper pallets likewise can be manufactured more quickly than conventional wooden or plastic varieties. Crucially, from the very beginning, this allowed T5 to provide clients with more responsive supply given that less lead time was needed. That same responsiveness applied to T5’s additional product focus early on, namely packaging materials including corrugated boxes. Here again, speedy supply proved a key advantage for clients, and especially export companies, whose immediate requirements can vary substantially and change quickly throughout the year.

T5’s unflagging enthusiasm for finding new and better ways to do things soon made the company Thailand’s top source of corrugated paper products. From breaking with norms so as to provide genuinely innovative pallet and packaging products, to going beyond the usual expectations of a traditional manufacturer to provide tailored design and consultancy services, T5 established itself as an industry leader. The experiences gained and reputation earned by T5 over the years, moreover, would eventually lead to partnerships with major domestic and international companies. All T5 partners benefit from T5’s unrivaled combination of large-scale production capabilities enhanced by personalized consultation and support services.

Today, T5 stands poised to continue its success as a manufacturer and supplier of paper pallets and packaging materials. The coming years, moreover, will see the company expand its design capabilities to emphasize non-corrugated paper products including household items such as home storage, furnishings, and décor.

Core values mean strong bonds

T5’s core brand values – five it so happens – reinforce all operations and influence every relation. The values create strong bonds between T5 and its partners and customers, as well as between its employees and the communities where T5 operates.

1. Dependability
It’s important to be on the same page

There’s an expression in Thai, puen koo kid (เพื่อนคู่คิด). A general translation is “close friend” as well as “trusted partner”, or literally “thinking partner”. Either way, the expression conveys a sense of dependability, of someone you can rely on. There’s a further sense of someone who thinks like you do, who intuitively understands and anticipates your needs and concerns. Such traits combine to form an essential value at T5: dependability. Clients can depend on T5 to provide meaningful, honest, and comprehensive consultation. They can then later depend on timely advice and easily accessed service even outside business hours.

For clients and customers, T5 is not only their thinking partner but also their personal paper guide. T5 helps them get things aligned and assure a desired result. The company listens, learns, and thinks carefully – until everyone is on the same page – before skillfully guiding each client to their goal.
2. Capability
Vanguard hardware and can-do creativity
T5 is more than a manufacturer and supplier. The company’s production site in fact comprises an in-house R&D function along with the kind of advanced equipment and technology required for conceiving, designing, making, and delivering innovative paper-based products. Among hardware examples are sophisticated digital printers requiring no master plate, resulting in not only superior-quality designs but likewise more affordable output.
Of course even the most ultramodern hardware needs old-fashioned human ingenuity. T5’s design team has in-depth knowledge of paper’s material properties and its many uses – including ways to create highly functional and durable products not usually associated with the material. Indeed, it was through such expertise in paper’s properties and potential that T5 became first in Thailand to manufacture paper pallets, which despite being lighter are in fact highly durable and can support loads of up to 3 tons. And given T5’s design and production capabilities, those qualities and specs are bound to improve.
3. Customizability
A client’s personal paper-works
T5 has the know-how and flexibility to create customized paper solutions. Whether it’s a small run of stylish packaging, large-scale production of corrugated boxes to precise measurements, or paper pallets by the hundreds of thousands, T5 can do it all and do it quickly.
In this regard T5’s consultancy and design proficiency are key. Initial consultancy takes in diverse concerns, sometimes going beyond paper-related requirements to assess each client’s unique business process. This ensures advice and recommendations that are thorough, relevant, honest, and meaningful. Additionally, because it’s a design house staffed with top-flight creatives and equipped with advanced technologies, T5 has the necessary flexibility to provide maximum customizability.
The same personalization, flexibility, and creativity, moreover, enhance T5’s expanding line of paper-based household furnishings and décor. Whatever you need and no matter how soon, T5 is your personal paper-works.

4. Applicability
Wide-ranging functions and uses
T5 expertise stretches beyond efficient and cost-effective methods for companies to package and store products ahead of delivery to retailers and consumers. More and more, paper-based products designed and made by T5 are consumer products themselves. Indeed the applicability of T5 designs is broad and for many might be surprising. Just some applications for home use include: tables, computer desks, cabinets, bed frames, shelves, shoeboxes, pet houses, and more.
So apart from industry-leading corrugated-paper products such as pallets and boxes, expect to see from T5 in coming years many new and imaginative uses of other paper types across diverse applications.
5. Responsibility
Genuine care for people and the planet

T5’s commitment to responsible business practice is a natural extension of its responsibility to clients and customers. In fact, the same care and attention the company devotes to customer relations is seen just as clearly in T5’s devotion to colleagues, communities, and the environment.

T5 does more than talk about the principles of corporate responsibility and sustainability: the company commits them to paper. For instance, when working with international partners T5 readily signs up to what are often stringent environmental, workplace and documentation requirements. Among measures adhered to are those pertaining to resource use, waste management/pollution control, fair labor practices, workplace safety and other factors fundamental to responsible business operation. The company likewise abides by International Organization for Standardization (ISO 9001) benchmarks.

T5 takes just as seriously its duties as a company within the paper industry. It holds Forest Stewardship Council Chain-of-Custody certification (FSC CoC) and thus strictly abides by the organization’s standards regarding sustainable use of natural resources. Company certification requires that all other companies in a supply chain be FSC CoC certified, among them harvesters, processors, manufacturers, distributors, printers, and most retailers. This allows T5 clients and customers to know with confidence the products they buy have come from responsibly managed sources.

T5 Paper Pallet Co., Ltd. – Your Personal Paper Guide

T5 Paper Pallet Co., Ltd. promises to be a personal paper guide for every client, consumer, and employee. As a designer and manufacturer of innovative paper-based products and a full-service paper consultancy, T5 excels by being a flexible and accessible company always there for associates at every step of the way, whether as a long-term partner among global corporations and SMEs or as a trusted friend to individual retail customers. T5 furthermore promises to conduct all business operations responsibly, with the health and well-being of people and the preservation of natural resources foremost concerns at all times.