For the promotional products industry, this is a very practical issue. PPWR applies not only to packaging manufacturers, but broadly to market participants: producers, importers, distributors, companies assembling gift sets, brands selling under their own label, as well as e-commerce and shipping operators. Under the regulation, a “producer” may include not only the manufacturer, but also an importer or distributor if they are the first to place packaging or a packaged product on the market in a given EU country.

 

What PPWR is about

The main goal is simple: less packaging waste, more rational packaging, and greater recyclability and reusability. The European Commission indicates that the regulation is meant to support the circular economy, reduce the use of virgin resources, and ensure that packaging on the EU market is more recycling-friendly. By 2030, all packaging placed on the EU market must be designed to be recyclable in an economically viable way.

For the industry, this means a shift in thinking: packaging must not only look good, but also be justified, material-efficient, easy to sort, and compliant with new documentation requirements.

 

Why this matters for the promotional products industry

In the promotional sector, packaging often serves multiple roles: protecting the product, creating a “wow” effect, organizing gift sets, reinforcing branding, and supporting logistics. The issue is that this is exactly where solutions may arise that PPWR will assess critically: oversized boxes, decorative fillers, unnecessary layers, packaging designed more for display than function, and excessive empty space in e-commerce shipments.

This affects situations such as:
– packaging a single item in an oversized box,
– gift sets with excessive decorative filling,
– shipping small items in overly large courier boxes,
– importing ready-made products from Asia without full knowledge of whether their packaging complies with EU requirements.

Under PPWR, such cases may create compliance risks. The takeaway is clear: packaging is becoming a compliance issue—not just a marketing or logistics one.

 

Key obligations companies should be aware of

1. Packaging must be minimized
From January 1, 2030, packaging weight and volume must be limited to what is strictly necessary for its function. The regulation explicitly discourages packaging elements that artificially increase perceived volume, such as double walls, false bottoms, or unnecessary layers.

For the promotional industry, premium packaging will still be possible—but its function must be justifiable (protection, logistics, safety, branding, recyclability, or reuse). “Because it looks bigger and more premium” will no longer be enough.

 

2. Limits on empty space in shipping and grouped packaging
PPWR introduces requirements to reduce empty space. For grouped, transport, and e-commerce packaging, the maximum empty space ratio will be 50%. Fillers such as paper shreds, air cushions, bubble wrap, foam, and polystyrene chips are counted as empty space.

This directly impacts companies shipping promotional kits, welcome packs, and gift boxes. Packaging formats and fillers will need more careful selection.

 

3. Packaging must be designed for recycling
Packaging must be designed to be collected, sorted, and recycled. From 2030, recyclability performance classes will apply, and by 2035, “recycled at scale” requirements will be introduced.

In practice, this means moving away from hard-to-recycle, multi-material packaging without clear justification, overly complex constructions, or elements that hinder recycling—especially in premium packaging formats.

 

4. Recycled content requirements for plastics
The regulation introduces minimum recycled content levels in plastic packaging. From 2030, this will generally be 35% for most plastic packaging, with different thresholds for food-contact materials.

For the promotional industry, this affects plastic boxes, sleeves, blisters, mailers, and packaging components. Even if the obligation formally lies with the manufacturer, importers and brands must be able to demonstrate compliance.

 

5. New labeling requirements
From August 12, 2028 (or later depending on implementing acts), packaging will require harmonized labels indicating material composition to help consumers sort waste. These labels will be based on clear pictograms.

Companies will need to allocate space for these markings and ensure packaging designs can accommodate them.

 

6. Concrete compliance obligations for producers, importers, and distributors
Producers may only place compliant packaging on the market. They must carry out conformity assessments, prepare technical documentation, and issue an EU declaration of conformity. Documentation must be kept for 5 years (single-use) or 10 years (reusable packaging).

Importers and distributors also have verification and due diligence obligations. This marks a major shift: packaging can no longer be treated as a simple add-on.

 

7. Extended Producer Responsibility (EPR) and registration
PPWR strengthens EPR systems. Producers must cover the costs of collection, sorting, and recycling, with fees incentivizing better-designed packaging. National producer registers will also apply, requiring registration in each country where packaging is first placed on the market.

For promotional businesses, this makes cross-border sales and e-commerce more complex and formalized.

 

8. Special attention to food-contact packaging
From August 12, 2026, food-contact packaging cannot be placed on the market if it contains PFAS above specified thresholds.

This is particularly relevant for packaging of mugs, bottles, lunchboxes, food gifts, and promotional sweets. Supplier material declarations will need careful verification.

 

Benefits for the industry

PPWR brings greater harmonization across the EU, reducing regulatory fragmentation. It also rewards better design—companies already investing in smart, sustainable packaging may gain a competitive advantage. Increasingly, corporate clients expect environmentally responsible packaging alongside attractive products.

The regulation also strengthens companies’ position in client discussions, enabling them to justify more rational packaging solutions.

 

Challenges and difficulties

Companies will face increased organizational effort: verifying suppliers, collecting documentation, updating specifications, and monitoring regulatory developments. This requires time, cost, and cross-department collaboration.

Some traditional presentation standards may also need rethinking, as certain visually appealing packaging solutions may no longer be viable or require stronger functional justification.

There is also transitional uncertainty, as some details will be clarified through future implementing acts and guidelines.

 

Risks and threats

The biggest risk is assuming the regulation only applies to packaging manufacturers. In many cases, promotional product companies will also fall under its scope.

Another risk is lack of documentation. Without proof of compliance, authorities may require corrective actions, withdraw products from the market, or impose restrictions.

Finally, there is the risk of penalties. Member states were required to introduce penalty systems by February 12, 2027, including administrative fines.

 

What companies should do now

The best approach is not to wait until August 2026, but to start reviewing packaging now. Key questions include:
– Is packaging oversized?
– Can empty space and fillers be reduced?
– Do we know the material composition?
– Can suppliers provide proper documentation?
– Do imported products meet compliance requirements?
– Does cross-border sales trigger additional obligations?

 

Conclusion for the industry

PPWR is not a “future issue.” It will directly affect everyday commercial, purchasing, design, and logistics decisions. For the promotional products sector, it means one thing: packaging is no longer just an aesthetic addition—it becomes a matter of regulatory responsibility and competitive advantage.

Companies that act early will be better positioned to adapt smoothly, avoid costly corrections, and build offerings aligned with evolving client expectations.