Regulation (EU) 2025/40
PPWR Recyclability Requirements 2030 for Molded Fiber Packaging
The PPWR has applied across the EU since 12 August 2026. The obligation that all packaging placed on the market be recyclable is already in force; the harmonised criteria that will grade how recyclable it is arrive later, and the hard design deadlines land in 2030. THECA sits on the supply side of that problem: PPWR-compliant molded fiber made from 100% post-consumer recycled fibre, engineered around your product, tooled in our own mold shop and supported by the documentation your conformity file draws on.
Where a THECA project starts.
100% post-consumer recycled fiber
Every THECA product is moulded from post-consumer recycled cellulosic fibre. No virgin-fibre route is required.
PPWR compliant
Our products are PPWR compliant. Your final configuration, added components, intended use, target market and role still shape the project-level picture.
Fibre and nothing else, by default
A fibre-only component carries no non-fibre content to separate, declare or defend in a recyclability assessment.
Engineering and tooling in-house
Type 1, 2 and 3 production plus machine and mold development under one roof, so design changes move at project speed.
What the PPWR changes
A regulation rather than a directive — and it is already running.
Regulation (EU) 2025/40 replaced Directive 94/62/EC and has applied directly in every member state since 12 August 2026. There is no national transposition step, and the obligations reach manufacturers, importers, distributors and online sellers placing packaging or packaged products on the EU market.
Two consequences matter for procurement and packaging teams. First, Article 6(1) already requires all packaging placed on the market to be recyclable; the Commission has confirmed that until the harmonised design-for-recycling rules apply, manufacturers work to the requirements and standards carried over from the previous directive. Second, the obligations attach to the packaging unit as placed on the market, not to one component. Moving a tray from plastic to fibre is a strong move on material, but the pack still has to answer for weight, volume, added non-fibre elements, labelling and technical documentation.
Responsibility for conformity sits with the “manufacturer” in the PPWR sense — normally the party that orders the packaging and decides its design specification, which for sales and grouped packaging is usually the filler or brand owner. Suppliers feed that file with information and documentation; they do not replace it. Knowing which role you hold is the first practical step, because it determines who signs the declaration of conformity.
Verified timeline
The dates that actually drive your design decisions.
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11 February 2025 — Entry into force
The Regulation entered into force, replacing the Packaging and Packaging Waste Directive as the EU framework for packaging.
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12 August 2026 — General application
The PPWR became applicable. The Article 6(1) recyclability obligation and the PFAS limits for food-contact packaging took effect on this date, with no transitional period for exhausting stocks of non-compliant food-contact packaging.
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By 1 January 2028 — Secondary legislation due
The Commission is to adopt the delegated acts setting design-for-recycling criteria and the related assessment methodology. The implementing act defining how the empty space ratio is calculated is due before 12 February 2028.
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1 January 2030 — The design deadline
Design for recycling applies from this date or 24 months after those delegated acts enter into force, whichever is later, and packaging must reach recyclability grade A, B or C. Packaging minimisation under Article 10, the 50% empty space cap under Article 24 and the restricted formats under Article 25 also apply.
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1 January 2035 — Recycled at scale
The second half of the recyclability definition applies: separate collection, sorting without harming other streams, and recycling at scale, subject to the implementing acts that set the methodology.
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1 January 2038 — Grade C phased out
Only packaging in recyclability grades A or B may be placed on the market.
Recyclability toward 2030
What “recyclable” will mean once the grades arrive.
Article 6 defines recyclability in two halves. The first is design for recycling: the pack must be designed for material recycling so the resulting secondary raw material is good enough to substitute primary material. The second is system performance: when it becomes waste it must be separately collectable, sortable without affecting other waste streams, and recycled at scale. Recyclability will then be expressed as performance grade A, B or C, with grade C disappearing from the market in 2038.
The qualification that matters commercially: the delegated acts defining the criteria, the assessment methodology and the grade calculation are due by 1 January 2028 and had not entered into force as of 15 September 2026. No one can issue a final PPWR grade today, and the Commission has confirmed that recyclability conformity assessment and the related technical documentation under Annex VII are not required until those acts apply. Limited exemptions also exist within Article 6 for specific packaging types.
What can be done now is to design out the features that every published fibre-recycling method penalises — non-separable non-fibre layers, hard-to-repulp coatings, heavy ink coverage — so the pack is refined in 2028 rather than rebuilt in 2029. Tooling amortises over years; the geometry you approve this quarter is very likely the geometry that meets the 2030 threshold.
Minimisation and empty space
Minimisation is a design obligation, not a packing habit.
Article 10 requires that, by 1 January 2030, packaging weight and volume be reduced to the minimum necessary to ensure functionality, taking account of shape and material. It also bars packaging with features that exist only to increase the perceived volume of the product, such as double walls, false bottoms and unnecessary layers. Marketing and consumer acceptance are no longer accepted as justifications for extra weight or volume. Until the end of 2029, the minimisation requirements and compliance standard carried over from the directive continue to apply.
Separately, Article 24 caps the empty space ratio at 50% for grouped, transport and e-commerce packaging from 1 January 2030, or three years after the implementing act setting the calculation methodology enters into force, whichever is later. That duty falls on whoever fills the packaging. For sales packaging there is no fixed threshold; empty space is judged through the minimisation assessment instead.
None of this is a licence to under-protect. Product protection and functionality remain recognised performance criteria, and a damaged product is a worse outcome environmentally and commercially than a few extra grams of fibre. Molded fiber is well placed here because the cushioning is geometry rather than bulk: ribs, contact zones and controlled clearances do the work void fill used to do, and nesting components take less inbound transport and warehouse space than loose foam alternatives. See how THECA selects the production route for a given wall structure and load case.
More than the base material
Recyclability is decided by everything you add to the fibre.
A fibre base is the straightforward part. What moves a pack up or down a future grade is the non-fibre content layered onto it. Under the PPWR, a non-fibre material that cannot be separated manually makes the unit composite packaging once it exceeds 5% of the unit’s mass; labels, varnishes, paints, inks, adhesives and lacquers sit outside that specific calculation but still affect how cleanly the fibre repulps.
| Added element | Usual reason for adding it | Where the risk sits | How THECA handles it |
|---|---|---|---|
| Coatings and barriers | Moisture, grease or oxygen resistance | May resist repulping and add non-fibre mass to the unit | Applied only where the application genuinely requires it, after the geometry has been tested without it |
| Films and laminations | Sealing, presentation or product visibility | Often non-separable, and counts toward the composite threshold | Treated as a deliberate specification decision with a documented reason, not a default |
| Printing and inks | Branding, instructions, identification | Heavy coverage can affect fibre quality and visual impurities | Coverage and placement reviewed against what actually has to be legible on the pack |
| Adhesives and labels | Closing, bundling, batch marking | Residues and carriers can carry through to the recycled stream | Designed out where a formed feature, tab or interlock can do the same job |
| Lids, closures and inserts | Retention, stacking, product access | Mixed-material units are harder to sort and to declare | Fibre lids and formed retention features used where the application allows a mono-material build |
Scroll the table sideways on smaller screens to see every column.
Buyer checklist
Define these before asking anyone to quote.
With these answers, an engineer can give you a technical position on material, structure and production route. Without them, any supplier is guessing.
- Product and application
- Target EU market or markets
- Packaging format and its role in the pack hierarchy
- Intended use, including contact with the product
- Current packaging material and construction
- Added non-fibre components you need to keep
- Protection requirements and known failure modes
- Packing-line, denesting and automation constraints
- Transport, storage and humidity conditions
- Annual quantity — series projects start from around 10,000 units
- Testing and documentation your customers or auditors request
How THECA supports the transition
From brief to series supply, with the file built as you go.
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01
Technical brief
Product data, current pack, market, volumes and documentation expectations are collected in one pass.
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02
Packaging and material review
We confirm whether a fibre-only build is realistic and say so early if it is not. Explore the molded fiber product range.
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03
Structural and tooling design
Wall structure, ribs, clearances and nesting are developed with the production route selected from the requirement.
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04
Sample production
For technically suitable projects, a complete brief reaches a first molded fiber sample in about four weeks.
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05
Application validation
Fit, packing sequence and handling are trialled with the real product. ISTA drop testing is arranged where a project requires it. Requirements differ by sector — see molded fiber by industry.
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06
Series production and documents
Typical series lead time is 2–4 weeks after final product and tooling approval and a confirmed order. ISO 9001, FSC Recycled, PFAS analysis and independent Intertek analyses for selected products are available for review alongside our certificates.
Related compliance topics
Frequently asked
Three questions buyers ask about PPWR and fibre.
Does the PPWR apply already, or is this a 2030 problem?
Both. The Regulation has applied since 12 August 2026, and obligations including the general recyclability requirement and the PFAS limits for food-contact packaging are live now. The numeric and grade-based requirements — design for recycling, minimisation, the empty space cap and the restricted formats — land from 1 January 2030, with some tied to secondary legislation that is still to come. Because tooling outlasts the gap, the design decision you take now is effectively a 2030 decision.
Does switching to molded fiber cover every PPWR obligation?
No, and it should not be sold that way. THECA products are PPWR compliant, but the Regulation assesses the packaging unit as placed on the market: added films, coatings, labels, adhesives, weight, volume, empty space, labelling and technical documentation all form part of the picture. A fibre component is a strong and often decisive contribution to that assessment; it is not a substitute for it, and the declaration of conformity stays with the economic operator that ordered and specified the pack.
What does THECA need to assess a packaging project?
Product dimensions, weight, drawings or 3D data, sensitive areas, the current packaging method, carton and pallet constraints, distribution conditions, the target market, expected annual volume and any documentation or testing your customers require. From that we can say whether a fibre-only build is realistic, which production route fits, what the tooling implies and which documents belong with the specification.
Official sources
- EUR-Lex — Regulation (EU) 2025/40 on packaging and packaging waste
- EUR-Lex — Commission Notice, guidance document for Regulation (EU) 2025/40
- European Commission — Packaging and Packaging Waste Regulation
- European Commission — New EU rules on packaging enter into application
- EUR-Lex — Summary: packaging and packaging waste from 2026
Last reviewed: 15 September 2026
This page provides general technical information and does not constitute legal advice. Requirements should be assessed for the specific product, market and intended use.
Next step
Discuss the PPWR requirements of your packaging project.
Send the product and application, the target market, the intended use, the expected annual quantity, your packaging and protection requirements, and any testing or documentation your customers ask for. Our engineers come back with a position on material, structure, production route and the documents that belong with the specification — including an honest answer if molded fiber is not the right route for your application.