## Background The Packaging and Packaging Waste Regulation (EU) 2025/40 will fully apply from August 12, 2026, replacing the former Packaging and Packaging Waste Directive 94/62/EC. The biggest difference from the original directive is that the compliance object has expanded from "packaging materials" to "packaging systems," with new requirements added for recyclability by design, empty space ratio, recycled content, and more.
## Frontline Observations: Four High-Frequency Issues **First, the packaging hierarchy has not been fully mapped.** Companies typically only count outer boxes, ignoring inner liners, bubble bags, sealing tape, manual bags, and cable ties. PPWR's "packaging components" include all levels; missing any one means missing compliance.
**Second, composite materials cannot be separated.** If paper-plastic composites or aluminum-plastic composites cannot be separated under existing recycling systems, the recyclability assessment will be directly downgraded.
**Third, the empty space ratio exceeds the limit.** Enlarging box sizes to prevent transport damage is an industry habit, but PPWR sets a clear upper limit on empty space.
**Fourth, outdated reports are being reused.** Testing under the old directive era only covered total heavy metals and did not include recyclability or recycled content ratios, so it cannot support declarations of conformity under the new regulation.
## Practical Impact on Companies In the short term, the most direct costs come from packaging structure redesign (typically an increase of 5%–15%) and testing and assessment fees; in the medium term, recyclability grading will be linked to fees after 2028, and companies that switch designs early will gain a cost advantage.
## Recommended Actions 1. Establish a packaging BOM by "level," incorporating tape, labels, and inner liners. 2. Conduct separability assessments for composite materials and replace those that cannot be separated as early as possible. 3. Recalculate box types and empty space ratios. 4. Complete heavy metal testing and recyclability assessments, and prepare packaging declarations of conformity.
## Note This article is an industry observation and does not constitute legal advice. For specific applicable provisions, please refer to the original text of the regulation and the delegated acts of the European Commission.