The EU PPWR and honeycomb paper: what changes for buyers

The EU packaging rules changed this summer. The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied across the EU since 12 August 2026. It replaced the old Packaging Directive.

For honeycomb paper buyers, three things matter now and two more come later.

Now, paper wrap must stay under the heavy metals limit of 100 mg/kg. The manufacturer must hold technical documentation and an EU declaration of conformity. The EU importer must check that it exists. Later, from 2030, parcels must meet a 50% maximum empty space ratio. Wrap and void fill count as empty space in that ratio. Packaging must also meet recyclability grades.

Paper is not exempt. It only escapes some rules that were written for plastic.

We export from Jaipur to 20+ countries, and we quote honeycomb paper in euros as well as in dollars and pounds. So I have read the parts of this regulation that touch our product. This is a buyer's summary, not legal advice. Before you rely on any point for a compliance decision, check it with someone who practises EU product law.

Does PPWR apply to honeycomb paper at all?

Yes, in almost every case a buyer will meet.

Honeycomb paper used to wrap goods inside a shipping box is protective packaging. Article 24 of the Regulation even names "paper cuttings", air cushions and bubble wrap as examples of filling materials. The lawmakers clearly had this kind of material in mind.

The full text is on EUR-Lex: Regulation (EU) 2025/40 (European Parliament and Council, Official Journal L, 22 January 2025). It entered into force on 11 February 2025 and applies from 12 August 2026 (Article 71).

One caveat. Annex I lists "wrapping paper (sold separately to consumers and business operators)" among items that are not packaging. Some people read that line as covering all wrap. I would not rely on it for protective wrap that goes inside shipping boxes, and the Regulation does not mention honeycomb paper by name. If a lot of your business depends on that point, get a legal opinion.

What applies already, since 12 August 2026?

Four obligations reach honeycomb paper today.

The heavy metals limit is not new. The recitals of the Regulation say it maintains the existing restrictions on these four metals, so a supplier who was compliant under the old Directive should already have test reports. Coloured honeycomb paper is the place I would look first, because the limit applies to the paper and everything printed or dyed on it.

The paperwork is the bigger change. The Commission's PPWR FAQ (DG Environment, 2nd edition, 3 August 2026) says that for generic, unbranded packaging, the manufacturer is normally the company that physically makes it. It also says EU importers must check that a manufacturer in a third country has carried out the conformity assessment and drawn up the declaration, including for generic packaging materials such as paper sheets.

Article 15 also asks the manufacturer to identify the packaging with a type, batch or serial number, and to give its name and postal address, on the packaging or in an accompanying document where that is not possible. For rolls, ask your supplier how it does this. A carton label with a lot number, repeated on the invoice, is the simplest way I know.

What if you sell our rolls under your own brand?

Then, for PPWR purposes, you probably become the manufacturer.

Article 21 says an importer or distributor that places packaging on the market under its own name or trademark is treated as the manufacturer, with all the duties under Article 15. This matters for private label. A UK packaging distributor already sells our rolls under its own brand and codes, and for the EU the same model now carries EU paperwork with it.

In practice, the brand owner needs the supplier's test reports and material information to build its own technical file. Plan who prepares what before the first container, not after. We would rather settle that with you on paper at the quotation stage. Our private label page covers the rest of the set-up.

What comes later, and when?

Most of the heavier obligations start between 2028 and 2030.

The 50% empty space rule is the one that will change packing tables. The calculation method is still to come. The Commission's guidance notice, C/2026/3084 (Official Journal C, 10 June 2026), says the implementing act will be adopted before 12 February 2028 and that the ratio must be met by whoever uses or fills the packaging.

Why does honeycomb wrap count as empty space?

Because Article 24(3) says so for all filling materials. It defines empty space as the volume of the outer box minus the volume of the sales packaging inside it, and adds that space filled by materials such as paper cuttings, air cushions, bubble wrap and foam fillers "shall be considered as empty space".

So PPWR is material-neutral here. Paper wrap gets no credit over bubble wrap. What helps is a box that fits the product closely, with only as much wrap and fill as the product needs.

I would read this as good news for honeycomb paper used properly, because a few close turns of wrap take less room than a big loose cushion. It is bad news for a small mug in a large box full of fill, whatever the fill is made of. Sales packaging used as e-commerce packaging is exempt from the 50% ratio under Article 24(5), but it must still meet the minimisation rule.

Our guide on choosing the right box size shows how to measure and size boxes so the ratio is not a shock in 2030.

What PPWR does not do to paper

Some rules sound wider than they are. Three worth knowing:

1. The recycled content targets in Article 7 apply to the plastic part of packaging, not to paper.
2. The reuse targets for transport packaging in Article 29 do not apply to transport packaging in the form of cardboard boxes, under Article 29(4).
3. Paper packaging with under 5% plastic counts as a single material, not as composite packaging. The Commission notice says paper-based packaging with 5% or more plastic is caught by the bans on certain single-use plastic formats in Annex V.

That last point is worth a question to any supplier of "paper" padding with a coating or a plastic layer. Plain kraft honeycomb has no plastic layer, but ask for it in writing.

What to ask your supplier for

These are the documents I would ask any honeycomb paper supplier for, before the first EU order:

1. A heavy metals test report for each paper type and colour you buy, from an accredited laboratory.
2. The EU declaration of conformity, or a clear statement of who will draw it up.
3. A material composition statement: fibre, any coating, any dye or ink.
4. How the rolls are identified: lot or batch number on the carton and the invoice.
5. For food-contact use, evidence on PFAS. From 12 August 2026, Article 5(5) sets PFAS limits for food-contact packaging.
6. For FSC claims, the claim and certificate code on the invoice. Our guide to FSC labels explains what to check.

Any supplier, us included, should be able to tell you which of these it can provide today, and when it can provide the rest. If the answer is only "we are compliant", ask again.

A word on EPR and other EU rules

PPWR also sets up extended producer responsibility. The EU business that first makes the packaging available in a member state is usually the producer who registers and pays fees there (Articles 44 and 45). A Commission proposal from December 2025 to suspend the authorised representative duty in Article 45(3) was still not adopted when I checked the European Parliament Legislative Train (updated 20 September 2026).

PPWR is also not the only EU rule on your paper. The EU Deforestation Regulation covers paper products too, and our post on the EUDR and paper packaging imports explains it. Green claims made to consumers fall under a separate EU directive. For customs codes and import documents, see our guide to importing honeycomb paper into the EU.

If you import into the EU

If you import honeycomb paper into the EU, send us your list of PPWR documents with your enquiry. Write to us through the contact page, and we will answer item by item in writing, including anything we cannot yet provide.