REGULATORY INSIGHT | EU PACKAGING
The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has generally applied since 12 August 2026. For industrial and transport packaging, the main challenge is to determine which items qualify as packaging, how packaging units and DoC or technical-file boundaries should be defined, and which testing evidence can support product families. This guide addresses these practical questions for pallets, stretch wrap, straps, drums, IBCs and FIBCs. Companies needing implementation support can also review REACH24H's EU PPWR Packaging Compliance Services.
Quick Navigation
Jump to the key sections of this article.
Which Industrial and Transport Packaging Falls Within the PPWR?
Classification should be based on function rather than the product name alone. An item is more likely to be packaging when it is used by an economic operator to contain, protect, handle, deliver, or present a product, without being an integral part of that product.
Industrial and Transport Packaging Examples
| Common item | PPWR classification point |
|---|---|
| Pallets, pallet collars, and reusable crates | Generally treated as transport packaging. Wood, plastic, and metal formats should be assessed according to their material composition and structure. |
| Stretch wrap, pallet wrap, shrink film, and similar films | Generally transport packaging when used to stabilise, group, or protect goods during handling and transport. |
| Straps, bands, and sealing tape | Strapping can be a separate transport-packaging format. Tape is commonly managed as a component of the box or other package to which it is applied. |
| Corrugated boxes, wooden cases, bubble wrap, air cushions, foam, and paper fillers | Usually packaging or packaging components and should be recorded within the actual packaging configuration and supporting technical file. |
| Plastic, steel, and fibre drums; IBCs; and FIBCs | Typical industrial or transport packaging. The assessment should reflect the complete structure, materials, components, and intended use. |
| Road, rail, ship, and air containers | The container itself is excluded from the PPWR definition of transport packaging. Pallets, boxes, wrap, straps, and cushioning used inside it may still be packaging. |
Items used inside a freight container, such as dunnage bags, bracing straps, or metal supports, require a fact-specific review. Equipment owned and repeatedly used by a logistics provider may be closer to transport-securing equipment. By contrast, materials supplied by the exporter for a shipment, delivered with the goods, or discarded as packaging waste are more likely to be treated as packaging.
How Should Packaging Units, Technical Files, and DoCs Be Divided?
Industrial-packaging projects involve two separate grouping decisions:
DoC and technical-file grouping: determine the packaging type or unit by function, final configuration, responsible manufacturer, and actual use.
Testing and evidence grouping: determine representative samples by material, formulation, additives, production process, colour, printing, supplier, and risk.
These decisions are related, but they are not identical. One shipment does not automatically require only one DoC, and a package containing several components does not automatically require a separate DoC for each component. The correct boundary depends on whether the components form one packaging unit, whether the same manufacturer controls the conformity basis, and whether the supporting evidence covers the complete configuration.
Typical Documentation Structures
| Typical configuration | Suggested documentation logic |
|---|---|
| Box + sealing tape used as a fixed configuration | May be documented as one complete packaging unit where the same conformity basis covers the box, tape, and other relevant auxiliaries. |
| Strap + metal or plastic buckle | May be treated as one strapping unit, but each material and component still needs adequate test or compliance evidence. |
| Drum body + lid + valve + gasket + label | May be covered as one complete drum package if the technical documentation addresses every actual component. |
| Pallet + stretch wrap + straps | Usually represents different packaging formats. Each format and its manufacturer responsibility should be assessed separately before deciding the DoC structure. |
| Box + bubble wrap or foam cushioning | A fixed configuration may be documented together. Cushioning that is marketed separately or used in changing configurations should be assessed separately. |
| IBC or FIBC + accessories | A DoC may address the complete IBC or FIBC format, while the technical file and evidence should cover the frame, liner, valve, pallet, lifting loops, seams, label, and other applicable components. |
Several sizes or specifications may be grouped under one DoC where the material, formulation, manufacturing process, intended use, and other conformity-relevant characteristics are equivalent. The covered range should be clearly identified in the declaration and technical file. A change in polymer, formulation, colour, printing, coating, intended use, or supplier may require separate assessment or additional evidence.
Supplier evidence must also be traceable to the packaging it supports. Different suppliers should not share a test report by default. Any reliance on a common report should be supported by documented equivalence of the material, formulation, production conditions, and relevant risks.
For a fuller explanation of manufacturer responsibility, document retention, change control, and multi-SKU grouping, see EU PPWR Declaration of Conformity: Who Signs, When to Update and How to Group Multiple SKUs.
Which PPWR Requirements Need Attention Now?
The PPWR applies in phases. Industrial and transport packaging should therefore be managed through two workstreams: requirements that are already applicable and requirements that will apply from later dates.
Requirements to Prioritise at the Current Stage
Substances of concern (SoCs): packaging should be manufactured so that the presence and concentration of SoCs in materials and components are minimised. Supplier composition data, additives, coatings, inks, and adhesives should be reviewed proportionately.
Heavy metals: the total concentration of lead, cadmium, mercury, and hexavalent chromium must be assessed against the PPWR requirement. Migration or soluble-heavy-metal results do not normally replace evidence of total concentration.
PFAS in food-contact packaging: the PPWR limits apply where packaging is intended to contact food. A pallet, strap, wrap, or cushioning material that does not contact food does not become subject to PFAS testing merely because it is used in a food supply chain.
Recyclability: packaging should undergo a documented recyclability review. The detailed harmonised design-for-recycling criteria and performance grades apply under later milestones and should be tracked separately from the current baseline requirement.
Conformity and traceability: the responsible manufacturer should complete the applicable conformity assessment, prepare technical documentation and an EU DoC, and link the packaging type, batch, serial number, or equivalent identifier to the supporting file.
The ECHA working list of approximately 700 packaging SoCs remains a research-stage list and should not be treated as a new prohibited-substance list or universal testing panel. See REACH24H's explanation of the draft PPWR SoC list for the distinction between the study and binding requirements.
Later Requirements to Track
Depending on material and use, companies should also plan for later milestones involving:
recyclability performance grades and detailed design-for-recycling criteria;
minimum recycled-content requirements for plastic packaging;
reusable packaging and reuse systems;
empty-space limits for grouped, transport, and e-commerce packaging; and
harmonised labels and material information.
Pallet wrapping and straps remain transport-packaging formats under the PPWR. The European Commission has exempted their use in specified transport scenarios from the 100% reuse requirements, but this does not remove other applicable PPWR obligations. The Commission's pallet-wrapping and straps exemption notice explains the limited scope of the exemption.
How Should Testing and Supporting Evidence Be Planned?
PPWR testing does not mean that every packaging SKU must automatically be sent to a laboratory. A risk-based strategy can group equivalent products by base material, formulation, additives, process, supplier, and intended use, then select representative or higher-risk samples. The technical file should record why the selected sample represents the declared packaging range.
Review the Full Packaging Structure
The evidence plan should extend beyond the main substrate. Typical points for review include:
Pallets: the main pallet body, nails and other metal parts, coatings, paints, and labels.
Strapping: the base polymer or metal, buckles or seals, inks, and coatings.
Drums: body, lid, valves, gaskets, handles, coatings, and labels.
IBCs: inner container, steel frame, pallet, corner protectors, valves, closures, and venting components.
FIBCs: woven fabric, liner, lifting loops, seams, sewing thread, labels, and closures.
Corrugated boxes: board, printing inks, adhesives, tape, labels, coatings, and staples.
Check Whether Supplier Reports Still Cover the Finished Package
A raw-material report supports the final compliance conclusion only when the material, formulation, processing, and actual packaging remain within its scope. If plain board is subsequently printed, coated, glued, or combined with tape to create a box, the board report alone will not normally cover the added inks, coatings, adhesives, or tape.
What Should the Technical Documentation Contain?
The technical file should provide a traceable conformity basis for the packaging covered by the DoC. Depending on the packaging and applicable requirements, the file should record:
packaging description, structure, function, and intended use;
materials, component list, weight, specifications, and suppliers;
test reports, supplier declarations, assessment records, and the rationale for representative samples;
recyclability, reuse, and other applicable evaluation results;
traceability information linking the packaging type, batch, or other identifier to the file;
the basis for any exemption or derogation relied upon; and
the packaging types, variants, sizes, and specifications covered by the EU DoC.
The file and DoC should be reviewed when the material, formulation, structure, supplier, manufacturing process, intended use, or applicable legal requirement changes. Version control is essential: a DoC that covers multiple formats remains defensible only while the underlying conformity evidence remains representative.
A Five-Step PPWR Starting Plan for Exporters
Build a packaging inventory. Record every pallet, box, film, strap, cushioning material, drum, IBC, FIBC, and other packaging format by material, specification, supplier, food-contact status, and actual configuration.
Map responsible operators. Review branding, design control, procurement, final processing, import routes, and destination Member States to identify the manufacturer, importer, supplier, and EPR producer roles.
Define packaging and documentation units. Decide which packaging formats require separate conformity files and which components can be covered within one complete packaging unit.
Collect supply-chain evidence and design the assessment plan. Obtain specifications, composition data, supplier declarations, test reports, process information, and batch-traceability records before selecting representative samples.
Establish change control and regulatory monitoring. Reassess the evidence when suppliers, materials, structures, or uses change, and track delegated acts, implementing acts, standards, and official FAQs.
PPWR Conformity and Packaging EPR Are Different Workstreams
Packaging conformity and packaging extended producer responsibility (EPR) are connected but distinct. EPR registration, reporting, and fee payment do not replace the packaging assessment, supporting evidence, technical documentation, traceability, or EU DoC. Companies should map product-conformity duties and Member State-level EPR duties separately, then connect them through one packaging inventory and governance process.
How REACH24H Can Support Industrial and Transport Packaging
REACH24H supports manufacturers, exporters, brand owners, importers, and packaging suppliers with packaging-specific PPWR implementation, including:
packaging scope, configuration, and responsible-operator assessment;
risk-based testing and supplier-evidence strategy;
recyclability and reuse assessment; and
technical documentation and EU DoC preparation or review.
Need to assess your industrial or transport packaging?
Submit your packaging list to identify how pallets, stretch wrap, straps, drums, IBCs, or FIBCs should be assessed and documented under the EU PPWR.
Recommended Reading
EU PPWR Declaration of Conformity: Who Signs, When to Update and How to Group Multiple SKUs
EU PPWR Guidance 2026: Key Compliance Requirements and Timelines
PPWR Traceability and Enforcement: What the August 2026 FAQ Means for Packaging Operators
ECHA Circulates Draft List of Around 700 PPWR Substances of Concern
