For manufacturers, retailers and packaging buyers, this means looking beyond whether packaging simply performs its immediate function. Material composition, recyclability, the amount of packaging used and the information available about it are all becoming part of the same regulatory picture.

Responsibility is moving through the supply chain in both directions

One consequence is a changing relationship between different parts of the packaging supply chain. Companies increasingly need information from their suppliers while also being responsible for providing relevant information to their own customers.

Lasse Borg, CEO of Finnish paper packaging manufacturer and flexographic printing house Carccu®, believes this represents a significant change in how responsibilities are distributed.

“Many customers and manufacturers do not understand that in the future,

responsibilities will run both ways in the value chain – up and down. Previously, they only flowed downwards,” Borg says.

In practice, this means that decisions made by a raw-material supplier can have implications several stages further down the chain. Packaging manufacturers and buyers therefore need to know which requirements apply to a particular product and what information is required to support it.

Chemical restrictions are already affecting food packaging

Some of the regulatory changes are already tangible. New PPWR limits for per- and polyfluoroalkyl substances, or PFAS, in food-contact packaging took effect on the 12th of August 2026. The transition period for the EU ban on bisphenol A (BPA) in food-contact materials had ended the previous month.

The PFAS restrictions are particularly relevant to applications where resistance to grease or water is required. Such performance has traditionally sometimes been achieved with fluorinated substances, but paper packaging can also rely on other approaches. In parchment-type papers, for example, grease resistance can be created through a tightly compacted cellulose-fibre structure, while other applications can use PFAS-free barrier solutions.

The change illustrates a practical challenge for the packaging sector: when a substance is restricted, an alternative must still provide the properties required by the application. Regulatory compliance and technical performance must therefore be considered together.

Recyclability is becoming a design question

The PPWR also shifts attention towards what happens to packaging after use. All packaging placed on the market must be recyclable, with more detailed design-for-recycling criteria following later in the implementation timetable.

That makes recyclability something to consider during product development rather than only when the package reaches the waste stream. Coatings, labels, sleeves and combinations of different materials all form part of the structure that eventually enters a recycling system.

Printing can form part of the same design equation. Flexographic printing transfers ink directly onto paper and, where the application allows, can provide branding, instructions or other information without requiring a separate label. Carccu®, for example, uses water-based inks in flexographic printing on paper substrates.

This means that recyclability is increasingly influenced by decisions made well before packaging reaches the consumer: not only the choice of base material, but also what is added to it and how the required information is incorporated.

Less packaging is another part of the equation

Recyclability addresses what happens after packaging has been used. Waste prevention asks an earlier question: how much packaging needs to enter the system in the first place?

The PPWR targets unnecessary packaging and introduces measures concerning empty space, reuse and certain single-use formats. Dimensions, layers, labels and protective materials consequently become relevant not only from a practical perspective but also in efforts to reduce packaging waste.

This does not mean simply using as little material as possible. Different applications have different requirements: food paper may need grease or heat resistance, a paper bag sufficient strength, and protective wrapping properties suited to storage or transport. The practical question is whether those requirements can be met without unnecessary material or complexity.

Proving that compliance is becoming part of the packaging process

Meeting regulatory requirements also involves being able to demonstrate that they have been met. This is where documentation, certification and traceability become particularly important.

Carccu® provides one example of how this works at manufacturer level. According to the company’s practices, PFAS and heavy-metal limits are verified through the supply chain and food-contact requirements are covered by Declarations of Compliance. The origin of certified virgin fibre is documented through FSC® Chain of Custody and PEFC Chain of Custody certification, while the company also operates under ISO 9001 and ISO 14001 quality and environmental management systems.

As Borg has put it in discussing certification:

“Certification is proof through an external audit that we operate responsibly.”

The need for such evidence extends beyond the PPWR itself. Food-contact requirements continue to apply alongside the new packaging regulation, while forest-based packaging can involve additional questions concerning raw-material traceability. A single packaging product can therefore be subject to several overlapping requirements.

August 2026 was a starting point

The PPWR did not bring all of its requirements into effect at once on the 12th of August 2026. While the regulation became applicable on that date, more detailed requirements in areas including design for recycling, recycled content, labelling, unnecessary packaging, reuse and certain single-use formats will take effect in stages. Manufacturers, retailers and packaging buyers will therefore need to follow the developing framework while making decisions about products that may remain in use for years.

The direction of travel is nevertheless clear. Packaging is increasingly being assessed as a whole: what it contains, how it performs, how much material it uses, what happens to it after use and whether businesses can provide the information needed to demonstrate compliance.

For companies operating in this environment, the ability to respond to changing requirements may consequently become as important as any individual material choice.

“When we do our best, I trust that it will be enough; we are capable of rapid changes, so we can keep pace with the world,” Borg says.