Paper and cardboard packaging generally faces lower regulatory burden than plastic under the PPWR, but faces specific requirements around PFAS (per- and polyfluoroalkyl substances), recyclability, and food contact compliance. This guide covers PPWR requirements for paper and cardboard packaging.
PFAS Restrictions for Food Contact Paper
The PPWR and related EU chemical regulations are progressively restricting PFAS in food contact paper and cardboard. PFAS are used in food contact paper to provide grease and water resistance (e.g., fast food wrappers, pizza boxes, microwave popcorn bags). The EU's PFAS restriction under REACH entered into force in 2023 for food contact paper, prohibiting PFAS above 0.1 mg/m² per individual substance or 1 mg/m² for the sum of PFAS.
Recyclability Requirements
Paper and cardboard packaging must be recyclable from 2030. Key recyclability issues include: wet-strength resins that prevent repulping; plastic coatings and laminates that contaminate paper recycling streams; silicone release liners; and composite packaging with inseparable paper and plastic components.
Fibre-Based Packaging
The PPWR encourages substitution of plastic packaging with fibre-based alternatives where technically feasible. However, fibre-based packaging must meet the same minimisation, recyclability, and eco-design requirements as other packaging materials. Fibre-based packaging that is contaminated with food or moisture may not be recyclable and must be designed to minimise contamination.