The real impact of the 3 new categories in Europe’s 2026 PPWR regulations on printing companies—3 things that must be done whenever products are sold to EU customers, regardless of whether the printing company is an exporter

Why I Wrote This Article

In November 2025, Mr. Zhang, the owner of a printing factory in Jiangsu specializing in branded packaging, approached me: “I have a client that is a domestic maternal and infant brand. Their products are sold in Germany, but they require my packaging to comply with the EU PPWR. I’m completely bewildered—I don’t even have any EU clients, so why should I follow EU regulations?” Mr. Zhang’s confusion is widely shared.

PPWR is the EU Packaging and Packaging Waste Regulation, adopted in December 2024 and entering into force in February 2026. Its purpose is to reduce packaging waste and advance the circular economy. In Europe, this regulation is known as PPWR (Packaging and Packaging Waste Regulation), while Chinese printing plants often hear it referred to as the “Sustainable Packaging Regulation” or the “EU Packaging Environmental Upgrade.”

The regulation’s core impact on Chinese printing companies is “upstream transmission”: if a printing company’s customers (finished-product manufacturers or brands) sell their products to the EU, the packaging produced by the printing company must comply with PPWR. Even if the printing company has no direct export business, as long as the products ultimately enter the EU market at any stage of the supply chain, the printing company must comply with the regulation.

Mr. Zhang later asked me 3 questions: 1) Should the printing plant proactively upgrade to PPWR now? 2) If so, what needs to be changed? 3) What would happen if it did not make the changes? This article answers these 3 questions and clearly explains the 3 things the printing plant can start doing now.

PPWR Category 1 Impact: Recyclable Design—All Packaging Sold in the EU Must Be Designed According to 5 Criteria

PPWR sets forth 5 specific standards for “recyclable packaging design.” The printer’s product structure design, material selection, and ink usage must all comply with these standards. The 5 standards will become mandatory from February 11, 2027, with a 1-year transition period in between.

Five standards for recyclable design:

The impact of these 5 standards when actually implemented by the printing plant:

A. Impact on Print Design: When the proportion of dark colors in the customer’s design is substantial, the printer must inform the customer that “the recyclability of this design is poor and may affect sales in the EU.” If the customer insists, the printer must reject the design or make adjustments.

B. Impact on Material Selection: Many customers now request “white cardboard + matte film” laminated gift boxes. This material has poor recyclability because the lamination film makes separation difficult at recycling facilities. Printers should proactively recommend the alternative of “white cardboard + local UV coating.” Although the visual effect differs slightly, this alternative offers much better recyclability.

C. Impact on Ink Selection: Certain brands' spot inks (especially fluorescent/metallic inks) are prone to excessive heavy metal content. Printers must test the EN 71-3 report for each batch of ink and record it in the “ink file.”

The printshop’s practical compromise on recyclable design: shifting from “print whatever the customer wants” to “deliver what the customer wants + recyclable constraints.” This adjustment raises the professional demands on the printshop’s designers by one level.

PPWR Impact Category 2: Share of Recycled Materials—30% Recycled Plastics by 2030, 50% by 2040

PPWR has a clear timetable for the "minimum recycled content percentage" for different packaging materials:

This regulation has a significant impact on printers’ “upstream supply chain management.” When printers procure raw materials (paper/plastic/ink/adhesive), they must obtain the supplier’s “recycled content ratio declaration.”

Practical execution difficulties:

Difficulty 1: Suppliers are unwilling to issue declarations. Many small and medium-sized raw material suppliers, including those of domestic raw materials, do not have measured data on the “recycled content percentage.” They can only provide vague statements such as “estimated 10-30% recycled.” The printing plant needs to replace these suppliers with suppliers that have FSC/PEFC certification or PEFC recycled certification.

Challenge 2: Relationship between recycled content and price. Raw materials with a high proportion of recycled material are 10-30% more expensive, so printing plants need to factor this into their quotations in advance; otherwise, customers will not accept them.

Challenge 3: Third-Party Verification of Recycled Content Percentage. Customers may require printing plants to provide a "third-party verification report of the recycled content percentage of raw materials." At present, only a limited number of laboratories in China can issue such reports, so printing plants should make arrangements in advance.

3 things the printing plant can start working on now:

PPWR Category 3 Impact: Excessive Packaging Restrictions—A Void Space Ratio Exceeding 40% May Result in Fines of 3-5% of Turnover

Article 22 of the PPWR defines “excessive packaging” as packaging with a void rate exceeding 40%. Void rate = (total packaging volume - product volume) / total packaging volume.

This development will have a massive impact on the gift box industry. Gift box customers traditionally expect packaging to look “premium and spacious,” but PPWR requires it to be “compact.” An empty space ratio of over 40% is very common in China’s gift industry—for example, a gift box containing 50ml of perfume is often designed with an internal capacity of 200ml, resulting in an empty space ratio of 75%.

Penalty rules: From February 2026, excessive packaging may be subject to a fine of 3-5% of the packaged product's turnover. Large brand owners may face fines of up to EUR 15 million or 5% of global turnover.

The logic of holding the printing plant jointly liable is as follows: the printing plant designed the gift box, and the customer’s finished product was sold to the EU. The customer’s void ratio was noncompliant, resulting in a fine. The customer may then trace the matter back to the printing plant’s “noncompliant design” and seek compensation.

The printing plant’s response strategy:

Strategy 1: Redesign the gift box. Design the gift box dimensions to the minimum volume required for the “product + cushioning,” keeping the void ratio within 25-35%. This makes the gift box appear “one size smaller” visually while complying with PPWR.

Strategy 2: Add a clause to customer contracts. Add a “packaging void ratio control” clause to contracts with printing plants and EU customers, specifying that if the customer requests an excessively packaged design, the customer shall bear liability for any PPWR penalties. This clause protects printing plants against joint liability.

Strategy 3: Provide 2 sets of designs. The printer will present the customer with 2 sets of design drafts: 1 “traditional grand-scale version” (void rate 50%+; not suitable for the EU market), and 1 “PPWR-compliant version” (void rate 35%; suitable for the EU). The customer will select based on the final target market.

Execution Priorities for the 3 Types of Impact

Three types of factors that affect the actual priorities of printing plants:

The most common mistake among printing plant owners is to “wait until February 2026.” However, printing plant customers are already signing contracts in accordance with PPWR. Printing plants that start making changes now will be compliant by February 2026; those that do not start now risk being penalized by EU customers after February 2026.

3 Things the Printing Factory Can Start Doing Now

3 items sorted by cost from lowest to highest:

Task 1: Establish a “List of Customers Subject to PPWR” (cost: RMB 0). The printing plant should list all cooperating customers and identify which of their products are ultimately sold to the EU. Once the list is established, orders from these customers should be produced in compliance with PPWR requirements as a priority. When the printing plant’s sales team communicates with customers, they can proactively ask: “Where is the final destination of sale for your products?”

Item 2: Map Raw Material Suppliers (Cost 1-3 Ten-Thousand Yuan). The printing plant categorizes its existing raw material suppliers into: 1) suppliers with FSC/PEFC recycled-content certification; 2) suppliers that make a “recycled content” claim; and 3) suppliers with neither. Cooperation should be prioritized with the first two categories, gradually replacing the third.

Item 3: Establish PPWR documentation (cost RMB 30,000–80,000). The printing plant establishes one set of “PPWR Compliance Documentation,” including: 1) proof of recycled content percentages in raw materials; 2) a packaging void ratio calculation sheet; 3) an ink EN 71-3 report; 4) a customer PPWR compliance undertaking for orders; and 5) an internal PPWR audit system for the printing plant. Once the documentation is complete, the customer’s compliance review passes on the first attempt.

The printing factory can proceed in stages: first complete Task 1 (at zero cost), then Task 2 (10,000–30,000), and finally Task 3 (30,000–80,000). With a total investment of 40,000–110,000, the printing factory will have established the foundation for PPWR compliance.

Further Reading