The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the new European packaging regulation that gradually introduces requirements for all packaging placed on the EU market — including cold chain packaging such as Polystyrene Boxes, thermal boxes and insulation materials. As a Dutch manufacturer of cold chain packaging, we have aligned our products and documentation accordingly. On this page, you can read what the PPWR entails, what it means for your cold chain packaging and which documentation we provide as a manufacturer.
What is the PPWR?
The PPWR replaces the old Packaging Directive (94/62/EC) and is — unlike a directive — a regulation: the rules apply directly and uniformly in all EU Member States, without national transposition. The regulation entered into force in early 2025 and the main obligations will apply gradually from August 2026.
The key principles of the PPWR:
- All packaging must be recyclable — from 2030, minimum recyclability performance classes will apply, with stricter requirements in 2038.
- Minimisation — packaging must not be larger or heavier than necessary for its function.
- Restrictions on substances of concern — including limit values for PFAS in food-contact packaging.
- Mandatory documentation — manufacturers must be able to demonstrate conformity with technical documentation and an EU Declaration of Conformity.
- Labelling and recycled content — harmonised labelling and, for plastic packaging, minimum percentages of recycled material in later phases.
What does the PPWR mean for EPS cold chain packaging?
EPS (expanded polystyrene) remains permitted under the PPWR as transport packaging. However, there are requirements that you, as a user of cold chain packaging, should take into account:
Recyclability
EPS is a mono-material and highly recyclable through specialised collection streams: clean EPS is compressed and processed into new insulation and packaging material. Under the PPWR, recyclability is classified into performance classes; we document per product type how our packaging performs and through which streams it can be recycled.
PFAS in food-contact packaging
The PPWR sets limit values for PFAS in packaging that comes into contact with food. Our Polystyrene Boxes are produced without the addition of PFAS; on request, we provide a PFAS declaration for each product.
Minimisation and sizing
Packaging must be appropriate for its function. For cold chain packaging, wall thickness is functionally determined by the required insulation performance — we substantiate this in our technical documentation. In practical terms, this also means: choose a box that is just large enough for your product and gel packs. Our buying guide can help you with this.
Which documentation do we provide?
As a manufacturer, we make the following PPWR documentation available to our business customers:
- EU Declaration of Conformity per product type
- PFAS declaration for food-contact applications
- Recyclability information sheets with material specification and collection stream
- Technical documentation and material specifications on request
Do you ship food or pharmaceuticals and does your quality department need these documents? Email us at info@cooledsolutions.com with the products you purchase — you will usually receive the documentation within a few working days.
PPWR timeline
- February 2025 — PPWR entered into force
- August 2026 — main obligations apply, including conformity requirements and PFAS limit values for food contact
- 2030 — all packaging must be recyclable (design-for-recycling classes)
- 2035–2038 — stricter requirements: recyclability “at scale” and higher standards
Frequently asked questions
Can I still use Polystyrene Boxes after 2026?
Yes. EPS transport packaging remains permitted. The PPWR does not ban materials, but sets requirements for recyclability, substances of concern and documentation. Our Polystyrene Boxes comply with these requirements and we provide the corresponding declarations.
As a webshop or wholesaler, am I responsible myself?
The primary obligations lie with the manufacturer of the packaging. As a customer, however, you must be able to demonstrate that your packaging is compliant — for this, you use your supplier’s Declaration of Conformity. We provide this as standard to business customers.
Is EPS recyclable enough for the 2030 requirements?
EPS is a mono-material with an existing recycling stream and can be recycled effectively provided it is collected cleanly. We monitor the delegated acts in which the EU will define the final recyclability performance classes and update our documentation accordingly.
Does the PPWR also apply to thermal boxes, insulation film and gel packs?
Yes, the PPWR applies to all packaging and packaging components. Documentation is also available for our thermal boxes, insulation film and ice packs.
Ready to get started? View our Polystyrene Boxes from our own Dutch production, or request a quote — including the PPWR documentation your organisation needs.
This page is intended as a practical introduction and does not constitute legal advice. For your specific obligations, please consult the text of Regulation (EU) 2025/40 or your compliance adviser.