PPWR requirements by packaging level (primary, secondary, tertiary)

Three levels, different duties

It helps to separate packaging into the three levels the regulation treats differently.

Primary & secondary (the box)

• Structural integrity still matters for freight survival — e.g. a minimum Edge Crush Test (ECT) rating such as 32 ECT for standard goods, higher for heavy items. This is a logistics requirement, not a PPWR one, but it sits on the same spec.
• Design for recycling — declare the packaging's likely recyclability grade.
• Recycled content — for plastic components, declare the post-consumer recycled share. Minimum recycled-content thresholds for plastic packaging start applying from 2030, so aligning supplier sourcing now avoids a later scramble.

Tertiary (the pallet)

This is where PPWR bites hardest for importers. The regulation limits empty space in grouped, transport and e-commerce packaging. The commonly cited cap is no more than 50% empty space — some earlier drafts referenced a lower figure (around 40%), so confirm the final adopted percentage against the official text for your packaging type. Practically, your spec should force suppliers to declare pallet footprint, material, the void space their packing method leaves, and any filler used.

• Wood pallets — international freight already requires ISPM 15 heat-treated, certified wood (or plastic alternatives) to clear customs. Ban raw, untreated wood explicitly.
• Overhang & stacking — state hard numbers (no-overhang policy, maximum stack height, weight cap). These intersect with the minimisation principle: packaging sized to the minimum necessary for safe function.

Labelling

Existing warehouse labelling (barcode placement, labels per pallet, visibility outside the stretch wrap) now sits alongside PPWR's harmonised labelling rules — EU-wide recycling symbols and, increasingly, QR-code data carriers linking to material composition and recyclability information.

This is general guidance. Verify exact thresholds and grades against the official consolidated regulation.