The Packaging and Packaging Waste Regulation (PPWR) introduces new measures to reduce packaging waste and improve resource efficiency across the European Union. Two important provisions are Article 9, which establishes requirements for compostable packaging, and Article 10, which focuses on minimising packaging volume and weight. These articles aim to ensure that packaging is designed with sustainability in mind while reducing unnecessary material use.

As businesses prepare for future PPWR obligations, manufacturers and importers should review their packaging portfolios, product designs, and technical documentation. Early preparation will help organisations meet future requirements while supporting circular economy objectives.

What You Need To Understand?

Articles 9 and 10 address two different aspects of sustainable packaging. Article 9 specifies where compostable packaging is mandatory and establishes technical standards for compostability. Article 10 requires packaging to be designed using only the minimum amount of material necessary to perform its intended function, helping reduce packaging waste at its source.

Key Requirements

Articles 9 and 10 introduce practical requirements that help reduce packaging waste and improve sustainability. Businesses must understand where compostable packaging is required and ensure packaging is designed using only the minimum material necessary while maintaining product performance and safety.

Mandatory Compostable Packaging

Article 9 introduces mandatory compostability for specific packaging applications. From 12 February 2028, sticky labels attached to fruit and vegetables, along with permeable tea bags, coffee pods, and similar single-serve beverage units intended to be disposed of together with their contents, must meet the applicable compostability requirements.

Compostability Standards

Compostable packaging must be compatible with industrial composting standards. Where required by Member States, it must also meet home compostability standards. The European Commission will request harmonised technical standards for home compostability to support consistent implementation across the EU.

Packaging Minimisation Requirements

Article 10 establishes that packaging must be designed so its weight and volume are reduced to the minimum necessary while still protecting the product and fulfilling its intended purpose. Packaging must not include unnecessary components or be designed to create a misleading impression about the quantity of the product.

Performance Criteria and Prohibited Packaging

Starting from 2030, manufacturers and importers must ensure packaging complies with the performance criteria established under Article 10. Packaging designed solely to increase the perceived product volume without serving a functional purpose will be prohibited under the regulation. Certain exemptions apply for protected packaging designs and products covered by geographical indications.

Implementation Deadline & Challenges

Article 9 introduces key milestones beginning in 2026 and 2028, while Article 10 introduces mandatory performance criteria from 2030. Although these deadlines may appear distant, businesses should begin evaluating packaging designs and materials well in advance to avoid future compliance challenges.

What Will Be the Main Challenges?

Meeting the requirements of Articles 9 and 10 may require businesses to review packaging materials, redesign existing packaging, and collect supporting documentation. Early planning will help organisations address compliance challenges while preparing for future PPWR implementation deadlines.

Identifying Compostable Packaging Applications

Businesses must determine whether their packaging falls within the mandatory compostable packaging categories and ensure appropriate materials are selected for compliance.

Meeting Compostability Standards

Demonstrating compliance may require testing, certifications, and technical documentation showing compatibility with recognised industrial or home composting standards where applicable.

Reducing Packaging Without Affecting Performance

Packaging minimisation requires balancing material reduction with product protection, transportation, and functionality. This often requires redesigning existing packaging solutions.

Updating Technical Documentation

Manufacturers and importers should maintain accurate technical documentation to demonstrate compliance with PPWR requirements and support future conformity assessments.

This is How We Simplify Your Compliance Process

Preparing for Articles 9 and 10 requires more than understanding the regulation. Businesses also need practical processes to assess packaging, manage documentation, and collect supplier information. PackIntelX helps simplify these activities through structured compliance solutions designed for evolving PPWR requirements.

Packaging Design Reviews

Evaluate packaging designs to identify opportunities for packaging minimisation while maintaining functionality and regulatory compliance.

Technical Documentation Management

Organise compliance records, supporting evidence, and technical documentation within one structured platform.

Supplier Data Collection

Collect material declarations, technical specifications, and supporting documentation digitally from suppliers to strengthen compliance processes.

PPWR Compliance Assessments

Review packaging portfolios against Articles 9 and 10 to identify potential compliance gaps before implementation deadlines.

Key Takeaway

• Article 9 introduces mandatory compostable packaging requirements for specific packaging applications.
• Compostable packaging must comply with recognised technical compostability standards.
• Article 10 requires packaging weight and volume to be reduced to the minimum necessary.
• Packaging designed only to increase perceived product volume will be prohibited.
• Early packaging assessments and documentation management will help businesses prepare for future PPWR obligations.

Conclusion

Articles 9 and 10 strengthen the PPWR’s objective of reducing packaging waste while supporting more sustainable packaging design. Businesses should begin by assessing where compostable packaging is required, reviewing existing packaging designs, and preparing the documentation needed to demonstrate future compliance. Taking action early will help organisations reduce compliance risks and prepare for upcoming implementation deadlines.

Preparing for PPWR starts with understanding your obligations. PPWR Conformity by PackIntelX provides efficient solutions forn businesses to organise compliance data, assess packaging requirements, and simplify technical documentation for evolving packaging regulations.