EU PPWR 2025/2026: The Complete Guide for European Packaging Buyers — What the New Regulation Means for Your Strapping and Stretch Film

Breaking Update (25 February 2026): The European Commission adopted a landmark decision exempting companies using pallet wrapping film and strapping bands from the 100% reuse obligation under the EU PPWR — the most significant packaging regulation development of 2026.

The EU Packaging and Packaging Waste Regulation (PPWR) — Regulation (EU) 2025/40 — is the most comprehensive overhaul of European packaging law in three decades. For procurement managers, supply chain directors, and packaging engineers buying strapping bands and stretch film for European operations, understanding PPWR is no longer optional. It is a compliance requirement, a tender qualification criterion, and — for those who get ahead of it — a competitive advantage.

This guide gives European packaging buyers the complete picture: what PPWR requires, what the February 2026 exemption changed, what it did not change, and exactly how Greenstrix supports your compliance journey.

1. What Is the EU PPWR? — The 50-Word Answer

Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — entered into force on 11 February 2025. It replaces the 1994 Packaging Directive (94/62/EC) with legally binding requirements covering all packaging placed on the European market. The headline obligations are: 100% recyclability for all packaging by 2030, a 40% reuse target for transport packaging by 2030, mandatory recycled content, and strengthened Extended Producer Responsibility (EPR) across all EU member states.

PPWR applies to all economic operators in the packaging supply chain — manufacturers, importers, distributors, and users of packaging — wherever in the world those operators are based, if their packaging enters the European market.

2. The February 2026 Exemption — Critical News for Strapping and Film Users

Under the original PPWR text, Articles 29(2) and 29(3) required that transport packaging — including pallet wrapping film and strapping bands — meet a 100% reuse obligation by a defined transition date. This was widely interpreted as requiring operations to switch entirely to reusable strapping and film systems, eliminating single-use materials from European logistics entirely.

On 25 February 2026, the European Commission adopted a delegated decision granting a targeted exemption: pallet wrapping film and strapping bands are exempted from the 100% reuse obligation under Articles 29(2) and 29(3). This is a significant practical relief for European packaging operations — it means single-use stretch film and strapping remains compliant during the transition period.

What still applies: The exemption does not affect any other PPWR requirement. The 40% reuse target for transport packaging under Article 29(1) remains in force — though this applies at the portfolio level, not for each individual product category. The 100% recyclability mandate by 2030 is fully unaffected by the exemption. Every strap and every film roll you purchase must be recyclable by 2030.

3. PPWR Recyclability Requirements

The recyclability requirement is the most immediately actionable PPWR obligation for packaging buyers. From 2030, all packaging placed on the EU market must be recyclable — meaning it must be capable of being sorted and recycled at scale in existing European waste management infrastructure. The good news for strapping and film buyers: the standard materials already comply.

All five materials supplied by Greenstrix meet the PPWR recyclability criterion through established European industrial recovery streams. Greenstrix provides a Declaration of Conformity confirming recyclability status for each product on request.

4. PPWR Implementation Timeline

5. What PPWR Means for Different European Markets

Germany — Strictest Implementation, LUCID System

Germany operates the world's most advanced packaging take-back system — the LUCID register — which requires all companies placing packaging on the German market to register and pay EPR fees. Germany is aligning the LUCID framework directly with PPWR requirements, meaning that from 2026–2027, LUCID registration will increasingly require PPWR recyclability documentation for all packaging materials, including strapping and film. German procurement departments — among the most rigorous in Europe for supplier qualification — are already requiring PPWR compliance declarations as a standard tender condition.

France — AGEC Law Alignment

France's AGEC (Anti-Gaspillage pour une Économie Circulaire) law preceded PPWR and established a robust national framework for packaging sustainability. French regulators are aligning AGEC implementation with PPWR to create a unified compliance framework. French large-scale retailers have been among the first in Europe to include PPWR recyclability verification in their supplier qualification requirements — making compliance documentation essential for any packaging supplier targeting the French market.

Italy — CONAI EPR System

Italy's CONAI (Consorzio Nazionale Imballaggi) is one of Europe's most mature EPR systems, covering all packaging materials including strapping and film. Italian companies placing packaging on the market contribute EPR fees through CONAI, which funds collection and recovery. CONAI is directly integrating PPWR recyclability requirements into its material certification framework. For Italian operations, PPWR compliance documentation is increasingly required not just for tendering but for CONAI reporting.

Poland — Growing Enforcement

Poland is a rapidly growing manufacturing and logistics hub for European supply chains. Polish packaging regulation enforcement has historically lagged behind Germany and France, but is accelerating significantly as EU-level PPWR enforcement begins. Polish packaging buyers — particularly those supplying to German or French end-customers — are increasingly required to demonstrate PPWR compliance upstream. The Polish market presents a significant opportunity for compliant suppliers to differentiate from non-compliant commodity alternatives.

6. The PPWR Compliance Checklist

For European packaging buyers of strapping and film, the following actions constitute a practical PPWR compliance programme:

• Recyclability verification: Confirm that all strapping and film materials used are recyclable through existing EU recovery infrastructure — request written confirmation from each supplier
• Declaration of Conformity: Obtain a written Declaration of Conformity from each packaging supplier confirming PPWR recyclability status
• Material composition certificates: Obtain certificates identifying the polymer type and recovery pathway for each packaging material
• EPR registration audit: Verify your EPR registration status in each EU member state where you place packaging on the market (Germany: LUCID; Italy: CONAI; France: CITEO)
• 40% reuse planning: Begin planning for how your transport packaging portfolio will demonstrate progress toward the 2030 reuse target — document what reusable options exist for each application
• Supplier documentation standard: Establish a minimum documentation standard for packaging suppliers that includes recyclability declaration, material composition, and EPR compliance status
• Tender qualification review: Review all active and upcoming tenders to identify PPWR compliance requirements — proactively prepare documentation packages
• 2035 recycled content roadmap: Begin investigating recycled-content options for packaging materials to prepare for the 2035 mandatory recycled content targets

7. How Greenstrix Supports Your PPWR Compliance

Greenstrix provides European buyers with a complete PPWR compliance documentation package with every supply arrangement:

• Declaration of Conformity confirming recyclability status for each product supplied
• Material composition certificates identifying polymer type and recovery pathway
• ISO-certified quality management with full batch traceability from resin to finished product
• DUNS registered — internationally verified business identity for procurement qualification
• DGFT authorized exporter — full Indian export regulatory compliance for all European shipments
• Europe-dedicated commercial team at +49 176 85614141 for compliance query support

As a supplier based outside the EU, Greenstrix recognizes that European buyers have heightened documentation requirements for non-EU packaging suppliers. Our compliance documentation is structured specifically to meet the needs of German, French, Italian, and Polish procurement qualification processes.

8. Related Guides

• PET Strapping Band — Complete Technical Guide
• PP Strapping Band — Complete Technical Guide
• LLDPE Stretch Film — Complete Technical Guide
• Shrink Film — Complete Technical Guide
• Composite Cord Strap vs Steel — Complete Engineering Evidence
• How to Reduce Industrial Packaging Costs in Europe 2026
• PET vs PP vs Cord Strap — The Definitive Selection Guide