In short: The European Packaging and Packaging Waste Regulation, the PPWR, has been generally applicable since August 12, 2026. It regulates the physical packaging, not what you say about it. For those who buy corporate gifts, three things have already changed. False bottoms and double walls to make the box look bigger are a thing of the past, empty space cannot exceed 40 percent in shipping, and all packaging requires an EU declaration of conformity that your supplier should be able to show you.
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A different rule from the one we wrote about in September
A month ago we wrote about the directive regulating what you can say about a sustainable gift. That rule is about words. About green claims without backing, about the word "eco" printed on a lid, about claims that no one can back up if someone asks.
This is another one. Regulation (EU) 2025/40, known in the sector as PPWR, does not regulate what you say. It regulates the box. The material, the size, the empty space inside, the paperwork that accompanies it. They are two rules with two different objects and it is best not to mix them up, because complying with one does not cover the other.
The important date has already passed. The regulation was published in January 2025, came into force in February of that year, and after eighteen months of transition it has been generally applicable in the 27 Member States since August 12, 2026. That is, it has been in effect since the summer. If you closed your last corporate order before August, the next one already plays by different rules.
The false bottom, which was almost a tradition
Here is the change that will be most noticeable in the corporate gift, and it is the least discussed.
The regulation prohibits double walls, false bottoms, and any design element whose sole function is to increase the perceived volume of the packaging. Read it again thinking about the last corporate gift box you received. The one that had a 600-milliliter bottle inside a case the size of a shoebox, with a raised tray so that the product was at eye level and there was nothing underneath. That is exactly what the rule points out.
In addition, empty space is limited to 40 percent in transport and e-commerce packaging. For an order of two hundred units shipped to two hundred different homes, which is how a good part of remote team gifting works today, that figure ceases to be an aesthetic detail and becomes a design restriction.
The cynical reading is that the sector had been selling expensive air for years. The practical reading is more useful. If your supplier shows you an impressive case, now is the time to ask how much of that volume is product.
The document you should ask for and almost no one asks for
Since August, all packaging requires an EU declaration of conformity. It is the document that certifies that the packaging complies in recyclability, recycled content, reuse, labeling, and substance restriction.
Regarding substances, there is a point that affects more catalogs than it seems. Food contact packaging cannot exceed the technical limits of PFAS, the so-called perfluorinated compounds, and the limit of 100 milligrams per kilo for heavy metals is maintained. This covers paper cups with greaseproof coating and takeout food boxes, products common in welcome packs and event merchandising.
The formal responsibility for compliance lies with whoever manufactures, imports, or distributes the packaged product, not with the company that buys the gift. But the nuance matters little when the package carries your logo. If the packaging you distribute to your staff does not comply, the problem lands on your brand before the manufacturer's, just as happens with environmental claims.
Asking for the declaration of conformity costs one email. It is the cheapest question on the whole list and the one that most quickly separates a supplier who has their house in order from one who improvises.
What is coming, and why it conditions next year's order
PPWR is being rolled out in phases and the next ones arrive sooner than it seems.
| Date | What changes |
|---|---|
| February 2027 | The hospitality industry will have to allow the customer to use their own reusable packaging. |
| August 2028 | Mandatory harmonized labeling, with information on materials and recyclability. |
| January 2029 | Separate collection of 90 percent of single-use plastic bottles and beverage cans. |
| January 2030 | Only packaging with recyclability classification A, B, or C. Minimum percentages of recycled content in plastic packaging, between 30 and 65 percent depending on the type. Reuse targets for part of the transport packaging. |
| 2038 | Only A or B classifications are allowed. |
It is best to undo a misunderstanding that is circulating. Harmonized labeling, which includes indicating the reusability of a package, is not an obligation in force today. It arrives in August 2028. If someone is selling you a service now to comply with that urgently, they are two years ahead of schedule.
The other piece that is best to have on the radar is extended producer responsibility. The regulation provides that the financial contribution of each package is modulated according to its recyclability classification, which applies from 2030. Translated, the poorly designed package ceases to be just an image problem and starts to cost more money.
Five questions before closing the end-of-year order
If you are closing the Christmas order, which is what is due in these weeks, these five questions cover almost everything the rule will require you to explain later.
- Can you send me the EU declaration of conformity of the packaging?
- What percentage of the box volume is product and how much is empty space?
- Does the case have raised trays, double walls, or a false bottom?
- If it is shipped to individual homes, does the transport packaging respect the 40 percent empty space limit?
- What material is the packaging exactly made of and what recyclability classification does it have?
A serious supplier answers all five without getting nervous. One who has not looked at them will answer you with adjectives.
The beautiful thing has to be the product
There is an irony in all this for those who have been choosing a useful gift instead of a flashy gift for a long time. An object that is used daily does not need a case that makes it look more expensive. The work that remains is the same for everyone: ask the supplier to answer the five questions above, as well as us.
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The rule does not force anyone to stop making beautiful gifts. It forces the beautiful thing to be the product and not the volume of the box. For part of the sector that is a complete redesign. For another it is to keep doing the same thing.
If you are reviewing suppliers for the last quarter, in the Christmas gift planning guide is the calendar of deadlines, and in the sustainable corporate gifts guide the complete selection criterion. To see where the market is going this year, the 2026 corporate gift trends provide the context.
One last thing that is best to say clearly. This is general information about a public rule, not legal advice, and we do not claim to be certified or audited under the PPWR. If your company has doubts about how it applies to you, that conversation is with your advisor.
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For the end-of-year gift that is used in the office and at home.
If you want to review how a corporate order would fit with these criteria, you can request a proposal here. We work with orders from 20 units.
Written by the Fluye Bottle team