The EU Packaging and Packaging Waste Regulation is changing the way businesses evaluate packaging entering the European market.
For Malaysian manufacturers exporting to Europe, preparing for PPWR does not necessarily begin with completely redesigning every package.
It begins with understanding what packaging you currently use.
Regulation (EU) 2025/40 applies generally from 12 August 2026 and covers packaging regardless of material or origin.
The following checklist provides a practical starting point for businesses reviewing their transport packaging.
PPWR Packaging Review Checklist
1. Identify Every Packaging Component
Start with the complete shipment.
Do not examine only the outer box.
A typical industrial shipment may include:
– Product packaging
– Inner supports
– Cartons
– Pallet
– Divider sheets
– Corner protection
– Cushioning
– Strapping
– Stretch film
– Void fillers
– Top protection
Create a list of every component.
This helps reveal where materials may be unnecessary or where multiple components perform the same function.
2. Record the Material Used
For every packaging component, identify its main material.
Understanding the material composition is an important first step towards evaluating recyclability.
PPWR introduces requirements relating to packaging composition and the recyclable or recoverable nature of packaging placed on the EU market.
3. Ask: Is the Packaging Designed for Recycling?
Recyclability is one of the central directions of PPWR.
Ask:
Q – Can the packaging be recycled?
Q – Can different materials be separated easily?
Q – Are unnecessary mixed-material components being used?
Can difficult-to-recycle components be reduced?
Eltete TPM describes fibre-based transport packaging and simplified material structures as part of its approach to recyclability and circular packaging.
4. Check for Unnecessary Packaging
Look at every component and ask:
What function does this perform?
It should have a clear answer.
Possible functions include:
– Carrying the load
– Protecting corners
– Cushioning the product
– Stabilising boxes
– Securing the load
– Distributing pressure
– Preventing movement
If material has no clear function, it should be reviewed.
PPWR specifically aims to prevent unnecessary packaging and reduce packaging waste.
5. Measure Empty Space
Check the amount of empty space inside:
– Cartons
– Cases
– Pallet loads
– Export packaging
Excessive empty space can require additional materials just to prevent products from moving.
A better packaging configuration may reduce both empty space and the amount of protective material required.
6. Review Packaging Weight
Record:
Product weight
versus
Complete packaged weight
Then calculate how much weight is coming from transport packaging.
If a heavier component can be replaced with a suitable lighter solution while still meeting the required performance, it may improve overall logistics efficiency.
Eltete uses this principle across several fibre-based transport-packaging solutions.
7. Review Your Pallet or Load Carrier
The pallet can represent a significant part of the material and volume associated with a shipment.
Depending on the application, businesses may evaluate alternatives such as:
– Slip Sheets
Thin kraftliner load-support sheets used for palletless handling where compatible equipment is available.
– Paper Pallets
Paper-based raised load carriers for applications where a conventional pallet format remains necessary.
– PallRun®
Paper-based pallet runners used in suitable pallet and transport-packaging configurations.
– EdgeRunner®
A paper-based pallet solution combining Edgeboard and PallRun® components.
The appropriate alternative depends on load, handling, storage and transport conditions.
8. Review Protective Packaging
Product protection should be targeted according to actual risk.
Instead of adding material around the entire product, identify vulnerable areas such as:
– Corners
– Edges
– Surfaces
– Gaps
– Load-contact points
Solutions such as Edgeboard, Honeycomb Board and protective profiles can provide targeted protection in appropriate applications.
Eltete Honeycomb Board, for example, can be shaped into cushioning, dividers, void fillers, edge protectors and weight spreaders.
9. Avoid Reducing Packaging Too Far
PPWR preparation is not about using the least packaging possible regardless of performance.
Product damage creates its own environmental and commercial cost.
A packaging system still needs to:
– Protect products
– Support handling
– Maintain load stability
– Withstand transport conditions
Therefore, optimisation should focus on eliminating unnecessary packaging rather than necessary protection.
10. Ask Whether the Packaging Could Be Simplified
A packaging system involving many different materials can create more complicated end-of-life handling.
Review whether certain functions can be combined.
For example:
Before
Wooden pallet + separate corner structures + multiple internal materials
Potential alternative
Engineered fibre-based load carrier + Edgeboard + customised Honeycomb components
This does not mean the second option is automatically appropriate for every shipment.
It illustrates why the entire packaging system should be evaluated together.
11. Check Your Packaging Documentation
PPWR places increasing emphasis on conformity, information and supply-chain responsibilities.
Businesses exporting to Europe should therefore keep accurate information about the packaging they use.
Consider documenting:
– Packaging description
– Material
– Weight
– Dimensions
– Supplier
– Product specification
– Recyclability information
– Relevant certifications or declarations
Specific documentation obligations should be confirmed according to the company’s role in the supply chain and the applicable PPWR provisions.
12. Speak With Your European Customer or Importer
Do not assume that every European customer will implement PPWR requirements in exactly the same operational way.
Speak with customers and importers.
Ask whether they have:
– Supplier packaging specifications
– Restricted-material requirements
– Documentation requirements
– Recyclability criteria
– Packaging-weight targets
– Packaging-minimisation programmes
Eltete TPM notes that importers and other businesses placing packaged goods on the EU market have responsibilities under the new regulatory framework.
13. Review Packaging Before Changing Materials
Do not change a pallet, box or protective component based only on sustainability claims.
Before implementation, evaluate:
– Static loads
– Dynamic loads
– Racking
– Forklift handling
– Humidity
– Transport mode
– Load distribution
– Product sensitivity
The new packaging still needs to perform its primary job.
14. Look for Reduce Opportunities
Ask:
Q – Can we reduce material?
Q – Can we reduce weight?
Q – Can we reduce packaging dimensions?
Q – Can we reduce empty space?
Q – Can we reduce unnecessary components?
These questions directly support packaging-waste prevention.
15. Look for Replace Opportunities
Then ask:
Could suitable conventional materials be replaced with paper-based alternatives?
Potential Eltete options may include:
– Slip Sheets
– Paper Pallets
– PallRun®
– EdgeRunner®
– Honeycomb Board
– Edgeboard
– Protective profiles
Replacement should always be application-specific.
16. Plan for Recycling
Finally:
What happens when the European customer opens the shipment?
Consider:
– How materials are separated
– Whether recycling instructions are clear
– Whether mixed materials can be reduced
– Whether the packaging is compatible with the destination’s recycling system
Packaging design should consider the end of the journey as well as the beginning.
The Eltete 3R Approach
Eltete’s environmental philosophy can provide a simple framework for a packaging review:
– Reduce
Use only the packaging required for adequate protection and logistics performance.
– Replace
Where appropriate, replace heavier or less suitable components with fibre-based alternatives.
– Recycle
Design packaging with end-of-life recycling in mind.
Eltete has used the Reduce, Replace, Recycle principle as a core part of its environmental approach, and Eltete TPM connects this philosophy with the direction of PPWR.
Frequently Asked Questions
Q – Should Malaysian companies start reviewing their packaging now?
A – Yes. PPWR applies generally from 12 August 2026, making it appropriate for exporters supplying Europe to understand how their packaging is affected.
Q – Is replacing wooden pallets with paper pallets required by PPWR?
A – No. PPWR does not simply require every wooden pallet to be replaced by a paper pallet. Packaging decisions depend on applicable requirements and the specific supply chain.
Q – Does lighter packaging automatically comply?
A – No. Reduced weight can support material efficiency, but compliance depends on the complete packaging and applicable PPWR requirements.
Q – Should we ask European customers about PPWR?
A – Yes. Customers and importers may have their own implementation, supplier-documentation and packaging requirements.
Start With Your Current Packaging
PPWR preparation does not need to begin with assumptions.
Begin with data.
– What do you use?
– How much do you use?
– What is it made from?
– Is it necessary?
– Can it be recycled?
– Could it be lighter or simpler?
Eltete Malaysia can help manufacturers and exporters evaluate recyclable paper-based transport packaging according to actual product, load and logistics requirements.
Contact Eltete Malaysia to discuss a transport-packaging review for products exported to the European market.
