PPWR sets requirements for packaging and recycling of construction products 

The new EU Packaging and Packaging Waste Regulation (PPWR) and the amendment to the Waste Act, which came into effect in August, oblige manufacturers and importers of construction products to ensure, among other things, the minimization and recyclability of packaging materials. New requirements also apply to transport packaging used in the construction industry, such as pallets and pallet strapping.

The regulation applies to all packaging, regardless of material and intended use – including packaging for concrete elements, steel beams, pipes, insulation, aggregate products and infrastructure construction materials (Articles 1–2). 

The company must identify its role in the packaging supply chain. The manufacturer of a construction product is generally responsible for the packaging in which it places the packaged product on the market. The importer is responsible for the packaging of packaged products imported from outside the EU. (Articles 3 and 15). 

Packaging design and documents 

In the future, the manufacturer must be able to demonstrate that the packaging used meets the requirements of the PPWR. This means packaging minimization, recyclability, management of restricted substances and, where necessary, reusability.  

The weight and volume of the packaging must be kept as small as possible to protect the product, ensure safe transport and handling. The empty space of the sales packaging must be as small as possible and the empty space of transport and online shopping packaging must not exceed 50% from 2030 (Articles 10 and 24). 

The manufacturer must draw up a technical documentation and an EU declaration of conformity for the packaging. The documentation describes, for example, the intended use of the packaging, the materials, the standards applied, the test reports and an assessment of how the requirements are met. The EU declaration of conformity is kept for five years for single-use packaging and for ten years for reusable packaging. The CE marking is not used to demonstrate the PPWR requirements (Articles 15, 38 and 39; Annexes VII-VIII). 

Producer responsibility and reporting 

The producer responsibility for packaging is maintained and clarified. The producer must join a producer organisation or fulfil the obligations themselves, register in the producer register, report the quantities of packaging placed on the market and pay the related fees. If the company is not itself under producer responsibility, it should ensure from the supplier that the responsibility has been fulfilled (Articles 44–47). 

Transport packaging in infrastructure and industry 

An important practical issue for the construction industry concerns transport packaging. From 2030, certain transport packaging, such as pallets, plastic boxes, IBCs, drums, canisters, pallet hoods and pallet straps, will have reuse targets: the general rule is at least 40% reusable in 2030 and the target level is 70% in 2040.  

For deliveries between the same company's premises and within the same Member State, certain transport packaging must be made 100% reusable from 2030. However, Commission Delegated Decision (EU) 2026/429 exempts certain operators using pallet hoods and pallet straps from the 100% reusable requirement for these forms of packaging.  

Cardboard boxes, transport packaging for hazardous materials and customer-specific packaging for large machines or equipment are, in some respects, outside the obligations (Article 29). 

What needs to be done? 

1. Assemble a packing list: sales and transport packaging, such as pallets, big bags, stretch films, tie-down straps, boxes, barrels and canisters. 
2. Identify the role of the company: manufacturer, marketer of the packaged product, importer, distributor, or just a user of the packaging on the construction site. 
3. Prepare an EU declaration of conformity. Ask packaging suppliers for written information on materials, composition, harmful substances, recyclability, recycled material and traceability. 
4. Ensure labeling so that packages placed on the market can be identified by type, batch or other identifier and linked to documents. 
5. Check producer responsibility. Find out if your company needs to register, join a producer organization, report packaging volumes, or pay producer responsibility fees in Finland or other countries. 
6. Map plastic packaging. Find out the types of plastic used and whether they will be subject to minimum recycled content requirements from 2030. 
7. Assess transport packaging. Identify which packaging can be included in the 2030 reuse targets and which transports require a reuse system. 
8. Clarify big bag practices. Reusing big bags on the construction site is not a goal in principle if the product is not brought to market at the same time. 
9. Update internal instructions. Add a requirement to procurement and logistics to provide packaging information and pre-check new packaging. 
10. Assign responsibility for the work. Designate a person or team for the packing list, supplier information, documentation, and monitoring of the 2028–2030 requirements. 

The Packaging and Packaging Waste Regulation PPWR entered into force on 11 February 2025 and was applied from 12 August 2026. The amendment to the Waste Act (648/2026) also entered into force on 12 August 2026. PPWR The aim is to reduce unnecessary packaging and packaging waste and increase the recyclability, reuse and circular economy of packaging in the EU internal market.  

See also

• European Union Packaging and Packaging Waste Regulation (PPWR)
• Act on Amendments to the Waste Act (648/2026)
• Frequently Asked Questions (FAQ) regarding the PPWR Regulation

More information

Kirsi Martinkauppi

Sustainability Director

kirsi.martinkauppi@rt.fi +358 50 582 2464

Rakennustuoteollisuus RTT ry