EU packaging regulation PPWR: what changes for corporate gift boxes

With a corporate gift, the gift box, tissue paper, cushioning and courier carton are as visible as the product itself. Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (EU) 2025/40, known as the PPWR, has applied across the European Union, and it will gradually change what that packaging may look like. This guide explains, date by date, what already applies, what arrives in 2028 and 2030, and what it means for your next gift box.

If you order corporate gifts with logo for Christmas or a client event, the PPWR affects you in two ways: whether the gift packaging complies, and who is responsible for it. The good news is that most of the stricter requirements only take effect in 2030 – but a packaging design you approve today may still be in use by then.

In short

• Regulation (EU) 2025/40 entered into force on 11 February 2025 and has generally applied since 12 August 2026; it replaces the former Packaging Directive 94/62/EC.
• Already now, the packaging manufacturer must prepare technical documentation and an EU declaration of conformity; limits on heavy metals and on PFAS in food-contact packaging apply.
• From 1 January 2030, double walls, false bottoms and other features that only increase the perceived volume of the product are banned; e-commerce, grouped and transport packaging may contain no more than 50% empty space.
• A harmonised sorting label is required from 12 August 2028, or 24 months after the implementing acts if that is later.
• If packaging is made under your name or trademark, you may yourself be the manufacturer of that packaging under the Regulation – clarify roles with your supplier before ordering.

What is the PPWR and why does it matter for corporate gifts with logo?

The PPWR is a regulation, not a directive: it applies directly and uniformly in all Member States without each country having to transpose it into national law. According to the European Commission's packaging waste page, the aim is for all packaging on the EU market to be recyclable in an economically viable way by 2030. The Commission's press release states that each European generated an average of 178 kg of packaging waste in 2023.

A corporate gift is a typical case where packaging does more than protect: it creates the first impression, carries the brand and often a greeting too. Exactly these kinds of packaging – deep gift boxes, multi-layer boxes with inserts, a large carton around a small product – are the ones the Regulation will affect most. At the same time, the Regulation explicitly takes gift-giving into account, as you will see below.

Timeline: the dates that matter

The biggest source of confusion with the PPWR is that different requirements have different dates. The table below is based on the Commission's PPWR guidance document published on 30 March 2026.

* Dates marked with an asterisk may move later if the Commission's implementing or delegated acts enter into force later: for the label it is 24 months after the implementing act, for the empty space rule 3 years, and for design for recycling 24 months after the relevant acts – whichever date is later applies.

What already applies (since 12 August 2026)

The manufacturer responsible for the packaging

According to the Commission's guidance, the packaging manufacturer is whoever designs or manufactures packaging, or has it manufactured, under its own name or trademark. The guidance stresses that there is only one manufacturer of a given packaging throughout the EU and that the trademark owner holds the decisive power in its relationship with suppliers. Exception: if the brand owner is a micro-enterprise and the supplier is in the same Member State, the supplier is the manufacturer.

In practice, if you order custom gift boxes with your logo, agree in writing with your supplier who is the manufacturer under the Regulation and who prepares and keeps the documentation. This is not legal advice – in more complex cases (for example, if you import packaging yourself from outside the EU), consult a lawyer.

Documentation and substances

Since 12 August 2026, the manufacturer must carry out a conformity assessment before placing packaging on the market and prepare technical documentation and an EU declaration of conformity. According to Fieldfisher's overview, documents must be kept for 5 years for single-use packaging and 10 years for reusable packaging. Lead, cadmium, mercury and hexavalent chromium combined may not exceed 100 mg/kg in packaging. If the gift box contains packaging in direct contact with food (for example, the inner wrapping of chocolate or biscuits), the PFAS limits apply to it as well.

An important nuance: the requirements concern packaging placed on the EU market for the first time from 12 August 2026. Packaging already placed on the market earlier may remain on the market.

What comes in 2030: empty space, double walls and false bottoms

Packaging minimisation (Article 10)

From 1 January 2030, the weight and volume of packaging must be reduced to the minimum necessary for its function. According to the guidance, packaging with characteristics that aim only to increase the perceived volume of the product, including double walls and false bottoms, may not be placed on the market. The Regulation's recitals state that marketing and consumer acceptance should not on their own justify additional packaging weight and volume.

For gift packaging it matters that the functionality criterion in Annex IV explicitly mentions sales for gift purposes and seasonal events. A gift box therefore does not have to become a plain brown carton – packaging can be presentable as long as every layer serves a function (protection, presentation, use) rather than merely creating an illusion of size.

Exemptions apply to packaging whose design rights or trademark were protected before 11 February 2025, where the requirement would affect the novelty or individual character of the design, and to products with a geographical indication. A newly designed custom gift box is unlikely to rely on this exemption.

Empty space ratio of no more than 50% (Article 24)

Economic operators filling grouped, transport or e-commerce packaging must ensure that the empty space ratio is no more than 50%. Empty space is the difference between the total volume of the packaging and the volume of the product, and according to Fieldfisher's overview filling material – paper shreds, air cushions and bubble wrap – also counts as empty space. The Commission will set the calculation method in an implementing act. If you ship gifts to home offices by courier, this mainly concerns the outer shipping carton.

Labels and environmental claims on gift boxes

From 12 August 2028 (or 24 months after the implementing act), packaging must carry a harmonised label on material composition and sorting, which may be supplemented by a QR code. If you are designing a gift box today that you plan to reorder in 2028 or later, leave space for the label in the print file.

The other side is marketing claims. According to PPWR Connect's analysis, Article 14 of the PPWR allows a claim about a regulated packaging property only if the property exceeds the minimum requirement, and the claim must state which part it concerns. In addition, Directive (EU) 2024/825 has applied since 27 September 2026, banning unsubstantiated generic claims such as "eco-friendly packaging" and presenting legal requirements as a distinctive advantage. So "PPWR-compliant box" is not a marketing message but an obligation.

If you want to make a claim about packaging, use verifiable information, such as FSC-certified board with its licence code. See also our FSC-certified promotional gifts and sustainable promotional products.

Checklist: a gift box that is ready for 2030

1. Measure the product before the box. Give the supplier the exact product dimensions and have the box made to fit the product, not the other way round.
2. Drop layers with no function. A false bottom, thick filler board or an inner box that merely "fills space" will not be allowed from 2030.
3. Prefer a single material. A box made only of board and paper is easier to recycle than one with a plastic window, magnet or lamination.
4. Ask your supplier to confirm roles in writing. Who is the manufacturer, and who prepares the technical documentation and declaration of conformity?
5. For food, ask for food-contact documents. If the box contains sweets or coffee, the inner packaging must be suitable for food contact.
6. Plan the courier carton separately. When shipping to home offices, choose a carton size with less than half empty space.
7. Leave room for the label in the design. The 2028 harmonised label and QR code need space.
8. Check your claims. Every environmental claim must be specific and substantiated.

Example: a client gift box, redesigned

Example (fictional scenario, not Logotrade data): An IT company is sending 150 clients an engraved thermal mug and a pack of coffee for Christmas. The original concept was a large box with a magnetic closure, a thick foam insert and a false bottom to make the box look more "premium".

1. Mapping functions. The team asked of every layer: does it protect, present or get used? The false bottom did none of these.
2. New dimensions. The box was redesigned around the mug and the coffee pack; the foam insert was replaced with a folded paper die-cut that holds the products in place.
3. Material. The magnet was replaced with a tuck flap and the plastic window was dropped – the box is now a single material.
4. Shipping. For home-office deliveries, a courier carton only slightly larger than the gift box was chosen, without large amounts of filler.
5. Result. The box stayed presentable (debossed logo, coloured inside print) but is simpler, lighter and already in line with the 2030 direction.

On tax: in Estonia, according to the Estonian Tax and Customs Board, the logo, transport and packaging are business expenses and are not added to the value of the gift; for a set of several items, however, the threshold applies to the set as a whole.

Common mistakes

• "It only applies from 2030." Some requirements – manufacturer obligations, documentation, substance restrictions – have applied since 12 August 2026.
• A grand box for a small product. A large box around a small item, a false bottom or thick filler is exactly what Article 10 restricts.
• A courier carton full of bubble wrap. Filling material counts as empty space.
• Mixed materials for no reason. A plastic window, metal clip and lamination in one box make recycling difficult.
• Green slogans on the box. "Eco", "green" or "PPWR-friendly" without specific evidence is misleading.
• Roles not agreed. If it is unclear who the manufacturer is, nobody prepares the documentation.

We cover the practical side of ordering branded packaging, gift sets and gift bags in more detail on the Logotrade blog.

How to choose a gift with simple packaging

The easiest way to cope with packaging requirements is to choose products that do not need much packaging. Textiles, mugs, notebooks and tools can often be packed in one slim box or bag. Ready-made gift sets are usually already matched to the box size, and for Christmas gifts it is worth asking whether the packaging itself can be printed with your logo instead of adding a separate outer wrap. With a high-end corporate gift, let the quality of materials and print carry the prestige, not the size of the box.

If you need a gift box design or want to rework an existing box, our advertising design team can help; browse the product catalogue, see logo application options under services and earlier projects in our portfolio.

Frequently asked questions

Does the PPWR apply directly in every EU country?

Yes. Regulation (EU) 2025/40 has applied directly in all Member States since 12 August 2026. National laws mainly regulate extended producer responsibility and waste management.

Do we have to throw away our current Christmas boxes?

No. The requirements concern packaging placed on the market for the first time from the date of application. The minimisation and empty space requirements apply from 1 January 2030.

Can a gift box still be beautiful and presentable?

Yes. The Regulation takes gift-giving and seasonal events into account. What is banned are elements that only increase perceived volume, such as double walls and false bottoms.

Who is the manufacturer if our logo is printed on the box?

According to the Commission's guidance, the manufacturer is the party under whose name or trademark the packaging is designed or manufactured; for a micro-enterprise in the same country, the supplier may be the manufacturer. Agree roles with your supplier in writing.

When does the new sorting label have to appear on gift boxes?

From 12 August 2028, or 24 months after the Commission's implementing act enters into force – whichever is later.

Does the 50% empty space limit apply to the gift box itself?

Article 24 concerns grouped, transport and e-commerce packaging, such as a courier carton. The size of the gift box itself is limited by the general minimisation requirement in Article 10.

Logotrade's experience

Logotrade OÜ has operated in Tallinn since 2004, helping companies across Estonia choose and brand gifts and their packaging. We are a member of the international promotional products networks PSI and ASI and of the Estonian Chamber of Commerce and Industry, which helps us follow how ready suppliers are for new EU requirements.

Send us details of the product, quantity, recipients and deadline at logo@logo.ee or via our contact page. In the quote we will specify the packaging material, production time, minimum quantity and price.

Sources

• Regulation (EU) 2025/40 on packaging and packaging waste (EUR-Lex)
• European Commission: PPWR guidance document (30.03.2026)
• European Commission: packaging waste
• European Commission press release IP/26/664
• Fieldfisher: 10 key things about the new EU packaging rules
• PPWR Connect: environmental claims on packaging