Premier Paper Group is aware of and actively monitoring the requirements of Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR).

Premier Paper supplies paper and board materials intended for subsequent conversion into packaging and other products. We do not design, manufacture or place finished packaging on the EU market.

Compliance of the finished packaging within the requirements of the PPWR will depend upon factors including the packaging design, dimensions, minimisation measures, conversion processes, coatings, laminations, inks, adhesives, labels, closures and the intended end use. Accordingly, responsibility for demonstrating compliance of the finished packaging, including primary, secondary and tertiary packaging components, rests with the packaging manufacturer and/or the entity placing the packaged goods on the EU market (importer or distributor).

Many of the detailed requirements of Regulation (EU) 2025/40, including those relating to packaging minimisation, recyclability performance grades, recycled content targets and harmonised labelling and sorting requirements, are subject to phased implementation across 2026 to 2040, and supporting secondary legislation.

We confirm that:

  • We maintain processes intended to ensure that the paper and board materials we supply comply with all currently applicable legal requirements relating to composition, material restrictions and substances of concern.
  • We work with our manufacturing suppliers to monitor developments in PPWR legislation and to support compliance with applicable requirements as they become effective.
  • Where relevant information is available from our suppliers, we can provide information relating to material composition, recycled fibre content, fibre certification and other technical characteristics of the materials supplied.
  • Information concerning the recyclability and regulatory compliance of the finished packaging can only be assessed once the packaging design and conversion process have been defined.
  • We will continue to support our customers in their obligation to create EU Declarations of Conformity by providing relevant technical and regulatory information available to us.

We note that paper and board manufacturers and raw material suppliers do not routinely issue comprehensive PPWR Declarations of Conformity covering packaging design, recyclability classification, labelling requirements and all packaging components, since these matters are dependent upon the characteristics and intended use of the finished packaging and are the responsibility of the entity placing that packaging on the market.

This statement reflects our current understanding of Regulation (EU) 2025/40 and will be reviewed and updated as further implementing acts and guidance are published.