Regulation · Regulation (EU) 2025/40 and UK rules

PPWR and plastic cores: what changes, article by article

ROLL Lab · updated 24 October 2026 · sources at the bottom of the page

Is the core packaging?

Yes, normally. Annex I of Regulation (EU) 2025/40 lists among the examples of packaging rolls, tubes and cylinders around which flexible material is wound (for example plastic film, aluminium, paper), except those intended to be part of production machinery and not used to present a product as a sales unit. It is the same rule that existed in the previous directive.

The two conditions for not being packaging must apply together: the core must be part of the machinery and must not present the product. A core bought empty and used only on your own machines, which never leaves the plant, may not be packaging. A core that leaves with the roll for a customer almost always is.

United Kingdom: Plastic Packaging Tax and EPR

The PPWR does not apply in Great Britain, but plastic cores do not escape regulation there. Three points for UK manufacturers, importers and buyers:

• Plastic Packaging Tax (PPT), in force since 1 April 2022. It is charged on each finished plastic packaging component made in or imported into the UK that contains less than 30% recycled plastic: £228.82 per tonne from 1 April 2026. A component counts as packaging if it is designed to contain, protect, handle, present or deliver goods in the supply chain, which is what a core does for a roll. Businesses that make or import less than 10 tonnes in 12 months do not pay, but those over the threshold must register.
• Which recycled plastic counts. Both post-consumer and reprocessed pre-consumer plastic count today, but from 1 April 2027 pre-consumer waste will no longer be accepted as a source of recycled plastic for PPT. Regrind returned straight to the same process never counts. From then on, PPT will be close to the PPWR rule: only post-consumer recyclate helps.
• Packaging EPR (pEPR). Under the UK extended producer responsibility scheme, larger producers report the packaging they place on the market by material and packaging type; disposal fees are charged mainly on household packaging.

Reusable cores pay PPT once, when they are made or imported, not on every trip. Exemptions exist (for example for some packaging used to import goods, or for medicines packaging): check them on GOV.UK. Rates and thresholds change every year, so verify current values before quoting them. Northern Ireland also follows some EU product rules under the Windsor Framework: businesses there should check which PPWR provisions apply.

National practice: how Italy classifies tubes and rolls

EU countries apply the packaging definition through their EPR schemes. Italy offers a detailed example: the CONAI circular of 27 June 2013, in force from 1 January 2014, applies the rule to cores with three cases:

The fee, when due, is paid by the last tube producer on sale to the first user. Under the PPWR, the European framework for extended producer responsibility (Art. 45) extends to all packaging, including industrial and commercial packaging.

The articles that matter for a plastic core

Minimum recycled content (Art. 7)

From 1 January 2030, or three years after the implementing act on the calculation method enters into force if later, every plastic part of packaging placed on the market must contain a minimum share of recycled plastic recovered from post-consumer waste, calculated as an average per manufacturing plant and per year.

Source: Art. 7(1) and (2) of Regulation (EU) 2025/40 (EUR-Lex text). For a PVC, PP or HDPE core for industrial rolls, the most likely category is d). Three critical points:

1. Post-consumer only. Reground production scrap and much post-industrial material do not count. Many “recycled” materials on the market are of this kind.
2. Origin and traceability. The recyclate must come from waste collected under EU rules or equivalent, and by 31 December 2026 the Commission must adopt the calculation and verification method, possibly with third-party audits. Meanwhile, recyclate is documented with EN 15343 (traceability and recycled content) and third-party certification: RecyClass for recycled content and EuCertPlast for recyclers are common in Europe, and national schemes exist (such as Plastica Seconda Vita in Italy). Mass balance schemes such as ISCC PLUS were designed mainly for chemical recycling: whether and how they will count for Art. 7 will be set by the implementing act.
3. Who proves it. The average is calculated per manufacturing plant and year, and compliance must be shown in the technical documentation of Annex VII. In practice, the first to document it is whoever makes the core; whoever buys it asks for it in the supply documents.

Use the calculator below, or open the PPWR 2030 and 2040 recycled content check full page, with method and sources.

Exemptions and grey areas

• Contact-sensitive packaging. A core for food or pharmaceutical film could fall into category b), with lower percentages (10% and 25%). The definition of contact-sensitive packaging is in Art. 3: read it case by case, because the core usually does not touch the product.
• Food contact and health. Art. 7(5) exempts plastic packaging in contact with food when the recycled share would make the product non-compliant with Regulation (EC) 1935/2004.
• Less than 5% by weight. The same paragraph exempts any plastic part weighing less than 5% of the whole packaging unit. For a roll, the wound material is the product, not the packaging: the core is almost always the main part of the packaging, and the exemption rarely applies. It may cover small plastic accessories on packaging made of other materials.
• Dangerous goods, medicines, medical devices. Excluded by paragraph 4 in specific cases.
• Possible future derogations. By 1 January 2028 the Commission will assess derogations from categories b) and d) for specific packaging; it can also adjust the percentages if recyclate is scarce or too expensive (paragraphs 12 and 13).

Recyclability (Art. 6)

All packaging will have to be recyclable. From 1 January 2030, or 24 months after the delegated acts on design criteria if later, packaging may be placed on the market only if it falls into grade A, B or C (Annex II: at least 95%, 80% and 70% recyclability by weight). From 1 January 2038 at least grade B will be required. From 2035 packaging must also be recycled at scale.

For plastic cores this means: mono-material, no fillers or additives that hinder sorting, compatible and separable components (plugs, end walls). Criteria per category will come with delegated acts by 1 January 2028. PP and HDPE have broader recycling chains; PVC is recyclable in dedicated chains and should be followed closely in the delegated acts. Heavily mineral-filled PP changes density and sorting behaviour.

Reuse: Arts. 11, 12 and 29

Packaging is reusable if it meets all the requirements of Art. 11: designed and placed on the market to be reused many times, to complete as many rotations as possible, emptied without damage, reconditionable under Annex VI and recyclable at end of life. By 12 February 2027 the Commission must set, by delegated act, a minimum number of rotations for the formats most used in reuse.

Art. 29 sets reuse targets (40% from 2030, with an indicative 70% target from 2040) for transport packaging in the form of pallets, foldable crates, boxes, trays, crates, IBCs, pails, drums and canisters, including pallet wrapping and straps. Cores are not on the list. So reusing them is voluntary today: useful for cutting costs, waste and fees, but not required. Reuse and return loops.

Labelling (Art. 12)

• Harmonised label on material composition: from 12 August 2028, or 24 months after the implementing acts if later. The obligation does not apply to transport packaging, except for e-commerce. If the core is transport packaging for a semi-finished product, the harmonised label is not required; if it is part of a sales unit, it is. Assess the classification case by case.
• Reusables: from 12 February 2029, or 30 months after the implementing act, a “reusable” label and a QR code or other digital data carrier that makes tracking and the calculation of trips and rotations easier. It does not apply to open systems without an operator.
• National labelling: some countries already require material codes under Decision 97/129/EC on packaging for businesses (Italy, for example: PVC 3, PP 5, HDPE 2).

Substances (Art. 5)

The sum of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg. For cores in PVC recycled from old products, which may contain lead stabilisers, you need a supplier declaration. REACH restrictions on lead in PVC also apply.

EU declaration of conformity and technical documentation

From 12 August 2026 the manufacturer of packaging must, before placing it on the market, carry out the conformity assessment (Art. 38), draw up the technical documentation of Annex VII and sign an EU declaration of conformity (Art. 39). This is required by Art. 15. The documentation is kept for 5 years for single-use packaging and 10 years for reusable packaging.

The manufacturer is whoever makes packaging or packaged products, or has them designed or made under its own name or trademark. In the roll supply chain there are therefore two levels: whoever makes the core, and whoever uses it to pack and sell the roll. Suppliers must give the manufacturer the information and documents needed to demonstrate conformity (Art. 16). In practice, buyers of cores ask the core maker for data on substances (Art. 5), recyclability and recycled content in a form they can use in their own technical documentation.

Minimisation (Art. 10). From 2030, packaging weight and volume must be reduced to the minimum needed for its function, under the criteria of Annex IV. For a core this means a wall justified by the load, not “extra for safety” without a calculation. A documented sizing (roll pressure, temperature, creep) also becomes evidence of conformity.

Key dates

What to do now

1. Classify your cores: which ones leave with the roll (packaging) and which stay in-house.
2. Ask your supplier for the post-consumer recycled share and how it will be proven with the EU method (and, in the UK, the evidence for the 30% PPT threshold).
3. Prefer mono-material: core and accessories in the same polymer, or separable.
4. Consider reuse where returns are possible: it reduces the number of cores placed on the market, even though it does not exempt you from Art. 7.
5. Follow the Commission’s acts of 2026–2028: the details will change.

Information summary based on the text of Regulation (EU) 2025/40 published on EUR-Lex and on HMRC guidance on GOV.UK; it is not legal advice. Delegated acts, implementing acts and guidance may change how the rules apply to specific cases.

Frequently asked questions

Further reading

Sources

1. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), text on EUR-Lex: Arts. 3, 5, 6, 7, 11, 12, 29, 45 and Annexes I, II, VI, VII
2. HM Revenue & Customs, Check which packaging is subject to Plastic Packaging Tax (updated 28 August 2026), GOV.UK
3. HM Revenue & Customs, Plastic Packaging Tax rates and registration threshold, GOV.UK
4. CONAI circular of 27/06/2013 on tubes and rolls (Italy), Comieco
5. Decision 97/129/EC, identification system for packaging materials
6. Regulation (EU) 2023/923 (REACH, lead in PVC)
7. Regulation (EC) 1935/2004 on food contact materials
8. ROLL Lab analysis
9. Regulation (EU) 2025/40, Arts. 10, 15, 16, 38, 39 and Annexes IV and VII (minimisation, manufacturer obligations, EU declaration of conformity)
10. EN 15343:2007, Plastics — Recycled plastics — Plastics recycling traceability and assessment of conformity and recycled content