A technical guide from NBLITE, Ningbo — for buyers sourcing LED lighting products for the EU and UK markets.
1. Why PPWR Applies to Us Now
PPWR — Regulation (EU) 2025/40 on packaging and packaging waste — entered into force on 11 February 2025 and becomes fully applicable across the EU on 12 August 2026. It replaces the old Packaging and Packaging Waste Directive (94/62/EC). The shift from a Directive to a Regulation matters: a Regulation applies directly in every member state, the same way, without each country writing its own national version first (Article 1, Article 2). NBLITE ships to the EU and UK, so packaging design now sits inside the same compliance conversation as the product itself.
2. The Requirements That Actually Touch Our Packaging
PPWR runs to 71 articles. Most of it is outside our scope — this is the part that isn’t.
| Requirement | What It Means | Applies From |
| Recyclability (Art. 6) | All packaging must be recyclable; graded A/B/C, tightening to A/B only. | A/B/C from 2030; A/B from 2038 |
| Composite material threshold (Art. 3(1)(24)) | A second material only counts as “composite” above 5% of total mass. | In force |
| Packaging minimisation (Art. 10) | Weight and volume cut to the minimum needed to function; no false bottoms or double walls. | From 1 Jan 2030 |
| Reuse targets — transport packaging (Art. 29; Delegated Decision (EU) 2026/429) | 40% reuse target generally; 100% between own/linked sites, but pallet wrap and straps are exempted from the 100% figure. Cardboard boxes are exempted outright (Art. 29(4)(d)). | From 2030 |
| Environmental claims (Art. 14) | Claims only for properties beyond the legal minimum, and must state what they cover. | In force |
3. What We’ve Changed On Our Own Lines
Not all of this is a PPWR requirement — some goes beyond what the law asks for. We’d rather be specific about which is which:
| Change | Relates To | Note |
| FSC-certified paper sourcing | Sits alongside Art. 6 | Not a PPWR mandate; our own sourcing standard |
| Laser marking instead of printed labels | Art. 10 (spirit) | Fewer adhesive labels, fewer components to separate |
| Digital user manuals via QR code | Art. 12(1) | Art. 12(1) covers component-sorting QR use; our manual QR sits alongside it |
| No inner box on select ranges | Art. 10, Art. 24 | Direct weight/volume and empty-space reduction |
| No plastic bag for product protection | Supports Art. 6 | Reduces mixed-material content in the box |
| Glassine paper cushioning on select lines | Supports Art. 6 | Paper-based protection stays within one recyclable stream |
| Recycled fibre content in packaging paper | Beyond Art. 7 | Art. 7’s mandatory recycled-content target applies to plastic, not paper |
4. What This Means If You’re Sourcing From NBLITE
If your compliance team is reviewing suppliers ahead of the August 2026 deadline: our packaging already tracks the recyclability, minimisation and reuse requirements above, and we can provide the underlying technical documentation on request — Articles 15 and 39 put that burden on the manufacturer placing packaging on the EU market. Most of our transport packaging is cardboard, which Article 29(4)(d) exempts from the reuse targets entirely.
NBLITE designs packaging for its LED battens, Weatherproof Batten, Bulkheads, Ceiling Lights,Panels,Linear and Downlight ranges around the same paper-first, minimal-layer approach described above. If you’re evaluating our packaging against PPWR for an OEM project or supplier review, our technical team can walk through the documentation directly: sales@nblite.com.
References
- Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (OJ L, 2025/40, 22.1.2025).
- Commission Delegated Decision (EU) 2026/429 of 25 February 2026 (OJ L, 2026/429, 6.5.2026).
