A clear window lets someone inspect a toy. An insert keeps its accessories together. A rigid gift box creates an opening experience and protects the objects inside. Each feature has a purpose, but each also adds material, affects recycling and needs to be included in the packaging specification.

The EU’s Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, generally applies from 12 August 2026. For toy and gift brands approving packaging in September 2026, the task is to meet the requirements applicable today while considering later rules before committing a design to repeated production. Start with the complete packaging the customer receives, including anything added during fulfilment.

The dates that affect an approval

Design duties also exist during the transition. The Commission’s interpretative guidance explains that the general recyclability obligation applies from August 2026, with the previous Packaging and Packaging Waste Directive requirements and related standards providing the interim basis. It also explains that existing minimisation requirements continue through the end of 2029. The later dates introduce specific assessment frameworks and limits; they do not make unnecessary packaging a sensible purchase today.

1. Identify every packaging part—and the function of any retained case

Lay out one complete packed product. Include the carton, window, tray, ties, sleeve, tissue, seals and other packaging components. Then add the delivery carton, cushioning, tape and labels used for an online order. A gift set sold as one unit can have sales packaging around the whole set; its classification follows its actual function, rather than the number of products inside.

• An ordinary toy carton and securing insert: their containment, protection and presentation functions bring them within the packaging review, even if a customer occasionally keeps them.
• A case integral to a play set: examine whether it forms part of the product itself, is necessary to contain, support or preserve it throughout its lifetime, and is intended to be used or disposed of together with it. A case whose structure is essential to play may warrant a different analysis from a box illustrated with a play scene. Record the intended function, drawings and instructions supporting the decision.
• A keepsake gift box: a recipient’s decision to store photographs or small objects in it does not, by itself, remove its original packaging function or establish PPWR reusable-packaging status.

Formal reuse involves repeated use for the packaging purpose for which the item was conceived, supported by the relevant design requirements and a reuse system. For example, a gift subscription collecting boxes for refilling would need arrangements for return, condition checks, appropriate reconditioning and further use. A durable lid and attractive storage suggestion establish much less. Resolve this distinction before relying on a reuse exemption or printing a reusable-packaging claim.

2. Review windows, inserts and finishes as a complete construction

A description such as “paper gift box” leaves several important questions unanswered. Obtain a component schedule identifying the board, wrapping paper, plastic film or tray, coatings, adhesives, closures and decorative parts, with their material specifications and weights. Record which parts separate during normal opening and which remain bonded together. This information supports the recycling assessment, substance review and packaging-weight reporting.

For a windowed toy carton, review the film and its attachment. The film provides visibility and can protect the product from handling, while the adhesive flange joins two materials that may follow different recycling routes. Compare a smaller window, a construction allowing easier separation, or a printed closed carton where direct visibility contributes little. An open aperture needs a fresh protection review because it exposes the product. The useful choice depends on what shoppers need to see and what the toy needs during distribution.

For securing inserts, start with the points carrying the load. A folded board cradle might support a small toy vehicle beneath its body while leaving wheels and projecting parts clear. That could replace some plastic or foam, but it still needs to restrain movement, retain accessories and allow straightforward removal. Check fit with real products across the expected dimensional variation. A sample that works only with one perfectly positioned toy is a weak basis for production.

For rigid gift boxes, examine the details that hold the construction together. Surface laminations, glued fabric, foam trays, magnets and ribbons can affect material separation and recovery. Useful alternatives might include a removable fitted tray, a paper closure or a different surface finish. Their suitability depends on the product, handling and intended appearance; switching one component to paper does not establish the recyclability of the finished box.

At CMIC, we can develop a small number of structural and material alternatives around these functions, then compare physical samples for fit, appearance, opening and protection. A textured paper may provide the desired tactile character with a different finishing route, for example, while a revised tray can make a smaller box feel carefully composed. The comparison should identify what changes in the customer experience as well as what changes in the material list.

Keep any recycling conclusion tied to the actual construction and assessment used. PPWR’s later framework considers components, separation, sorting and recycling compatibility; a high percentage of paper by weight is insufficient to assign a grade. For the current transition, the Commission guidance refers to existing requirements and standards such as EN 13430:2004, and defers the PPWR conformity assessment specifically for recyclability until the relevant Article 6(4) delegated acts enter into force.

For plastic windows, trays and films, classify the intended product before setting a recycled-content target. PPWR’s “contact-sensitive packaging” category covers packaging intended for products under specified EU legislation, including toys, food and cosmetics. A window or tray for a product covered by EU toy-safety legislation therefore needs review under that category. For gift brands, the contents determine the starting point: packaging for a toy or skincare set and packaging for decorative ornaments can fall under different rules, even when the boxes share a style.

Article 7’s first minimums for contact-sensitive packaging are 30% post-consumer recycled content where PET is the major component and 10% for other plastics, with single-use plastic beverage bottles treated separately. The target for other plastic packaging is 35%, which may be relevant to a tray holding decorative ornaments. These minimums apply from 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later. They are calculated by packaging type and format as an average per manufacturing plant and year; that calculation does not guarantee the same percentage in every individual window or tray.

Check exemptions before turning those figures into a purchasing specification. Article 7 includes an exemption for a plastic part representing less than 5% of the total weight of the whole packaging unit. A small window may warrant that check; its area alone cannot establish the result. Use the component schedule and a clearly identified packaging unit to document the calculation. This exemption concerns the recycled-content minimums and leaves the relevant substance and recyclability duties in place.

Ask the supplier to identify the polymer, explain the applicable category or exemption, and show how any recycled-content statement will be supported. Then sample the proposed material for clarity, colour, fit and protection. A changed plastic formulation can affect what shoppers see through a window or how a tray holds the product. Recycled content in the paperboard is a separate specification and cannot fulfil a requirement applying to the plastic.

3. Explain the space and material needed for protection and gifting

PPWR’s Annex IV expressly recognises packaging functionality associated with gifts and seasonal events, alongside protection, logistics, information and safety. A gift pack may need to bring separate items together, keep them arranged for the recipient and support the way the gift is handed over and opened. Under the 2030 minimisation framework, the assessment is whether the design fulfils those functions with the minimum necessary weight and volume. Marketing appeal or consumer acceptance alone cannot justify extra material or space.

Consider a pendant gift with a personal message. A shallow fitted tray can hold the jewellery in the arrangement in which it is given, while a card flap presents the message before the recipient reaches the gift. These are specific presentation and opening functions to assess. Compare that arrangement with a second rigid lid or a raised platform creating the same reveal. If the simpler construction preserves the intended presentation and opening sequence, the extra bulk has a weak justification. Proportion, paper texture and printing offer further ways to express the occasion within the necessary structure.

Consider two ceramic ornaments presented together. A divider can keep them from striking each other, while clearance around fragile projections and finger access can support protection and removal. Those functions help explain the layout. A deep platform added solely to make the contents appear larger has a different purpose. Before accepting it, explore a shallower box, a changed product orientation or a tray that presents the ornaments clearly without the same bulk.

The restriction on features aimed only at increasing perceived product volume should be read with that purpose intact. A protective double wall needs assessment for the work it performs; the words “double wall” do not make every reinforced structure equivalent to a false bottom. Equally, calling a structure premium does not explain why its dimensions are necessary.

We can compare reduced dimensions, revised inserts and material thicknesses using samples with the actual products. For gift presentation, open the alternatives in the intended sequence and record what each feature does: how the set stays arranged, when the message becomes visible and how the contents are revealed. Protection needs its own assessment, which may include drop, vibration or compression testing appropriate to the product and route, alongside fit and opening checks. Retain the sample versions, conditions and results, explaining what further reduction would compromise and which simpler alternatives preserve the required functions.

4. Review the ecommerce parcel separately

There are two different spaces to examine: the space around the product inside its sales packaging, and the space around that sales packaging inside the delivery carton. Article 24 sets a future 50% maximum for grouped, transport and ecommerce packaging. Sales packaging has its own requirement to minimise empty space for functionality and protection, with no equivalent general numerical threshold currently specified.

For the outer-pack ratio, the Regulation defines empty space by reference to the outer packaging volume and the volume of the sales packaging it contains. Paper shreds, air cushions, bubble wrap and foam fillers count as empty space. They may perform a protective function, but adding them does not improve the ratio.

An early sizing illustration: if the volumes used for comparison are 10 litres for a delivery carton and 4 litres for the sales box inside, the remaining 6 litres represent 60%. Adding shredded paper leaves that relationship unchanged. Use such comparisons to identify oversized combinations; formal compliance measurement must follow the applicable Commission methodology.

Ask the fulfilment partner to show the actual carton chosen for a single item, a two-item order and common mixed orders. One standard carton may fit the largest combination well and leave substantial space around a single gift set. A better size range or a validated alternative packing arrangement can address the cause. Preserve cushioning and clearance where the product needs them, and assess the full parcel after changes—especially where a retail window or decorated gift-box surface needs protection.

Article 24(5) exempts sales packaging used directly as ecommerce packaging, and reusable packaging used within a reuse system, from the 50% obligation. The sales packaging must nevertheless meet Article 10’s minimisation requirements. Shipping directly in a product box is therefore a route to assess for protection, closure, labels and customer experience; it does not settle the wider packaging review.

5. Match substance evidence to the materials being ordered

For ordinary toy cartons and paper gift packaging, check the combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium in packaging or packaging components. This is a combined concentration limit. Include the relevant printed papers, inks, coatings, adhesives and added components in the evidence review, as well as the main board.

Read a test report through its sample identification, materials covered, test scope, results and date. A report for an unprinted white board does not automatically establish the result for a finished box with a coloured wrap and a different adhesive. Likewise, a passing substances test supports the stated chemical assessment; recyclability, minimisation and the other applicable requirements need their own basis.

We can help connect the specified components with supplier information and coordinate project-specific testing where it is needed. Agree which declarations and reports support the design, what remains unverified, and which substitutions require review. This makes a later change from one ribbon, coating or insert supplier to another visible before it enters production. Food-containing gifts also need a review of the actual food-contact packaging, including the PPWR PFAS restrictions where applicable.

6. Name the responsible entities and assemble the packaging file

A company having packaging or a packaged product designed or manufactured under its own name or trademark is generally the PPWR manufacturer. The physical factory and the legally responsible manufacturer can therefore be different entities. For a brand sourcing custom packaging from China, record the allocation for the actual arrangement. The manufacturer must arrange the applicable conformity assessment, establish the technical documentation and draw up the EU declaration of conformity.

Article 16 requires packaging and material suppliers to provide the information needed to demonstrate conformity. Our contribution can include drawings, component specifications, supporting material information, sample coordination and relevant test records. The EU importer also has duties to check conformity and the availability of the manufacturer’s documentation. Agree who supplies each document and who maintains the finished packaging file.

Identify the producer for extended producer responsibility (EPR) separately. This role concerns packaging-waste obligations, including registration, reporting and fees in the relevant Member State. It depends on the packaging type and sales route, including whether a business supplies a local distributor or sells directly to end users across borders. Record the responsible entity for each country and route, including packaging removed or added by logistics partners. Component weights then become usable reporting data.

For the approved packaging type, assemble a file that connects the physical pack with:

• Its identification, intended use, relevant products and design version.
• Drawings, dimensions, component materials and the manufacturing specification.
• The requirements applicable at the relevant date, and an assessment of possible non-conformity.
• The standards, specifications or other assessment methods used, with explanations where needed.
• Applicable supplier evidence, calculations, assessments and test reports.
• The manufacturer’s EU declaration of conformity and arrangements for keeping production consistent with the documented design.

Under Article 15 and Annex VII, the manufacturer retains the technical documentation and declaration for five years after single-use packaging is placed on the market, or ten years for reusable packaging. Connect each product SKU to the packaging type it uses so records remain retrievable. Record first EU market placement where relevant: an order date or production date in China does not by itself establish when packaging was first made available on the Union market.

7. Check artwork, identification and environmental claims

Keep the toy’s required product information clear and legible when revising the packaging. A CE mark appearing on a toy carton concerns the product’s applicable legislation; it does not establish PPWR conformity for the packaging. Packaging identification and manufacturer or importer information also need attention. Article 15 requires a type, batch, serial number or another identifying element, with an accompanying-document route where the packaging’s size or nature prevents its inclusion.

For artwork expected to remain in use through the later label deadlines, plan against the adopted specifications and applicable stock-transition rules. The harmonised material-composition label covers ecommerce packaging even though other transport packaging is excluded from that particular requirement. Formal reusable packaging has a separate label timetable: 12 February 2029 or 30 months after the relevant implementing act enters into force, whichever is later, with specified exceptions.

Review environmental claims against the exact component and evidence they describe. If a recycled-content statement concerns only the board, say so. Article 14 requires claims about packaging properties regulated by PPWR to concern performance exceeding the applicable minimum requirements, identify whether they relate to a part, a packaging unit or all the operator’s packaging, and be supported in the technical documentation. Carry that precision into ecommerce descriptions as well as printed copy.

8. Approve a defined version and control repeat orders

The sample, specification, artwork and supporting evidence should describe the same packaging version. If a handmade sample uses temporary adhesive or a substitute insert material, record that difference and establish which production materials still need assessment. An attractive sample is most useful when everyone understands what it represents.

• Scope settled: packaging layers are identified, including the basis for any integral-product or reusable-packaging classification.
• Design supported: materials, dimensions, separability and necessary protection have been reviewed together.
• Delivery arrangement agreed: the fulfilment pack and packing instructions match the intended orders and distribution route.
• Evidence connected: responsible entities, applicable assessments, declarations and supporting documents are linked to the approved version.
• Changes controlled: suppliers will flag material, adhesive, coating, component or structural substitutions for review before production.

Article 15 requires manufacturers to keep series production in conformity and reassess changes that could affect it. A repeat order therefore needs review when the construction, materials, applicable requirements or supply arrangement changes. Record what changed and whether further assessment or testing is necessary. This preserves the reasoning behind the original approval while allowing the packaging to improve.

A useful packaging approval leaves the brand with a clear account of how the pack protects and presents its product, what materials it contains, and what supports its conformity. Through our EU packaging solutions, CMIC can help develop structural alternatives, compare samples and coordinate the relevant supplier evidence and testing. To discuss a toy carton or gift set, contact us with the product, current packaging or concept, intended EU markets and delivery route.