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The EU Packaging and Packaging Waste Regulation is changing how companies design, manufacture and place packaging on the European market. For food packaging producers, the impact extends beyond material selection. Tray structure, recyclability, recycled content, labeling, packaging weight and food-contact safety must all be considered together. This guide explains what the EU PPWR means for thermoformed food packaging and how manufacturers can review their materials, product designs and thermoforming equipment before supplying the EU market.
Table of Contents
The EU PPWR regulates packaging and packaging waste rather than thermoforming machines themselves.
A thermoforming machine cannot automatically make a food tray compliant with PPWR. Compliance depends on the complete packaging system, including the tray, lid, label, ink, adhesive, additives and intended market.
Recyclability, recycled content, packaging minimization and clear material identification are becoming more important for food packaging manufacturers.
Recyclable food trays should be evaluated as complete products, not only by looking at the base plastic.
Recycled content packaging may require additional checks for material consistency, food-contact suitability, heating behavior and forming quality.
Machine buyers should discuss material compatibility, sheet thickness, forming depth, heating control, mold design, trimming, scrap handling and quality inspection with their supplier.
PPWR requirements may change according to packaging type, material, application and implementation timeline. Companies should confirm the latest legal requirements for their target EU markets.
The EU Packaging and Packaging Waste Regulation, commonly called PPWR, is the European Union’s regulatory framework for packaging and packaging waste. It is formally established under Regulation (EU) 2025/40 and is intended to reduce packaging waste, improve packaging recyclability, increase the use of recycled materials and harmonize packaging requirements across EU member states.
The regulation applies to packaging placed on the EU market and covers different packaging formats and materials. It is relevant to packaging manufacturers, food producers, importers, distributors, retailers and other economic operators involved in the packaging supply chain.
The European Commission identifies several major objectives for the regulation, including:
Reducing unnecessary packaging waste
Improving the recyclability of packaging
Increasing recycled content in plastic packaging
Supporting reuse and refill systems
Improving packaging labeling
Reducing unnecessary packaging space and material usage
Restricting certain substances in food-contact packaging
For thermoformed food packaging manufacturers, PPWR should not be understood as a requirement for one specific machine or one universal plastic material. It is better understood as a framework that encourages packaging to be designed and produced with its full life cycle in mind.
Companies should review the latest requirements through the European Commission’s Packaging and Packaging Waste Regulation overview before making compliance decisions.
Thermoforming is widely used to produce food trays, takeaway containers, lids, cups and other packaging products. The process can support lightweight packaging and efficient high-volume production, but the final packaging must still be assessed according to its material structure and intended use.
A thermoformed food tray may include more than the formed base. Its overall packaging system may also contain:
A plastic tray
A lidding film
A printed label
Adhesives
Inks and coatings
Absorbent pads
Barrier layers
Sealing materials
Additives or processing aids
These components can influence the recyclability and food-contact characteristics of the finished package.
For example, a tray made from a recyclable polymer may still require additional evaluation if it is combined with materials that interfere with sorting or recycling. A packaging structure that uses multiple layers may provide useful barrier properties, but it may also require more detailed recyclability assessment.
This means that food packaging manufacturers should not evaluate PPWR only from the perspective of forming speed or machine output. They should also consider:
Whether the chosen material is appropriate for the target application
Whether the packaging structure can be recycled through relevant systems
Whether recycled content is required or commercially desirable
Whether the material is suitable for food contact
Whether the package uses more material than necessary
Whether the tray and other packaging components can be clearly identified
Whether the selected machine can form the material consistently
The machine is one part of the production system. Packaging design, material supply, mold design, forming parameters and quality control must work together.
The specific obligations under PPWR depend on the packaging type, application and implementation requirements. However, several areas are especially relevant to thermoformed food packaging.
PPWR-related area | Potential impact on thermoformed food packaging | Questions for manufacturers |
|---|---|---|
Recyclability | Food trays should be designed with future recycling requirements in mind | Can the tray structure be collected, sorted and recycled in the target market? |
Recycled content | Certain plastic packaging may need to include recycled material according to applicable requirements and timelines | Is the recycled material suitable for the application and forming process? |
Packaging minimization | Excessive material use and unnecessary empty space may receive more attention | Can tray thickness, dimensions and cavity design be optimized? |
Labeling | Packaging information should help identify material and disposal or recycling instructions | Can the packaging material and relevant information be clearly communicated? |
Reuse and refill | Some packaging applications may face requirements or incentives related to reuse | Is single-use packaging necessary for the intended application? |
Food-contact safety | Materials and substances used in food packaging must meet applicable food-contact requirements | Has the material supplier provided appropriate documentation? |
PFAS restrictions | Certain PFAS substances in food-contact packaging are restricted under the regulation | Have materials, coatings and additives been reviewed for the target market? |
This table is a practical overview rather than a complete legal interpretation. Food packaging manufacturers should confirm the exact provisions that apply to their products.
Packaging designers may increasingly consider mono-material or simpler packaging structures when they develop recyclable food trays. A simpler structure can make it easier to identify, sort and process the package after use.
However, material simplification should not reduce the package’s required performance. Food trays may still need to provide:
Product protection
Stacking strength
Resistance to moisture or grease
Sealing performance
Temperature resistance
Appropriate rigidity
Dimensional consistency
Compatibility with filling and sealing equipment
The challenge is to balance these requirements with recyclability and material efficiency.
Packaging minimization does not simply mean making the tray as thin as possible. If the wall becomes too thin, the tray may deform during filling, transportation or retail display.
A better approach is to review the complete design:
Product dimensions
Tray depth
Corner radius
Rib or reinforcement design
Wall-thickness distribution
Stacking structure
Trim layout
Mold cavity arrangement
Sheet utilization
A stable thermoforming process can help manufacturers reduce unnecessary material variation. Uniform heating, proper pre-stretching and suitable mold design can improve material distribution across the finished tray.
A food tray is often used together with a lidding film or sealing material. The tray material, rim structure and sealing method should be considered together.
Designers should evaluate:
Rim flatness
Sealing width
Rim strength
Tray flange dimensions
Film compatibility
Seal integrity
Opening behavior
Material separation after use
Changing the tray material without checking the lid or sealing process may create production or packaging problems. PPWR preparation should therefore involve both the tray manufacturer and the food packaging system supplier.
Clear material identification can support sorting and recycling. The exact labeling requirements depend on the applicable EU rules and implementation guidance, but packaging suppliers should be prepared to provide accurate material information.
For a thermoformed food tray, the manufacturer should maintain records related to:
Polymer type
Sheet supplier
Recycled content where applicable
Additives
Coatings
Printing
Adhesives
Food-contact documentation
Production batch information
Good documentation also helps customers evaluate whether the packaging is suitable for their own compliance and procurement requirements.
Recycled content packaging is receiving more attention because the PPWR includes requirements and targets related to recycled materials in plastic packaging.
For thermoforming manufacturers, the use of recycled content may influence both material procurement and production stability. Recycled sheet materials can vary according to the source material, processing history, composition and supplier controls.
Before using recycled content packaging, manufacturers should evaluate:
The sheet should have consistent thickness, surface quality and forming behavior. Variations can affect heating, stretching and wall-thickness distribution.
Not all recycled plastic is automatically suitable for food-contact applications. The material supplier should provide the relevant documentation for the intended use and target market.
Recycled material may respond differently during heating and forming. Production trials should confirm the appropriate temperature range, heating time and cooling conditions.
Some applications may accept a certain level of color or clarity variation, while others require a consistent visual appearance. Clear food trays and retail packaging may require stricter appearance control.
The material should be tested under actual production conditions. Important factors include:
Sheet thickness
Forming depth
Mold geometry
Heating-zone control
Vacuum or pressure settings
Cooling time
Trimming performance
Finished-part dimensions
MINGDU’s High-Speed Automatic BOPS PP PET Thermoforming Making Machine is relevant to projects involving BOPS, PP and PET sheet forming. However, the suitability of a specific recycled material should still be confirmed through material documentation and forming trials.
PP is widely considered for food containers, trays, lids and other packaging products. It may offer a useful balance of lightweight construction, chemical resistance and heat performance for selected applications.
When selecting PP sheet for thermoforming, manufacturers should review:
Food-contact suitability
Sheet thickness
Forming temperature
Heat resistance
Sealing compatibility
Recyclability in the target market
Recycled content availability
PET may be selected when clarity, stiffness or visual presentation is important. PET trays are used for various food packaging applications, but the exact material grade and structure should be matched to the product and sealing system.
Manufacturers should confirm:
Transparency requirements
Product visibility
Stiffness
Recycled content availability
Forming behavior
Tray and lidding-film compatibility
PS has historically been used in disposable food packaging and trays. Its suitability depends on the target market, application and applicable regulatory requirements. Manufacturers should not assume that a material used in an existing product will automatically meet future market expectations.
PVC and other thermoplastics may be used in specific applications, but their suitability should be assessed based on food-contact requirements, recycling conditions, additives, local regulations and customer specifications.
The correct material decision should be based on a complete review rather than on recyclability alone. Food protection, shelf life, sealing performance, appearance and production stability remain important.
PPWR does not require buyers to purchase a particular type of thermoforming machine. However, manufacturers may need equipment that can produce consistent packaging while supporting changes in material, thickness and design.
Stable heating is important when working with different sheet materials or recycled content. Buyers should ask about heating zones, temperature control, adjustment flexibility and process repeatability.
Uneven heating may lead to:
Thin spots
Wrinkles
Incomplete forming
Warping
Inconsistent tray dimensions
Surface defects
Vacuum forming, pressure forming and combined pressure-and-vacuum forming may be used for different food packaging designs.
The appropriate process depends on:
Tray geometry
Required detail
Forming depth
Material type
Sheet thickness
Production volume
Dimensional requirements
For projects that require controlled forming and packaging production flexibility, manufacturers can review MINGDU’s Pressure And Vacuum Forming Machine.
Mold design influences both packaging quality and material usage. Buyers should discuss:
Cavity layout
Product nesting
Draft angles
Corner radii
Venting
Cooling
Trim-line design
Stacking requirements
Changeover requirements
A well-designed mold can help improve sheet utilization and reduce unnecessary trim waste.
PPWR-related packaging projects may require careful control of the final tray dimensions and trim waste. The machine configuration should match the required cutting method.
Some projects may use mechanical cutting, while others may require a laser cutting system or a separate trimming process. The decision depends on product geometry, production volume, material and tooling requirements.
For higher-volume food packaging, forming may be coordinated with punching, cutting and stacking. MINGDU’s Multistation Thermoforming Machine category is designed around coordinated forming and downstream operations for products such as trays, containers and lids.
Automation can help reduce manual handling, but the final system should be selected according to the actual product and production plan.
Before confirming a machine, buyers should provide:
Material type
Sheet thickness
Recycled content information where applicable
Product drawings
Tray dimensions
Forming depth
Required output
Sealing method
Surface and appearance requirements
The supplier can then evaluate the material and recommend suitable machine parameters. A machine quotation based only on the product name may not be sufficiently accurate.
MINGDU provides several thermoforming equipment categories relevant to food packaging production, including pressure forming, pressure-and-vacuum forming, thin-gauge thermoforming and multistation thermoforming.
For food tray and container projects, the Plastic Food Tray Container Thermoforming Making Machine can be used as a relevant product reference.
For projects that require a configurable food packaging solution, manufacturers can also review the Customizable Pressure Sheet Thermoforming Machine for Food Packaging.
The final machine recommendation should be based on the customer’s actual material, tray structure, production volume and forming requirements. MINGDU can discuss:
Product dimensions
Material options
Sheet thickness
Forming method
Mold configuration
Cutting method
Stacking requirements
Production workflow
Trial and sample requirements
A machine supplier can support the forming process, but the packaging producer remains responsible for confirming the finished packaging’s regulatory suitability for the target market.
Food packaging manufacturers can use the following checklist when reviewing an existing or new thermoformed packaging project.
Is the tray made from one material or multiple material layers?
Are the lid, label, adhesive and coating compatible with the intended recycling route?
Does the packaging contain unnecessary components?
Can the tray structure be simplified without reducing product protection?
What is the polymer type?
Is recycled content used?
Is the recycled content documented?
Is the material suitable for the intended food-contact application?
Are additives, coatings and inks recorded?
Is the tray using an appropriate amount of material?
Can the wall thickness be optimized?
Is the tray sufficiently rigid during filling and transportation?
Are the rim and sealing areas stable?
Can the package be clearly identified and labeled?
Is heating consistent across the sheet?
Is forming stable across production cycles?
Is material distribution acceptable at deep corners and sidewalls?
Can trim waste be monitored?
Are finished parts inspected for dimensions and appearance?
Has the machine supplier reviewed the actual material?
Have product drawings and sheet samples been provided?
Has a forming trial been discussed?
Are mold cooling, venting and trimming requirements understood?
Are production records and quality checks defined?
PPWR places more focus on packaging recyclability, recycled content, material identification, packaging minimization, reuse and the control of certain substances. Thermoformed food packaging should be reviewed as a complete packaging system rather than as a plastic tray alone.
PPWR primarily regulates packaging and packaging waste, not thermoforming machines themselves. A machine does not receive automatic PPWR compliance status. The finished packaging, materials and supply chain documentation must be assessed according to the applicable requirements.
Not every food tray should be treated identically. Recycled content requirements may depend on packaging type, material, application and applicable timelines. Manufacturers should confirm the specific requirements for their product and target market.
PP and PET may be used for different food packaging applications, but recyclability depends on the complete package structure, local collection and recycling systems, additives, coatings, labels, adhesives and other components. A material name alone does not prove that a finished package is recyclable.
They should check material consistency, food-contact suitability, sheet thickness, heating behavior, forming performance, surface appearance, cooling behavior and documentation from the material supplier. Production trials are recommended before large-scale manufacturing.
PPWR restricts certain PFAS substances in food-contact packaging at specified concentration limits. The exact legal assessment depends on the substance, packaging type, concentration and applicable provisions. Manufacturers should obtain current regulatory advice and review materials, coatings and additives with their suppliers.
A multistation machine can coordinate stages such as forming, punching, cutting and stacking. This may help manufacturers manage consistent production, but the machine itself does not establish packaging compliance. Material, design, recycling and documentation requirements must still be addressed separately.
Provide the product drawing, tray dimensions, forming depth, material type, sheet thickness, recycled content information, target output, sealing method, trim requirements and any appearance or dimensional requirements. Samples of the intended sheet can also support process evaluation.
They can review cavity nesting, sheet size, tray geometry, wall-thickness distribution, trim layout, forming stability and material selection. Waste reduction should not compromise tray strength, food protection or sealing performance.
The EU PPWR is increasing the importance of packaging design, material selection and documentation across the food packaging supply chain. For thermoformed food packaging, the main considerations include recyclability, recycled content, material simplicity, packaging minimization, food-contact suitability and control of restricted substances.
The most practical approach is to evaluate the complete packaging system. A recyclable food tray should be considered together with its lid, label, adhesive, coating and other components. Similarly, a thermoforming machine should be selected according to the actual sheet material, thickness, product geometry, forming method and production workflow.
MINGDU offers pressure forming, pressure-and-vacuum forming, thin-gauge and multistation thermoforming equipment for different plastic packaging applications. If you are developing recyclable food trays, recycled content packaging or other thermoformed food packaging for the EU market, contact MINGDU with your tray dimensions, material, sheet thickness and target output.
MINGDU can then discuss a suitable forming configuration and recommend whether material testing or a production trial should be arranged before equipment selection.