PPWR — Packaging & Packaging Waste Regulation
How ROLL Packaging products comply with Regulation (EU) 2025/40 on Packaging and Packaging Waste, applicable from 12 August 2026, replacing Directive 94/62/EC.
ROLL's role and scope of this declaration
This declaration applies to products manufactured for and supplied by ROLL SNC di Pini Sergio & C. Depending on their use, ROLL products fall within the definition of packaging under PPWR — when used to deliver products to another economic operator — or outside it, when used only as internal handling equipment within the user's own premises (Article 3(1), point (1)).
When ROLL products are placed on the market as packaging under the ROLL name, ROLL is the manufacturer within the meaning of Article 3(1), point (13), PPWR. In that role ROLL draws up the technical documentation (Annex VII) and the EU declaration of conformity (Article 39, Annex VIII model). A copy of the declaration is available on request, identified by item code.
ROLL declares compliance with the requirements of Regulation (EU) 2025/40 that apply to the products it places on the market as packaging, on the basis of supplier documentation. Requirements whose application is deferred — recyclability (Article 6), minimum recycled content (Article 7) and the minimum number of rotations for reusable packaging (Article 11(2)) — are addressed as and when they become applicable.
Each product page offers a printable technical data sheet with the ROLL statement on Articles 5, 7, 11 and 39, in English, Italian, French, German and Spanish.
Sustainability requirements
ROLL products are designed and manufactured taking into account the applicable PPWR requirements (Chapter II), with particular reference to:
- Substances in packaging, reusability and recoverability
- Prevention at source through reduction of packaging weight and volume, while maintaining the required technical performance
- Suitability for reuse, material recycling and energy recovery, where applicable
EN 13427 to EN 13432 were the harmonised standards under the former Directive 94/62/EC. ROLL uses them as technical references. Under PPWR, presumption of conformity applies only to harmonised standards whose references are published in the Official Journal under Regulation (EU) 2025/40 (Article 36).
Article-by-article compliance
Substances in packaging
The raw materials used by ROLL are selected and managed through internal procedures aimed at minimising substances that could adversely affect the safety, recyclability and circularity of packaging.
Heavy metals
ROLL declares that the sum of lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr VI) present in its packaging and packaging components does not exceed 100 mg/kg, the limit set by Article 5(4) PPWR. The declaration is based on supplier documentation (Article 5(6)). This applies to both plastic and cellulosic (paper, cardboard) materials.
SVHC substances (REACH)
As a downstream user under Regulation (EC) No 1907/2006 (REACH), ROLL relies on the information and declarations provided by its raw material suppliers. According to that information, no substance on the current ECHA Candidate List of Substances of Very High Concern is present above 0.1% w/w.
PFAS
ROLL does not intentionally use per- and polyfluoroalkyl substances (PFAS) as functional components of the raw materials employed in its products, according to supplier documentation. The PFAS limit values of Article 5(5) PPWR — 25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS, 50 ppm for total PFAS — apply from 12 August 2026 to food-contact packaging only. ROLL does not declare analytical PFAS results.
NIAS — Non-Intentionally Added Substances
For products manufactured from recycled materials, the presence of accidental traces of Non-Intentionally Added Substances cannot be completely excluded due to the inherent variability of secondary raw material streams. Any such presence is considered consistent with the current state of recycling technology and with the intended use of the products.
Recyclability
ROLL designs its products according to principles intended to promote recyclability and compatibility with commonly available collection and recovery systems. The recyclability conditions of Article 6 apply from 1 January 2030 at the earliest, following the Commission's delegated and implementing acts.
Plastic products
Designed to facilitate the mechanical recycling of the polymers used (HDPE, PP, LDPE and equivalent materials) and identified through the material coding system established by Commission Decision 97/129/EC.
Paper and cardboard products
Designed to be compatible with paper collection and recycling systems, where applicable.
Composite products
Some ROLL products use composite materials (polyurea-coated expanded polystyrene) that are not recyclable in standard streams. These products are designed for maximum durability and reuse, and are clearly identified as composite in the product technical documentation. The recyclability classification provided for by PPWR will be updated following the publication of the delegated acts and implementation guidelines issued by the European Commission.
Recycled content in plastic packaging
Where technically compatible with the required product performance, ROLL offers products manufactured using recycled plastic materials. Several pallet families in the ROLL portfolio are produced from recycled PP and HDPE, including options supplier-certified under the Plastica Seconda Vita (PSV) scheme.
No percentage of post-consumer recycled (PCR) content is currently declared per item; the online catalogue indicates whether an item is made from virgin or recycled polymer. Under Article 7(1) PPWR the minimum PCR content, calculated as an average per manufacturing plant and year, is 35% for plastic packaging such as pallets (point (d)) and 10% for contact-sensitive packaging other than PET (point (b)); the 30% targets concern PET packaging and single-use beverage bottles. It applies from 1 January 2030, or three years after the implementing act under Article 7(8) if later.
ROLL monitors the development of the recycled content requirements established by PPWR and will align its products with the minimum targets applicable to the relevant packaging categories when they apply.
Bio-based feedstock in plastic packaging
The provisions of Article 8 of Regulation (EU) 2025/40 concerning bio-based feedstock are subject to the adoption of future implementing acts and harmonised methodologies.
Where applicable, products manufactured using bio-based raw materials are supplied upon customer request and are identified in the relevant product technical documentation.
Compostable packaging
ROLL products are not declared compostable under Article 9 of Regulation (EU) 2025/40, unless otherwise specified and supported by an applicable certification (e.g. EN 13432) referenced in the relevant product technical documentation.
Packaging minimisation
ROLL products are designed and manufactured according to engineering principles aimed at minimising packaging weight and volume, while maintaining the functional, mechanical, logistical and load protection requirements necessary for their intended use, including the handling, storage and protection of rolls and reels.
Reusable packaging
ROLL manufactures two categories of packaging products:
Reusable products
Conceived and designed to be re-used and to accomplish as many rotations as possible under normally predictable conditions of use (Article 11(1)(a)–(b) PPWR). No number of rotations is declared; the minimum will be set by delegated act under Article 11(2). Suitable for re-use systems organised by the user; compatibility with specific pooling systems is not declared. This category covers roll cradle pallets, plastic pallets, pallet transformers, end plates, flanges and premium wedges. Metal rack stillages are internal handling equipment, outside the definition of packaging. Cardboard cradles (PC family) are not declared as reusable packaging.
One-way products
Designed for single-use applications, typically as wood-replacement solutions for the shipping of rolls and reels. These products are clearly identified as one-way in the technical documentation.
Product families covered by PPWR
The following ROLL product families fall within the PPWR scope when used as packaging for the shipping of rolls and reels. Each links to the full product range with technical specifications and compliance attributes per item.
Regulatory reference
This declaration is issued with reference to Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on Packaging and Packaging Waste, which entered into force on 11 February 2025 and applies from 12 August 2026, repealing Directive 94/62/EC.
The official text of the regulation in all 24 EU languages is available on the EUR-Lex portal at eur-lex.europa.eu.
Disclaimer
The information on this page is provided for guidance only, on the basis of ROLL's most up-to-date knowledge and experience and of supplier documentation. This page is not a third-party certificate. ROLL cannot assume liability for damage arising from its use. This statement does not constitute any warranty, express or implied. In case of discrepancy, the EU declaration of conformity for the specific item prevails. All ROLL products are sold subject to the ROLL SNC general sales conditions. This publication replaces all previous versions and is subject to change without notice.