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 and supplied by ROLL SNC di Pini Sergio & C. Depending on their final use, ROLL products may fall within the definition of packaging under PPWR — typically when shipped together with goods to the end customer — or fall outside it, when used as internal handling equipment within a factory or warehouse.
ROLL declares compliance with the applicable requirements of Regulation (EU) 2025/40 (PPWR) and, until 11 August 2026, of Directive 94/62/EC on Packaging and Packaging Waste, on the basis of supplier documentation, internal manufacturing procedures and harmonised standards EN 13427 to EN 13432.
Except where a ROLL product itself constitutes the final packaging placed on the market, ROLL does not act as the economic operator responsible for placing the packaging on the market within the meaning of PPWR.
Essential requirements
ROLL products are designed and manufactured in compliance with the applicable PPWR essential requirements, with particular reference to:
- Packaging composition, 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
Where relevant, compliance is assessed in accordance with the harmonised standards EN 13427, EN 13428, EN 13429, EN 13430, EN 13431 and EN 13432.
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) in its products does not exceed the limit of 100 ppm established by the applicable legislation. 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. The raw materials used are compliant with the requirements of REACH and the current ECHA Candidate List of Substances of Very High Concern.
PFAS
ROLL does not intentionally use per- and polyfluoroalkyl substances (PFAS) as functional components of the raw materials employed in its products. Compliance assessments regarding PFAS requirements under PPWR will be carried out in accordance with the applicable legislation and its implementing measures.
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.
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.
The percentage of recycled content is declared on a case-by-case basis within the relevant technical or commercial product documentation, and is also indicated through structured product attributes in the online catalogue.
ROLL continuously monitors the development of the recycled content requirements established by PPWR and is committed to progressively aligning its products with the minimum recycled content targets applicable to the relevant packaging categories.
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.
Source reduction is verified in accordance with EN 13428 where relevant.
Reusable packaging
ROLL manufactures two categories of products:
Reusable products
Designed according to the principles of reusability set out in Article 11 of Regulation (EU) 2025/40 and EN 13429, with the objective of enabling multiple use cycles throughout the supply chain. This category covers the majority of the ROLL portfolio, including roll cradle pallets, end plates, flanges, reusable wedges and metal rack stillages.
One-way products
Designed for single-use applications, typically as wood-replacement solutions for the shipping of rolls and reels. These products are designed to optimise recyclability at end of life and are clearly identified as one-way in the technical documentation.
The reusability status of each product is declared as a structured attribute in the online catalogue, enabling buyers to filter products by intended use.
Product families covered by PPWR
The following ROLL product families fall within the PPWR scope when used as packaging for the shipping or storage 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 shall apply 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. ROLL cannot assume liability for damage arising from its use. This statement does not constitute any warranty, express or implied. It is intended only for the addressee and cannot be transferred to third parties. 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.