In the paints, coatings, adhesives, sealants and inks sector, packaging is no longer merely a logistical element. It has become an integral part of product design, sustainability strategy and regulatory compliance. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) is accelerating this transformation, but the real change concerns the way Research & Development, Regulatory Affairs, Purchasing, Quality and Supply Chain functions must work together to design competitive and compliant products.

For many years, packaging choices were driven mainly by technical performance, cost and availability. Today, that approach is no longer sufficient. The PPWR introduces a harmonised regulatory framework that will affect packaging design, waste prevention, recyclability and information management throughout the supply chain.

For a manufacturer of paints or adhesives, a metal can, plastic bucket, cartridge or IBC must continue to ensure safety, chemical compatibility, formulation stability and compliance with dangerous-goods transport requirements. At the same time, however, packaging will also have to be assessed against new European objectives for sustainability and circularity. Packaging therefore becomes a cross-functional issue involving design, purchasing, quality, sustainability and regulatory affairs.

From 12 August 2026, the PPWR is fully applicable in all Member States. For the Paint & Coatings sector, which will come together at Paint & Coatings Italy 2026 only two months after this deadline, the question is no longer whether to prepare for change, but whether to already be compliant.

A new approach to packaging design

Regulation (EU) 2025/40 does more than introduce new obligations: it asks companies to rethink how packaging is designed and managed throughout its lifecycle.

For the Paint & Coatings sector, this means no longer treating packaging as a component separate from the product, but as a design element to be developed from the earliest stages alongside the formulation.

An apparently simple choice, such as replacing a metal can with a plastic bucket or changing the format of a container, can have implications for chemical compatibility, product shelf life, transport methods, CLP labelling, ADR compliance and end-of-life management of the packaging.

From 12 August 2026, moreover, all packaging placed on the market must be recyclable (Article 6 of the Regulation): a principle that is already binding, even though the detailed criteria and recyclability performance classes A, B and C will become fully operational from 2030.

Another requirement concerns empty space in packaging: from 2030, its proportion in grouped and transport packaging may not exceed 50% (Article 24). This is a parameter that directly affects containers such as buckets and cans for paints and coatings, where the relationship between container volume and product has never been a marginal detail.

Packaging design is therefore becoming increasingly multidisciplinary and requires coordinated involvement from different business functions.

What complying with the PPWR means in practice

One of the most significant aspects of the new Regulation concerns companies’ internal organisation.

Compliance is not simply a matter of replacing one package with a more sustainable alternative; it requires reliable data and documented processes that make it possible to demonstrate compliance with the applicable requirements.

For many companies in the sector it will therefore be necessary to:

These activities require increasingly close collaboration between Regulatory Affairs, Purchasing, Quality, Sustainability and Research & Development.

Compliance involving multiple regulations

Companies in the Paint & Coatings sector already operate in a complex regulatory environment. Packaging may simultaneously be affected by the CLP Regulation for the classification and labelling of substances and mixtures, ADR requirements for the transport of dangerous goods and, now, the PPWR as well.

The challenge is not simply to comply with each individual regulation, but to integrate these requirements within a single decision-making process, avoiding duplication, document inconsistencies and corrective action at the final stages of product development.

Four questions to ask today

Companies wishing to prepare for the new requirements can begin by asking themselves some fundamental questions:

From compliance to competitive advantage

Companies that begin structuring their processes now will be able to manage the change more efficiently, reducing the risk of non-compliance and improving dialogue with customers and suppliers.

Compliance is no longer simply a regulatory obligation; it can become a tool for organisational innovation and a competitive factor, particularly in a sector such as Paint & Coatings, where product quality, safety, sustainability and performance must coexist.

Normachem supports companies in the chemical and formulation sectors in interpreting European legislation and defining practical, proportionate and business-oriented compliance pathways, helping companies assess applicable obligations, collect technical information and organise compliance processes.

The future of the Paint & Coatings sector will depend not only on innovation in formulations, but also on the ability to integrate regulatory compliance into business processes. The PPWR represents an important opportunity to rethink the role of packaging throughout the product lifecycle and to build more efficient and resilient organisational models.

At Paint & Coatings Italy 2026, the Normachem team will be pleased to discuss the practical implications of the PPWR and the most effective strategies for managing the change with manufacturers, importers and distributors. We look forward to welcoming you at stand 448 and to our sessions on Thursday 29 October on the European Packaging Regulation (Conference, 11:30, and TechFocus, 14:20). To attend the exhibition free of charge, you can register via this link.

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