PPWR 2026: What the New EU Packaging Rules Mean for Commercial Refrigeration
How packaging requirements are reshaping the supply chain — and what manufacturers and importers should prepare for
The EU Packaging and Packaging Waste Regulation (PPWR) marks a significant change in how packaging is regulated across the European market. Covering packaging placed on the EU market regardless of material or country of origin, the Regulation brings packaging design, material efficiency, recyclability and supply-chain information into closer focus.
For the commercial refrigeration industry, this matters because packaging is not a minor accessory.
A glass door refrigerator, upright freezer or undercounter refrigerator may travel thousands of kilometres before reaching its final market. Along the way, the cabinet must be protected from vibration, moisture, scratches, stacking pressure and impact. A typical packaging system can include corrugated cartons, corner protectors, plastic bags, internal protection, stretch film, straps and pallets.
As the European market moves toward stricter packaging requirements, the question for the refrigeration industry is no longer simply how to reduce packaging.
The more important question is:
How can manufacturers reduce unnecessary packaging while maintaining the level of protection required for heavy commercial refrigeration equipment?
Packaging Is Becoming Part of Product Readiness
Traditionally, commercial refrigeration manufacturers have focused their compliance efforts primarily on the equipment itself: electrical safety, energy efficiency, refrigerants and market-specific certifications.
Packaging was often treated separately as a logistics and cost issue.
PPWR changes that perspective.
Packaging increasingly needs to be considered as part of the product's overall readiness for the European market. The materials surrounding the equipment, the amount of packaging used and the information available about those materials may all become increasingly relevant across the supply chain.
This does not mean every existing carton, plastic bag or protective material must immediately be replaced.
Many PPWR requirements are introduced in stages. The direction, however, is clear: packaging should become more resource-efficient, increasingly recyclable and better documented.
For commercial refrigeration manufacturers, early preparation is therefore more practical than waiting until customers request information.
The Commercial Refrigeration Challenge: Protection Cannot Be Ignored
Commercial refrigeration equipment presents a different packaging challenge from many consumer products.
A large upright refrigerator may contain heavy components, glass doors, painted surfaces and refrigeration systems that require reliable protection during international transport. Reducing material without considering transport conditions can create another problem: product damage.
A damaged refrigerator may require replacement production, additional transport and disposal of damaged materials. In other words, less packaging is not automatically more sustainable if it significantly increases damage rates.
For this reason, the future direction of refrigeration packaging should not simply be:
Use less packaging.
It should be:
Use the right amount of packaging, in the right materials, for the right level of protection.
This balance will become increasingly important as manufacturers review packaging under the new regulatory environment.
What Parts of a Commercial Refrigerator Packaging System Should Be Reviewed?
There is no single "PPWR-compliant packaging model" for commercial refrigeration equipment. The requirements must be assessed according to the applicable packaging type and use.
However, manufacturers can begin by understanding the complete packaging structure of each major product category.
Outer Cartons
Heavy-duty corrugated cardboard remains an important solution for commercial refrigeration equipment.
Depending on product weight and transport conditions, packaging may use different structures such as double-wall corrugated board, BC or EB flute combinations, and different liner and paper specifications.
The future focus is not necessarily on reducing carton strength.
Instead, manufacturers should ask:
Is the carton appropriately sized?
Is unnecessary empty space being created?
Is the board specification higher than necessary for actual transport requirements?
Can the same protection be achieved with a more material-efficient design?
A properly designed high-strength carton may be more efficient than an oversized carton using excessive material.
Corner and Edge Protection
Corner protection is essential for products with glass doors and finished cabinet surfaces.
Possible materials may include paperboard angle protectors, kraft paper edge protection, corrugated components or paper honeycomb structures.
Where technically suitable, paper-based solutions may help simplify material systems. However, substitution should always be supported by compression and transport testing.
For a heavy refrigeration cabinet, a theoretically recyclable material is not automatically the right material if it cannot provide sufficient protection.
Internal Protective Materials
Internal protection can prevent product movement and reduce impact damage.
Depending on the application, manufacturers may review solutions such as molded pulp, paper honeycomb, corrugated inserts and other paper-based structures.
These alternatives may reduce reliance on certain mixed-material systems, but they must be evaluated according to actual performance.
International container transport exposes equipment to vibration, humidity and long transit times. Packaging redesign should therefore consider real logistics conditions rather than appearance alone.
Plastic Bags and Surface Protection
Plastic protective bags may be necessary to protect cabinets from dust, moisture and scratches.
The practical priority is not simply to eliminate all plastic. Manufacturers should first understand what plastic is actually being used.
For example:
- What polymer is used?
- Is the material mono-material or multi-material?
- What is the thickness?
- How much is used per unit?
- Can the supplier provide material and composition information?
Where technically appropriate, simpler and clearly identifiable material structures may be easier to document and manage than unnecessarily complex combinations.
Stretch Film, Straps and Pallets
Transport packaging is particularly important for large commercial refrigeration equipment.
Stretch film, PP or PET straps and pallets all contribute to load stability and product protection.
Manufacturers should therefore include these components in their packaging review rather than focusing only on the outer carton.
The objective is to understand how much material is used, why it is necessary and whether the packaging system can be optimised without compromising transport safety.
What Should Manufacturers Prepare?
For a manufacturer such as SUILING, the most practical first step is not to assume that the company must register packaging EPR in every European market.
PPWR packaging requirements and EPR obligations are not the same thing.
The legal responsibilities for registration, reporting and extended producer responsibility depend on the role of the economic operator, the specific Member State and the actual business model.
For a Chinese B2B manufacturer supplying EU importers, the more immediate operational priority is to establish reliable packaging information.
A useful internal packaging database could include:
| Packaging | Material | Information to Record |
| Outer carton | Corrugated cardboard | Structure, weight, material information |
| Corner protector | Paperboard / other | Material and weight |
| Internal protection | Foam / pulp / paper | Material, function and weight |
| Protective bag | PE / other plastic | Polymer type and weight |
| Stretch film | PE-based film | Material and usage per unit |
| Strap | PP / PET / steel | Material and weight |
| Pallet | Wood / plastic | Material and function |
This information can help manufacturers answer increasingly common customer questions about packaging.
It can also support future packaging optimisation.
The important point is that manufacturers should not wait until an importer asks, "What exactly is your packaging made of?" before starting to investigate.
What Should EU Importers Consider?
The situation is different for importers and other EU-based economic operators.
They should assess their own role in the relevant Member State and determine whether they fall within the definition of a producer for specific packaging obligations.
This may involve questions relating to registration, reporting and extended producer responsibility.
For this reason, the manufacturer and importer need to work together.
The manufacturer usually knows the technical details of the packaging.
The importer understands how the product is placed on its specific national market.
A more effective supply chain therefore involves an exchange of information.
Importers may increasingly ask manufacturers for packaging weights, material composition and supplier information. Manufacturers should be prepared to provide accurate technical data rather than general statements such as "recyclable packaging" or "eco-friendly materials."
A New Competitive Factor for Refrigeration Manufacturers
The impact of PPWR may extend beyond compliance.
It could gradually change how European buyers evaluate suppliers.
Traditionally, commercial refrigeration buyers have compared manufacturers based on product specifications, price, delivery time, production capacity and certifications.
These factors will remain fundamental.
However, packaging transparency may become an additional factor.
A supplier that can provide clear information about packaging materials, weights and structure may reduce the compliance workload of its European customers.
This creates an important distinction.
Two suppliers may offer similar refrigeration equipment at similar prices. But if one supplier can quickly provide a complete packaging breakdown while the other cannot identify the materials used in its own cartons, film and protective components, the first supplier may be easier to work with.
For importers managing multiple regulatory requirements, this can have real commercial value.
Packaging Optimisation Could Also Improve Logistics Efficiency
The PPWR discussion should not be viewed only as a compliance cost.
For commercial refrigeration manufacturers, reviewing packaging can also reveal operational opportunities.
A better-designed packaging system may help reduce:
- Unnecessary material consumption
- Packaging purchasing costs
- Excessive packaging volume
- Container space inefficiency
- Product damage during transport
- Disposal complexity for customers
The challenge is finding improvements without compromising product protection.
For example, reducing carton dimensions slightly may improve container loading efficiency. Replacing multiple small protective components with a more integrated structure may simplify assembly. Better packaging specifications may reduce inconsistent material quality between suppliers.
This means packaging optimisation can potentially support both compliance preparation and operational efficiency.
The Industry Is Moving From “Packaging Cost” to “Packaging Management”
The broader industry change is not simply about replacing plastic with paper.
It is about moving toward better packaging management.
In the past, the main questions might have been:
How much does the carton cost?
Can it protect the refrigerator?
How many units fit into a container?
These questions remain important.
But the future supply chain may also require manufacturers to answer:
What is the packaging made of?
How much of each material is used?
Why is each component necessary?
Can the materials be identified and documented?
Can unnecessary packaging be reduced?
Can the importer obtain the information needed for its own market obligations?
This is a significant change for the commercial refrigeration industry.
Packaging is becoming more closely connected with product development, procurement, logistics and market access.
How SUILING Is Looking at the Change
At SUILING, we believe packaging should continue to perform its primary function: protecting commercial refrigeration equipment throughout the supply chain.
At the same time, the regulatory direction in Europe makes it increasingly important to understand the materials and structures used around the product.
For manufacturers, preparation begins with visibility.
Understanding the packaging system. Documenting materials. Working more closely with packaging suppliers. Reviewing unnecessary complexity. And improving material efficiency without sacrificing protection.
For importers, reliable packaging information can also make it easier to assess their own obligations in specific European markets.
PPWR is therefore not only a regulatory topic.
For the commercial refrigeration industry, it is also a supply-chain topic.
And the manufacturers that begin improving packaging data and material transparency today may be better prepared for the expectations of tomorrow's European market.
Looking Ahead
The European packaging landscape is changing, and many PPWR requirements will continue to take effect in stages over the coming years.
For commercial refrigeration manufacturers, there is no need to redesign every packaging system overnight.
The more practical approach is to start with the fundamentals:
Know what materials are being used.
Know why each component is necessary.
Reduce unnecessary packaging where possible.
Maintain reliable protection for heavy commercial equipment.
Build accurate packaging data for customers and supply-chain partners.
As commercial refrigeration products move through increasingly regulated international markets, packaging will no longer be viewed only as the material used to deliver the product.
It will increasingly become part of how manufacturers demonstrate supply-chain readiness.