PACKAGING REGULATION AND CHOICES OF SUSTAINABLE MATERIALS: A CRITICAL DIALOGUE BETWEEN THE EUROPEAN PPWR AND BRAZILIAN DECREE NO. 12,688/2025, WITH EMPHASIS ON CARDBOARD AND CORRUGATED CARDBOARD

Abstract

Packaging regulation is at a historical turning point. In the European Union, Regulation (EU) 2025/40 – PPWR requires all packaging on the market to be economically recyclable by 2030, while harmonising design, labelling, prevention and substances of concern. In Brazil, Decree No. 12,688/2025 establishes the Reverse Logistics System for Plastic Packaging, with mandatory recovery targets (32% in 2026, scaling to 2040) and minimum post‑consumer recycled (PCR) content thresholds, starting at 22% in 2026 for large companies. This paper provides a critical comparison of these frameworks and discusses technical‑commercial implications for material selection, emphasising renewable, FSC chain‑of‑custody certified paperboard and corrugated board. We argue that cellulosic solutions, when designed for recycling (mono‑material, contaminant‑free and properly labelled), tend to reduce regulatory risk, compliance costs and reputational impacts while maintaining logistics performance. Decision‑making should be guided by design‑for‑recycling criteria, auditable traceability and evidence (LCA), prioritising cellulosics where technically feasible and, otherwise, polymers compatible with PCR targets and large‑scale recycling.