Gift Tins and PPWR Minimisation: What Changes in 2030

From 1 January 2030, Article 10 of PPWR requires packaging to be reduced to the minimum weight and volume needed for its function, and forbids characteristics whose only aim is to make the product look bigger: double walls, false bottoms, unnecessary layers. We make decorative gift tins. Part of what a gift tin does is on that list.

So: what changes, what is defensible, what to stop doing. See also what packaging buyers need to know about PPWR.

What Article 10 says, and when

Art. 10(1), from 1 January 2030: weight and volume shall be reduced to the minimum necessary to ensure functionality, taking account of shape and material. Art. 10(2): packaging shall not be placed on the market if it fails the Annex IV criteria, or has characteristics aiming only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers.

The date matters as much as the wording. Article 10 is not in force today. Regulation (EU) 2025/40 has applied since 12 August 2026, but until 31 December 2029 minimisation is governed by EN 13428:2004 under Directive 94/62/EC. Compliance pages say otherwise, some quoting a figure and a date for the separate empty space rule that the text does not support.

What survived for gift packaging

Annex IV, Part A, point 4 requires design to ensure functionality "taking into account the purpose of the product and particularities giving rise to its sale, such as sales for gift purposes, or on the occasion of seasonal events". That is what a metal gift tin lives on, and it is not an exemption: Art. 10(4) and Annex IV Part B want, for each criterion, the design requirement preventing further reduction. Argued, pack by pack.

Two familiar justifications are gone. Consumer acceptance and marketing were removed as grounds (recital 60, and the guidance says so in terms). "Customers like the look" is not a defence.

The exemption almost nobody can use

Art. 10(2)(a) exempts packaging protected by a design right or registered shape trademark, but only where the right was protected before 11 February 2025, and only where Article 10 would destroy its novelty or distinctiveness. Rights registered later get nothing, and most brands never registered one. It covers minimisation only: not recyclability, labelling, PFAS, heavy metals, EPR.

What we would change on a tin

Defensible, because the feature does work you can point at:

• A lid that reseals. Slip-on and inner-plug lids keep the pack closed after opening. Our lid types differ in how much metal they need, which is now a design decision, not just cost.
• Wall gauge and depth that protect the contents. Art. 10(1) asks for the minimum that ensures functionality.
• Embossing and the printed surface. Decoration on the metal adds no layer and no volume.
• A sealed inner pouch where the product needs a barrier. A decorative tin is not airtight. A layer carrying the shelf life works; one filling space does not.

Harder to defend, and we make all of them:

• Double skins and false bottoms. Named in Art. 10(2). Where a raised base makes a 200 g fill read as 300 g, it goes.
• Deep insert trays with headspace above the product. The tray is a layer, the headspace is volume.
• A sleeve or carton around a tin that is already rigid and printed. The clearest unnecessary layer.
• Window lids and one-piece acrylic lids. Art. 7(5)(b) leaves a plastic part outside the recycled content rules only under 5% of unit weight, and recyclability is graded per unit across all components (Art. 6(9)).

The weight argument, honestly

EPR fees are charged by weight and sit with the EU-side operator, usually the brand. A 250 g tin against a 12 g laminate pouch pays far more per unit even at a lower rate per tonne, and eco-modulation cannot close it. Anyone saying a tin wins on EPR is selling tins.

The other side is real too. Steel is a mono-material with an established separate collection stream in the EU, and 84% of steel packaging placed on the EU market was recycled in 2024 (Steel for Packaging Europe, EU harmonised method). That is a fact about steel, not your pack: the grade is assessed on the whole unit, so ribbons, board inserts and windows are yours to defend (see are tin boxes recyclable). Nor will we claim PPWR grows demand for metal. The defensible line is narrower: it penalises complexity, and steel is simple.

What is still unwritten

The design-for-recycling criteria and grades come from a delegated act due by 1 January 2028, and from 1 January 2030 packaging below grade C may not be placed on the market. Nobody can state a grade today, us included. The minimisation standard and empty space methodology are unpublished. The labelling acts are not adopted, so the 12 August 2028 date is conditional: that date or 24 months from entry into force of those acts, whichever is later. A tin tooled now for 2030 carries risk nobody can quantify.

What to decide now

Decide now, while it is cheap: size the tin to the fill, not the shelf; weigh every non-steel component and ask what it does; write the Annex IV Part B justification while the reasoning is fresh. Leave until the criteria land: grade claims, empty space sums, label artwork. And do not lean on re-use: keeping a tin is not PPWR re-use, and no Art. 29 target reaches retail food tins.

One last point on whose job this is. For a brand-printed tin the PPWR manufacturer is the brand, not the factory: Art. 3(1)(13)(a) puts that role on whoever has packaging made under its own name or trademark. Our duty is Art. 16: to give you what the Annex VII file needs, weights and components and the reason for each feature. The Article 10 justification is yours. If you want that conversation before the mould is cut, ask us for a quote and mention PPWR.

Frequently asked questions

Does PPWR ban decorative gift tins?

No. From 1 January 2030, Art. 10(1) cuts weight and volume to the minimum needed for functionality, and Art. 10(2) forbids features whose only aim is to increase perceived volume, naming double walls, false bottoms and unnecessary layers. Gift and seasonal purpose is a criterion in Annex IV, Part A, point 4, but it must be argued and documented.

Is the minimisation rule in force now?

No. Regulation (EU) 2025/40 has applied since 12 August 2026, but Article 10 takes effect on 1 January 2030. Until 31 December 2029, minimisation is governed by EN 13428:2004 under Directive 94/62/EC.

Can we use the design right exemption for our tin shape?

Only if the right was protected before 11 February 2025, and only where Article 10 would destroy its novelty or distinctiveness. Rights registered later get nothing, and it covers minimisation only, not recyclability, labelling, PFAS, heavy metals, EPR.

Do double walls and false bottoms have to go?

Art. 10(2) names them where the aim is only to increase perceived volume. A base holding an insert in place is a design requirement you can explain under Art. 10(4) and Annex IV Part B. A raised bottom that makes the fill look bigger is the target.

Our customers keep our tins. Is that re-use under PPWR?

No. Art. 11(1) sets nine cumulative criteria for reusable packaging, and Art. 26 requires a re-use system with a collection incentive. Keeping a tin is good; it is not a PPWR re-use claim. No Art. 29 re-use target applies to retail food tins either.