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SHORT ANSWER The EU PPWR does not ban all plastic, but it has applied to every pack placed on the EU market since 12 August 2026 and tightens recyclability and recycled-content rules through 2030. For glass bottle inserts, wet-press molded pulp is a recyclable fiber alternative to EPS foam and PET/PS blister trays. |
Why the PPWR is changing glass bottle packaging
The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, entered into force on 11 February 2025, and its main obligations have applied since 12 August 2026. Because it is a regulation rather than a directive, it applies directly and uniformly in all 27 Member States. Packaging that does not comply can no longer be placed on the EU market.
Brands in wine, spirits, cosmetics, and liquid or semi-solid foods are re-examining how their glass bottles are protected. Expanded polystyrene (EPS) cushions and PET/PS blister trays face growing pressure on recyclability, recycled content and packaging reduction. Wet-press molded pulp (also spelled moulded pulp or molded fiber) is made mainly from paper fiber and fits established paper recycling streams. It is hot-pressed in the mold (the process is also called thermoformed fiber), which gives thin walls, a smooth surface and a close fit around the bottle.
What the PPWR requires: not a blanket plastic ban
The PPWR is often called an EU plastic ban, but that is not accurate. Its main requirements are:
Bans on specific single-use plastic formats: formats listed in Annex V may not be supplied from 1 January 2030. Examples include hotel miniatures, bags for fruit and vegetables under 1.5 kg, and non-functional over-packaging.
Recyclability for all packaging: all packaging placed on the market must be recyclable, and reuse targets apply.
Recycled content: for plastic packaging in the "other" category, the minimum recycled content is 35% in 2030 and 65% in 2040. Sources differ on exact application dates, so check the official text.
PFAS limits: concentration limits for PFAS in food-contact packaging apply from 12 August 2026. Products placed on the market earlier do not have to be withdrawn.
Non-EU companies are covered: the rules apply to manufacturers, importers, brand owners and distributors placing packaging on the EU market, wherever they are based. Packaging without a declaration of conformity and test evidence may be refused at the border.
What this means for molded pulp. A bottle insert is secondary packaging. PET/PS blister and EPS inserts are not necessarily named in the Annex V list, but they carry rising compliance costs on recyclability and recycled content. Molded pulp is a fiber material with a mature paper recycling route, which makes it a natural way to lower compliance risk. The PPWR does not require molded pulp specifically, so orders still depend on cost, protection performance and supply capability.
Design case: a four-position mixed-bottle wet-press tray
The design below shows how one molded pulp tray can hold several different glass bottles in a single gift or multi-pack format.

Figure 1. Wet-press molded pulp tray, 420 mm × 380 mm × 70 mm, with four bottle positions and one accessory pocket.
Specifications
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Item |
Detail |
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Outer dimensions (L × W × H) |
420 mm × 380 mm × 70 mm |
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Footprint / enclosing volume |
About 0.16 m² / roughly 11.2 L |
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Process |
Wet-press (thermoformed, hot-pressed) molded pulp |
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Cavities |
Three long tapered bottle cavities, one square-shouldered short-neck bottle cavity, one shallow accessory pocket |
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Neck design |
Shared neck channel along the back edge, plus a separate neck relief for the square bottle |
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Wall thickness |
1.2mm |
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Tray weight |
115g |
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Drop test result |
630 mm drop on a packed unit of 4 bottles, drop sequence per ISTA 1A (1 corner, 3 edges, 6 faces); pass criteria: no bottle breakage, no leakage, tray and outer carton intact |
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Material |
Virgin sugarcane bagasse / can also use recycled fiber, coating or no coating |
Cavity sizes are visual estimates from the drawing and should be confirmed against the 3D file.
Cavity layout
Three long, tapered bottle cavities: bottles lie flat with necks facing the back edge. Suitable for wine, premium sauces, essential oils or skincare liquids.
One square-shouldered, short-neck bottle cavity: suited to spirits, perfume or cream jars.
One shallow, rounded-square pocket: in the rear right corner, for an accessory, sample, coaster or instruction card.
A continuous neck channel: the three long bottles share one groove, which tolerates different neck diameters and heights across SKUs and eases assembly.
Engineering notes
The 70 mm depth typically suits bottles of roughly 60 mm diameter or less lying flat. Larger diameters call for a deeper tray.
For irregular multi-cavity wet-press tooling, draft angle and corner radii control forming quality. Deeper cavities and sharper corners place higher demands on the tool and the pulp slurry.
Wet-press pulp is hot-pressed in the mold, which supports thin walls, a smooth surface, a tight fit and small draft angles. Dry-press pulp is thicker and rougher, so it is usually chosen for heavy-duty cushioning rather than for premium bottle presentation.
How molded pulp is used for glass bottles
Packaging formats
Single-bottle tray: one bottle per cavity, common for premium baijiu, spirits, perfume and serums, usually paired with a folding carton and replacing an EPS insert.
Shared multi-size tray: one tray holds three or more bottle sizes, typical of gift sets, assortments and trial kits. One tool can serve several SKUs by changing which positions are used.
Tray with molded pulp lid: two pulp pieces close together to form a full cushion, suited to demanding drop requirements, export shipping and e-commerce.
Tray placed directly in a carton: no separate lid, lower cost, and the most common retail format.
End markets
Cosmetics: serums, lotions, perfume, gift sets
Wine and spirits: wine, spirits, sake, beer gift packs
Other liquids: edible oil, vinegar, soy sauce, beverages, oral liquids
Semi-solid products: honey, jam, creams, sauces
Bottle shapes: round, square, tapered or irregular; tooling is made to match the bottle
Molded fiber market data
Market research firms define the molded fiber market differently, so their figures suit trend-spotting but should not be added together.
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Source |
Scope |
Figures |
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Smithers |
Global molded fiber |
About USD 4.5 billion in 2025 and 12.6 million tonnes of consumption; 4.1% CAGR to 2030 |
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Market Glass report |
Global molded fiber packaging |
USD 8.4 billion in 2024, rising to USD 10.3 billion by 2030 (3.5% CAGR); China forecast at 6.3% CAGR |
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Fortune Business Insights |
Global molded fiber packaging |
USD 9.10 billion in 2025, of which Europe about USD 1.63 billion; Asia Pacific holds 39.01% |
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Spherical Insights |
Global molded fibre pulp packaging |
USD 7.85 billion in 2025; 6.44% CAGR forecast for 2026 to 2035 |
Takeaways
Steady growth overall. Most forecasts fall between about 3.5% and 6.5% a year. Smithers explicitly cites PPWR implementation and spreading EPR schemes as supports for growth.
Europe is uneven. FMI forecasts annual growth of 5.5% in Spain, 4.5% in Italy, 3.5% in France and 3.4% in the UK, against 1.6% in Germany, a more mature market. New opportunities are more likely in southern Europe and France, where premium wine, spirits and cosmetics packaging is a larger share of demand.
Higher-value niches have more room. Commodity egg trays and foodservice packaging are already price-driven. Glass bottle inserts demand dimensional accuracy, cushioning and a good appearance, which supports better pricing.
Outlook and risks
Tailwinds
PPWR recyclability and recycled-content pressure is pushing brands to evaluate alternatives to plastic inserts.
Brand ESG targets and retailer requirements are moving packaging away from plastic.
Upgraded wine, spirits and cosmetic gift packaging calls for custom inserts with better cushioning.
Risks and challenges
Cost: custom tooling is expensive, and small runs carry a higher unit price.
Thin-wall design: walls of about 1.2 mm need careful cavity and rib design to carry heavy glass, so drop and vibration testing on the packed unit is essential.
Impact transfer: wet-press pulp disperses low- and medium-energy impacts well, but its thin, dense walls absorb less energy than thicker dry-press cushioning, so a very hard impact can pass through to the bottle. Testing with the actual bottle and outer carton shows whether the cavity layout protects it.
Moisture resistance: liquid and semi-solid products can leak or cause condensation, so water resistance needs evaluating.
Chemical compliance: coatings that use fluorinated chemistry would run into the PFAS limits, so compliant alternatives are needed.
Documentation: exporters need a declaration of conformity, material test reports and a clearly named responsible party in the EU.
Uneven national enforcement: in Germany, for example, fines for breaching PPWR obligations only apply from 12 February 2027.
Frequently asked questions
Does the EU PPWR ban plastic packaging?
No. Regulation (EU) 2025/40 does not ban plastic across the board. It bans specific single-use formats listed in Annex V from 1 January 2030 and requires all packaging to be recyclable, with minimum recycled content for plastic packaging. Plastic inserts therefore carry rising compliance costs.
When does the PPWR apply?
It entered into force on 11 February 2025 and its main obligations have applied since 12 August 2026. It applies directly in all 27 Member States and also covers companies outside the EU that place packaging on the EU market.
Can one molded pulp tray hold bottles of different sizes?
Yes. A multi-cavity tray can combine long tapered bottles, short square-shouldered bottles and a small accessory pocket, as in the 420 × 380 × 70 mm design shown above. A shared neck channel helps absorb differences in neck diameter and height between SKUs.
What is the difference between wet-press and dry-press molded pulp?
Wet-press (thermoformed) pulp is hot-pressed in a heated mold while still wet, giving thin walls of roughly 0.8-2 mm, a smooth surface and a tight fit. Dry-press pulp dries outside the mold in an oven, so walls are thicker (about 1.5 mm and up) and the surface is rougher. Wet-press suits premium glass bottle inserts; dry-press suits heavy-duty cushioning.
Do the PFAS limits affect molded pulp?
They can. PFAS concentration limits for food-contact packaging apply from 12 August 2026. A bottle insert is usually secondary packaging, but any water- or grease-resistant coating should be checked, and fluorine-free alternatives are the safer choice.
How should a molded pulp tray be validated for glass?
Protection depends on wall thickness, cavity fit and the outer carton, so a tray should be validated with drop and vibration tests on the full packed unit before launch.
Conclusion
The PPWR does not outlaw plastic, but it changes the cost and compliance profile of plastic inserts and strengthens the case for fiber-based materials in European packaging procurement. For glass bottles, molded pulp trays that combine multi-size flexibility, dependable cushioning, recyclability and verified compliance are best placed to win long-term brand business.
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NEED A CUSTOM MOLDED PULP TRAY? Send us your bottle drawings or samples, target market and quantity. We will propose a cavity layout, process option and compliance documents for the EU. Contact: Hesheng Innovation Development Co., Ltd. - send an inquiry |
Sources
Baker McKenzie, EU: Navigating the PPWR
ComplianceGate, PPWR Timeline and Dates
All4Pack, PPWR: how the entry into force will affect the sector
Smithers, The Future of Moulded Pulp Packaging to 2030
Fortune Business Insights, Spherical Insights, FMI and Market Glass market reports
Figures are third-party estimates. Verify policy dates against the official text of Regulation (EU) 2025/40 before relying on them.

