On 12 August 2026, the core provisions of the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) became applicable. All packaging placed on the EU market and all related enterprises must comply with the new requirements.

⚠  Core provisions now in effect: From 12 August 2026, packaging placed on the EU market must satisfy hazardous substance limits, producer information labelling, EPR registration, and declaration of conformity. Non-compliant packaging may be intercepted at customs or face delisting and fines in the EU market.

 I. Hazardous Substance Restrictions (Effective 12 August 2026)

PPWR Article 10 sets strict limits on hazardous substances in packaging. Compared with the previous Directive, the scope of control has expanded from “overall packaging” to “each individual component,” with no exemption threshold. Specific requirements are as follows:

1. Heavy Metal Concentration Limits (Article 10(1))

The total concentration of lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr⁶⁺) in packaging or packaging components shall not exceed 100 mg/kg (i.e. 0.01%). This limit applies to every separable component of the packaging (e.g. bottle body, cap, label, ink, adhesive), not an average across the whole packaging unit. The previous exemption for small components (≤0.25 m²) has been abolished — all components must comply.

2. PFAS (Per- and Polyfluoroalkyl Substances) Limits (Article 10(2), New)

This is a newly introduced control under PPWR, targeting PFAS in food-contact packaging, with a three-tier limit:

●  Single PFAS substance: below the limit of detection (target detection limit 0.025 mg/kg, i.e. 25 ppb)

●  Sum of PFAS: ≤1 mg/kg (i.e. 1 ppm)

●  Total Organic Fluorine (TOF): ≤50 mg/kg (i.e. 50 ppm)

★ Testing strategy: You may prioritise “Total Organic Fluorine (TOF) ≤ 50 mg/kg” as a screening indicator. If compliant, individual PFAS substance testing may be omitted, significantly reducing testing costs. This step-wise testing strategy has been recognised by multiple industry bodies.

3. Compliance Documents to Prepare

●  Test report for hazardous substances in packaging materials (issued by a third-party laboratory, covering Pb/Cd/Hg/Cr⁶⁺ total heavy metals)

●  PFAS test report or substance declaration (applicable to food-contact packaging; TOF screening recommended)

●  Material Safety Data Sheet (MSDS/SDS, covering all component materials)

●  Supplier declaration of non-use of restricted substances (REACH declaration)

 II. Labelling Requirements (Two-Phase Implementation)

PPWR adopts a phased approach to packaging labelling. Phase 1 takes effect on 12 August 2026; Phase 2 will follow on 12 August 2028.

Phase 1 (Effective 12 August 2026) — Producer Information Labelling (Article 12(1))

From 12 August 2026, all packaging placed on the EU market must display the following producer information: packaging material composition identifier (material code), and producer name or registration number. The labelling must be clearly legible, firmly affixed, and placed on the packaging itself or its attached label. For transport packaging (e.g. corrugated cartons), the information may be indicated on shipping documents.

Phase 2 (Effective 12 August 2028) — Uniform Material Pictogram Labels (Article 12(2)–(5))

The European Commission will develop uniform material classification pictograms and a colour-coding system. Packaging will then be required to display material information in the prescribed format, facilitating consumer identification and separate collection. Additionally, reusable packaging must bear a “reusable” label and the minimum number of uses.

●  QR codes may serve as a supplementary information carrier, but physical labels remain mandatory

●  Environmental claims (e.g. “biodegradable,” “o eco-friendly”) must be substantiated; generic or vague statements are prohibited (Article 12(7))

⚠  Important note: QR codes cannot fully replace physical labels. Physical labels are mandatory; QR codes serve only as a digital supplementary information channel. Do not affix only a QR code while omitting the physical material identifier.

 III. EPR Registration Requirements (Effective 12 August 2026)

PPWR Articles 44 to 46 establish the Extended Producer Responsibility (EPR) system, requiring all “producers” to complete registration before placing packaging on the EU market. Key points are as follows:

1. Who Qualifies as a “Producer”?

Any of the following scenarios constitutes a “producer” under PPWR, triggering the registration obligation:

●  Packaging manufacturers established in the EU

●  Packaging importers established in the EU

●  Packaging distributors established in the EU (selling under own brand)

●  Non-EU enterprises selling packaged products to EU consumers via remote sales (including cross-border e-commerce)

●  Fulfilment service providers established in the EU (warehousing, packaging, distribution)

⚠  Key reminder: PPWR does not provide a single EU-wide registration system. Producers must register individually in each Member State. Non-EU enterprises must also appoint an authorised representative in each Member State. Registration in one country does not confer the right to sell across the entire EU.

2. Information Required for Registration

●  Company name, address, and contact details

●  Types, materials, and quantities of packaging placed on the market

●  Authorised representative information (applicable to non-EU enterprises)

●  Proof of EPR compliance scheme participation (membership in a Producer Responsibility Organisation, PRO)

 IV. What Counts as “Packaging”? What Must Suppliers Provide?

PPWR Annex I defines the criteria for packaging: any item that serves the function of containing, protecting, handling, delivering, or presenting a product is considered packaging. Common examples:

●  Considered packaging: product outer boxes, shrink film, labels, cushioning foam, corrugated cartons, wooden pallets, express delivery boxes, bubble wrap, caps/closures, ink layers

●  Not considered packaging: integral components of the product itself (e.g. the body of a tea canister), tool cases (functional product components)

★ Supplier cooperation checklist: Packaging users (brand owners, traders) are advised to request the following documents from packaging suppliers to ensure smooth customs clearance: 

(1) Packaging material composition declaration;

 (2) Heavy metal test report (Pb/Cd/Hg/Cr⁶⁺); 

(3) PFAS test report (applicable to food-contact packaging);

 (4) REACH non-hazardous-substance declaration; 

(5) Packaging recyclability assessment report (in preparation for 2028 requirements);

 (6) EPR registration number or PRO participation proof; 

(7) Draft Declaration of Conformity (DoC).

 V. Action Plan for Enterprises

PPWR is a long-term regulation implemented in phases. Enterprises should adopt a two-step approach to compliance:

Essential Compliance (Effective 12 August 2026 — Immediate Action Required)

●  Complete or update EPR registration in each Member State; non-EU enterprises must appoint an authorised representative

●  Obtain heavy metal test reports for all packaging components, ensuring each component ≤100 mg/kg

●  Label packaging with producer information (name/registration number) and material composition code

●  Prepare and sign the EU Declaration of Conformity (DoC); retain technical documentation for at least 5 years

●  Request the above compliance documents from packaging suppliers and establish a supplier compliance file

Full Compliance (Phased Implementation 2028–2030 — Advance Planning Recommended)

●  Update packaging labels to the EU uniform pictogram format (before August 2028)

●  Assess packaging recyclability grade (A/B/C; from 2030, only grades A/B may be placed on the market)

●  Meet minimum recycled content requirements (from 2030, plastic packaging 10%–35%)

●  Control packaging void space ratio ≤50%; reduce over-packaging

The implementation of PPWR marks the EU’s entry into an era of full life-cycle packaging management. Enterprises are urged to complete essential compliance arrangements as soon as possible to avoid risks of customs detention, market delisting, or substantial fines. Our company offers one-stop compliance consulting services — please do not hesitate to contact us should you require assistance.