How to comply with PPWR?

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) officially entered into force in February 2025 and has been fully enforced from August 12, 2026, replacing the previous Packaging and Packaging Waste Directive (94/62/EC).

Given that these are brand new regulatory requirements, numerous importers and brand owners are unsure about their specific obligations under PPWR. This article will clarify the key compliance items you need to address.

The regulation introduces stricter full life-cycle compliance requirements for packaging products placed on the EU market, covering material restrictions, packaging design, recyclability, recycled content, labeling, and producer responsibility obligations.

The key requirements include:

I. Restrictions on Materials and Chemical Substances (Mandatory from August 12, 2026)

1. Heavy Metal Limits

The total content of four heavy metals — lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr VI) — contained in packaging materials must not exceed 100 mg/kg.

This requirement applies to all packaging components, including inks, adhesives, coatings, and surface treatments.

2. PFAS Restrictions

For food-contact packaging, the use of per- and polyfluoroalkyl substances (PFAS) is strictly restricted.

The requirements include:

• Total fluorine content: ≤ 50 ppm 

• Non-polymeric PFAS substances: ≤ 25 ppb 

• Total PFAS content: ≤ 250 ppb 

II. Packaging Design and Waste Reduction Requirements (Phased Implementation)

1. Packaging Minimization and Waste Reduction

Packaging must be designed to achieve the minimum volume and weight necessary to ensure its intended function, while avoiding excessive packaging.

Starting from January 1, 2030, the empty space ratio of e-commerce packaging and transport packaging must not exceed 50%.

2. Recyclability Requirements

From January 1, 2030, packaging placed on the EU market must meet defined recyclability standards.

Packaging will be classified into different recyclability grades:

• Grade A: ≥ 95% recyclable 

• Grade B: ≥ 80% recyclable 

• Grade C: ≥ 70% recyclable 

Packaging below Grade C will gradually be prohibited:

• Grade C packaging will be banned from 2030 

• Grade B packaging will be banned from 2038 

3. Minimum Recycled Content Requirements

From January 1, 2030, plastic packaging must contain a minimum percentage of post-consumer recycled material (PCR).

Examples:

• Food-contact PET packaging: minimum 30% PCR content (increasing to 50% by 2040) 

• Other plastic packaging: minimum 35% PCR content (increasing to 65% by 2040) 

4. Restrictions on Specific Packaging Types

Starting from January 1, 2030, certain single-use plastic packaging formats will be prohibited, including:

• Lightweight plastic bags 

• Single-use plastic packaging components 

• Single-use miniature packaging used in hotels and catering industries 

• Small single-use fruit and vegetable packaging 

• Other unnecessary disposable plastic packaging formats 

III. Labeling and Information Disclosure Requirements (Phased Implementation)

1. Standardized Packaging Labels

From August 12, 2028, packaging must display standardized labeling requirements.

Labels must clearly indicate:

• Material composition 

• Recyclability level 

• Waste sorting instructions 

The EU will gradually introduce unified digital labeling systems, including QR-code-based information disclosure.

2. Compostability Identification

Packaging labeled as “industrially compostable” must clearly indicate this information to prevent consumers from incorrectly disposing of packaging waste and contaminating recycling streams.

IV. Compliance and Registration Requirements (Mandatory from August 12, 2026)

1. Extended Producer Responsibility (EPR) Registration

All entities placing packaging products on the EU market, including:

• Manufacturers 

• Importers 

• E-commerce sellers 

Must complete EPR registration in each applicable EU member state and pay corresponding waste collection and recycling fees based on packaging volume and weight.

Non-EU companies must appoint an authorized representative within the EU to fulfill relevant compliance obligations.

2. Declaration of Conformity (DoC)

Companies must prepare an EU Declaration of Conformity (DoC) and maintain supporting technical documentation, including:

• Test reports 

• Compliance assessment records 

• Packaging evaluation documents 

These documents must be retained for inspection by customs authorities and market surveillance agencies.

Note: EPR registration systems, fee structures, and enforcement procedures may vary between EU member states. Companies must complete compliance procedures separately according to the specific requirements of each destination country.

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