The EU PPWR Packaging Regulation Is About To Come Into Force; The Compliance Red Lines For Packaging Are Now in Effect.

The first batch of mandatory provisions of the European Union's *Packaging and Packaging Waste Regulation* (hereinafter referred to as PPWR, Regulation (EU) 2025/40) will officially enter into force on 12 August 2026. This regulation, which supersedes the previous Directive (94/62/EC), is the "strictest packaging legislation in the history of the EU." It will be directly and uniformly applied across all 27 Member States without requiring individual Member States to transpose the legislation into their own legal frameworks. This milestone marks the formal entry of packaging and packaged goods exported to the EU into a new regulatory phase characterized by "unified standards and end-to-end compliance."

Regulatory Content

Scope of Application for PPWR

Application scope of PPWR: all materials, all scenarios, and all main components

Compatible with all materials: plastic, paperboard, glass, metal, composite film, foam padding, vacuum-formed liners, express shipping stretch film, individual flavorized small packaging bags, gift box plastic sealing, etc.;

Covers all application scenarios: sales packaging, combined packaging, transport packaging, e-commerce packaging, service packaging, and more;

Covers all stakeholders: manufacturers, importers, distributors, retailers, suppliers, cross-border sellers, export traders, and others.

Maximum limits for substances in packaging

1. The total content of the four heavy metals-lead, cadmium, mercury, and hexavalent chromium-in all packaging shall not exceed 100 mg/kg;

2. New PFAS restrictions for food-contact packaging

· Single PFAS (non-polymeric) <25 ppb

· Total PFAS (non-polymeric) <250 ppb

· Total PFAS content (expressed as fluorine content) including polymers ≤ 50 ppm

Sustainability hard metrics

1. Recyclability: As of January 1, 2030, packaging must meet Grade C or higher (recyclability ≥70%); as of January 1, 2038, only Grade A (recyclability ≥95%) and Grade B (recyclability ≥80%) will be permitted, while packaging of Grade C or below will be prohibited from entering the market.

2. Recycled plastic content: For the first time in the packaging sector, the recycled material content requirement has been elevated to a mandatory standard, with phased targets established for different types of plastic packaging;

3. Reduction and Void Ratio: From 2030 onward, the void ratio of packaging shall be ≤50%, and over-packaging shall be prohibited;

4. Labeling Information: Packaging placed on the market must comply with unified labeling standards prescribed by applicable regulations, and must disclose the material composition and recyclability markings;

5. EPR Registration: Producers whose packaging is first placed on the market in an EU member state, or who directly sell packaged products to end consumers, shall complete EPR registration in accordance with the requirements of the target market, submit packaging data declarations, and pay the relevant fees.

Corporate Compliance Recommendations

With fewer than 20 days remaining until the regulation takes effect, export enterprises in sectors such as cross-border e-commerce, fast-moving consumer goods, food-contact materials, and medical devices must take immediate action:

1. Hazardous substances screening: Verify whether the inventory packaging complies with the new regulatory limits to prevent customs clearance delays;

2. Supply chain reverse investigation: Require upstream packaging material suppliers to provide test reports and compliance declarations that comply with PPWR standards;

3. EPR Multi-National Registration: Complete EPR registration in each target member state based on the consumer's location; once the registration numbers are obtained, upload them to the platform for verification.

GRGTEST-related service capabilities

Compliance of packaging materials containing hazardous substances in contact with food

1. General packaging chemical safety: core indicators including four heavy metal tests for PPWR, PFAS (total fluorine/individual compounds), GB 43352 (strict standards for express delivery packaging), o-phthalaldehyde, formaldehyde, solvent residues, and PAHs (particularly in rubber/recycled materials/carbon black inks);

2. Food contact standards: GB 4806, GB 31604, EU 10/2011, FDA 21 CFR, LFGB, DGCCRF, Italian Legislative Decree No.1973, etc., applicable to materials including plastics/paper and cardboard/metal/rubber/coatings/silicone/enameled materials/ceramics/glass/adhesives/inks, etc.;

3. Restricted substances: bisphenols, PFAS, SVHCs, REACH XVII, testing items under Appendix I of the POPs Regulation, French MOAH/MOSH, and U.S. TSCA/TPCH-keeping abreast of the latest regulatory developments.

Packaging Physical Properties

Material property tests, including oxygen transmission rate (OTR), water vapor transmission rate (WVTR), thickness, and tensile strength.

Regulatory Interpretation and Compliance Consulting

Provide dynamic updates on EU regulations concerning PPWR and food contact materials, along with compliance strategy support.