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Implementation of EU Packaging Regulation (PPWR)

Peter Wong

Technical Director of DQS AP and DQS HK. IATF certified Automotive Auditor and PECB certified ISMS Auditor.
Jul 31 , 2026

The EU Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 will be implemented from August 12, 2026. Concurrently, the Packaging Directive 94/62/EC (PPWD), which has been in place for nearly 30 years, will be replaced.

For the vast number of manufacturers deeply involved in the EU market, packaging is no longer a secondary accessory - it has become a strict market access threshold determining whether the goods can clear customs smoothly and stay on the shelves. Non-compliance could result in customs detentions, product recalls, removals from e-commerce platforms, and severe fines of up to 6% of a company’s global annual turnover.

Fundamental Changes

Compared to the former PPWD, the PPWR is by no means a simple standard upgrade, but represents a complete restructuring of the regulatory framework:

  • Legal Hierarchy Upgrade
  1. Old PPWD: A Directive, meaning individual EU Member States transposed it into their own national laws.
  2. PPWR: An EU Regulation, directly applicable and uniformly enforced across all Member States.
  • Comprehensive Coverage
  1. All packaging entering the EU alongside goods falls under its scope:
  2. Primary sales packaging
  3. Secondary grouped packaging
  4. Transport/logistics master cartons
  5. Cushioning foam, adhesive tapes, labels, printed films, etc. (no exceptions)
  6. Applies universally to industrial goods, consumer products, and cross-border e-commerce shipments.

Note: The UK (Great Britain) enforces its own independent packaging regulations and is not subject to the PPWR. However, Northern Ireland will follow PPWR requirements.

 

Core Requirements

  • Restrictions on Hazardous Substances
  1. All Packaging Categories: The total content of four heavy metals—Lead (Pb), Cadmium (Cd), Mercury (Hg), and Hexavalent Chromium (Cr VI)—must be ≤ 100 mg/kg. High-risk items include printing inks, glues, surface coatings, etc.
  2. Food Contact Packaging: Introduces new restrictions on PFAS: individual PFAS substances must be < 25 ppb, alongside clear limits on total PFAS content, signaling tighter long-term chemical controls.
  • Recyclability Requirements
  1. Packaging placed on the EU market must possess practical recyclability in reality, not just theoretical material recyclability.
  2. Packaging will eventually be categorized into A/B/C/D recyclability tiers starting in 2030 and 2038. Hard-to-disassemble multilayer composite packaging will face progressive restrictions.
  • Mandatory Documentation & Liability Mechanisms
  1. The manufacturer must establish a complete Technical File and issue a PPWR Declaration of Conformity (DoC), maintaining long-term records of test reports and structural design files.
  2. Must comply with the EU’s Extended Producer Responsibility (EPR) schemes.
  3. Importers and manufacturers share joint liability; market surveillance authorities may conduct random inspections at any time.
  • Long-Term Sustainability Goals (Early Preparation to Avoid Future Risks)
  1. Measures such as packaging volume reduction (limits on over-packaging and empty space ratio), mandatory post-consumer recycled (PCR) plastic content, unified EU packaging labeling, and reusable packaging quotas will be rolled out in phases.
  2. Control mechanisms must be established from the source—starting at product R&D, structural design, and supply chain procurement.

 

Actions to address PPWR

  • Current Status Audit:

Review all packaging materials shipped to the EU (cartons, plastic bags, cushioning materials, labels, inks). Categorize them as standard vs. food-contact packaging, and identify high-risk areas for PFAS and heavy metals.

  • Material Verification:

Require suppliers to provide testing reports, when suitable.

When necessary, engage qualified third-party laboratories to perform hazardous substance testing and simultaneously evaluate the structural recyclability of packaging design.

  • System Integration:

Leverage existing ISO 9001 (Quality) or ISO 14001 (Environmental) management systems, while integrating IECQ QC 080000 (Hazardous Substance Process Management) to embed PPWR requirements directly into corporate operations.

  • Documentation Preparation:

Compile test reports and material specifications, draft the PPWR Declaration of Conformity (DoC), and build a comprehensive technical archive.

  • Long-Term Planning:

Optimize packaging design early: phase out high-risk composite materials and plan for recyclable packaging solutions to withstand the stricter tiered controls taking effect after 2030.

 

DQS Related Services

As a global independent certification body with decades of experience serving the manufacturing sector, DQS helps enterprises navigate European green trade barriers with the following services:

Appendix: Frequently Asked Questions (FAQs) on EU PPWR

We are a manufacturer exporting to the EU. Which entities are regulated by the PPWR?

All entities placing packaging on the EU market are bound by the regulation, including manufacturers, exporters, EU importers, and brand owners. As long as a product enters the EU territory wrapped in packaging, it must satisfy all PPWR requirements.

 

When does PPWR officially become mandatory? Can we still rely on the old directive?

PPWR becomes fully mandatory on August 12, 2026, at which point the old Packaging Directive 94/62/EC is officially repealed. Once the transition period ends, regulatory bodies will no longer accept compliance documentation based on the old directive.

 

How to Identify a Manufacturer Under the PPWR?

Supplementary Rules:

  1. Brand Owner Attribution Rule (Unless (b) applies): Where a natural or legal person has packaging or packaged products designed or manufactured under their own name or trademark—and places them on the EU market under that name or trademark—that brand owner is identified as the manufacturer, regardless of whether the contract manufacturer's trademark appears on the packaging.
  2. Micro-Enterprise Exemption Rule: If the brand owner qualifies as a micro-enterprise under EU definitions (fewer than 10 employees, with an annual turnover or balance sheet total not exceeding €2 million) and the packaging supplier is located within the same EU Member State, the packaging supplier is deemed to be the manufacturer. Note: This exemption does not apply to goods imported from outside the EU.

Our packaging is provided entirely by vendors and we only manufacture the product. Are we exempt from responsibility?

No, you still carry joint liability. The EU adheres to a "market-placer responsibility mechanism." If packaging contains excess hazardous substances or fails recyclability requirements, the end-product manufacturer faces risks of customs detention and penalties. You must incorporate PPWR standards into your supplier management framework.

 

What are the most common compliance risks during PPWR enforcement?

The most frequent risk areas include:

  1. Heavy metal levels exceeding limits in packaging materials and printing inks.
  2. Detection of PFAS substances in food-contact packaging.
  3. Multilayer composite packaging being difficult to separate, failing Design for Recycling (DfR) requirements.
  4. Over-packaging and excessive empty space ratios.
  5. Absence of a PPWR Declaration of Conformity (DoC) and complete technical files.
  6. Relying solely on vendor self-declarations without implementing actual hazardous substance process management controls.

 

The regulation requires packaging to be "recyclable." How can a manufacturer prove this?

The regulation assesses design-for-recyclability, not just whether raw materials are theoretically recyclable. Priority should be given to mono-materials while minimizing hard-to-separate composite coatings and adhesives to facilitate sorting and recycling.

 

Can our existing ISO 9001, ISO 14001, or IECQ QC 080000 certificates directly prove PPWR compliance?

Management system certificates alone are not equivalent to a PPWR DoC. However, these three systems complement each other and enable manufacturers to systematically manage compliance risks:

  1. ISO 9001: Manages packaging design changes, procurement, and document control.
  2. ISO 14001: Supports packaging reduction, circular design, and environmental compliance tracking.
  3. IECQ QC 080000: Systematically controls restricted substances like heavy metals and PFAS.

Integrating PPWR requirements into existing management systems is the most cost-effective long-term compliance solution.

 

What is the core connection between IECQ QC 080000 and PPWR?

They are highly aligned. PPWR mandates strict limits on heavy metals in all packaging and PFAS in food packaging; IECQ QC 080000 is a proven process management system tailored specifically for restricted hazardous substances. Implementing QC 080000 systematically controls packaging material risks and provides robust proof to support PPWR technical file requirements.

 

Is EPR registration mandatory for exporting packaging to the EU?

Yes, it is mandatory. Extended Producer Responsibility (EPR) regulations operate independently of PPWR technical clauses. When selling goods in EU Member States, companies must complete packaging EPR registration in each respective target country.

 

Are enforcement rules relaxed for small and medium-sized enterprises (SMEs)? Can we delay preparation?

No, there are no relaxed rules based on company size. As a unified EU Regulation, PPWR applies equally regardless of corporate scale. EU customs, overseas buyers, and e-commerce platforms conduct routine audits; non-compliant SMEs face the same risks of canceled orders, detained goods, and administrative fines.

 

Can DQS provide training courses ?

Beyond PPWR compliance reviews, DQS offers the following public training courses:

  1. PPWR Understanding Training
  2. ISO 9001, ISO 14001, and IECQ QC 080000 Standard Understanding and Internal Auditor Training

 

Author

Peter Wong

Over 20 years' experience in management system certification, operation and compliance management, with strength in quality and information security management.

Peter has qualifications of IATF certified Automotive Auditor, PECB certified ISMS Auditor, PECB  certified Data Protection Officer, ESDA certified ESD Auditor, etc.