Are You Ready for the EU PPWR? Key Compliance FAQs

With less than two weeks to go, the EU’s new Packaging and Packaging Waste Regulation (PPWR) becomes fully mandatory on August 12, 2026. Recently, we've seen a surge in inquiries from exporters across the chemical, machinery, personal care, and consumer goods sectors. Many businesses are struggling to navigate critical requirements—such as regulated packaging scopes, testing standards, Declarations of Conformity (DoC), EPR registration, and supply-chain liability. To help clients quickly assess its readiness and ensure compliance, we’ve put together this essential enterprise FAQ guide.

I. Regulatory Basics

Q1: What is PPWR? When is it implemented, and which old regulation does it replace?

On January 22, 2025, the EU Official Journal officially published the Packaging and Packaging Waste Regulation (Regulation 2025/40, PPWR), fully replacing the Packaging and Packaging Waste Directive (94/62/EC, PPWD) that had been in force for nearly 30 years. PPWR will be fully implemented from August 12, 2026, reshaping the rules for full life-cycle management of packaging in the EU.

Q2: What are the core changes in upgrading from the old PPWD Directive to a Regulation?

Expanded scope: full coverage of all packaging produced within the EU and imported from outside the EU;

Stronger binding force: a Regulation takes effect directly, leaving no room for autonomous adjustment by individual Member States;

Sharply increased penalties: violations may incur fines of 2%-6% of a company's annual turnover, and serious violations result in a direct ban from entering the EU market;

New full set of mandatory requirements on recyclability, EPR (Extended Producer Responsibility), and the DoC (Declaration of Conformity).

Q3: What packaging does PPWR control? Do shipping containers count?

Except for the shipping container body itself, all packaging used to contain, protect, transport, or display products is controlled, divided into 4 major categories:

• Primary packaging (IBC intermediate bulk containers/tank drums, FIBC flexible bulk bags, plastic/iron drums, raw-material inner bags and other packaging in direct contact with the product);
• Secondary / combined packaging (outer cartons for small drums, inner color boxes for products, etc.);
• Transport packaging (wooden/plastic pallets, stretch film, strapping, kraft paper, locking clips);
• Service packaging (cling film wrapping food, disposable plates holding food).

Q4: Are stretch film, pallets, and strapping exempt?

In June 2026 the EU added an exemption list: pallets, strapping, and stretch film are exempt from the reusability target requirements, but they must still meet the four heavy-metal content requirements, issue a recyclability declaration, and provide packaging technical documentation and a DoC. They cannot be fully exempted from compliance obligations.

Q5: What exemptions apply to packaging in direct contact with hazardous chemicals (IBC drums, iron drums)?

Only Article 6 (recyclability performance grading) and Article 11 (reusability quantitative targets — the 2030/2040 recycling-rate indicators) are exempt;

Heavy-metal testing, the DoC, technical documentation, and EPR registration obligations are NOT exempt — full compliance is still required.

II. Testing Requirements & Sample Submission Practices

Q1: What tests does PPWR require?

ALL packaging must comply: four heavy metals (lead, cadmium, mercury, hexavalent chromium), total content <= 100 ppm;

Only food-contact packaging additionally requires PFAS content limits;

Companies may voluntarily add REACH SVHC, restricted substances, bisphenol A, etc., to meet additional importer requirements or as part of the packaging technical documentation.

Q3: For the same packaging with multiple sizes and multiple printed patterns, if the raw materials are identical, can testing be combined?

If the substrate material and production process are completely identical and only the size differs: one combined test can be done; if the substrate is the same but the printing color/ink differs, different colors must be tested separately.

Q4: For thousands of color cards with identical raw materials but different printed patterns, does each need to be tested?

Core principle: different inks / color masterbatches must be tested separately; if only the paper substrate is the same and the ink is unified, testing can be combined; if the ink formulation differs, they must be separated.

Q5: Does sample submission require sending the complete package? What are the sample specifications?

No need to send the entire package — cutting a sample slice of >= 50 g is sufficient, which reduces warehousing and transport costs; coatings, inks, tapes, and other accessories are sampled and submitted separately.

Q6: How long is a PPWR test report valid?

The report itself carries no validity period; it only reflects the date of testing. Nevertheless, to ensure ongoing compliance monitoring, most buyers generally request annual testing. Kindly note that any modifications to the packaging—including changes to packaging materials, inks, or suppliers—will necessitate re-testing following such changes.

III. Compliance Documents (Technical Documentation + Declaration of Conformity)

Q1: What is a DoC? What are the legal responsibilities?

DoC — full name Declaration of Conformity, i.e., the packaging declaration of conformity — is a statutory self-declaration document issued by the enterprise, proving that the packaging complies with PPWR Articles 5-12 (at present, mainly comply with Article 5 first, then Articles 6 and 11). The manufacturer of the packaging or of the product bearing the packaging is the responsible party for issuing the DoC; non-compliant packaging will bear fines and the risk of cargo detention.

According to Article 39(4) of the Regulation, the product manufacturer is the first responsible party for the DoC.

Q2: What does the Technical Documentation (TD) include?

Technical documentation includes: packaging material list, supplier information, heavy-metal / PFAS test reports, recyclability / reusability self-declarations, packaging model / traceability identifiers, material-structure descriptions, packaging design data, etc.

Q3: For multiple packaging materials — cartons, pallets, stretch film, strapping — how many DoCs and technical documents are needed?

Issued separately by packaging type; different materials / categories each require an independent set of TD + DoC.

Example: corrugated cartons, plastic pallets, PE stretch film, and PP strapping — 4 categories of packaging require 4 independent sets of documents;

Supplement: for the same material with only size differences, if the packaging technical documentation is consistent, they can be merged within one DoC; but if the packaging technical documentation differs, the DoC must also be re-prepared; for the same packaging from different suppliers, separate testing and separate documents are required.

Q4: Do small components like pallet nails and packaging locking clips need a separate DoC?

No separate DoC is required; they are archived together with the main packaging as packaging accessories, but the components must individually comply with specific substance-limit requirements, and if testing is needed, components of different materials must be tested separately.

Q5: Do transparent tape and outer-packaging shipping-mark ink need a separate DoC?

Based on current practical experience, no separate DoC is needed — they are included in the overall outer-packaging technical documentation; but tape and ink must individually comply with specific substance-limit requirements, and if testing is needed, it is conducted separately.

Q6: If the product packaging has no enterprise information printed on it, who issues the DoC? Can the packaging factory's documents be used directly?

If the packaging has no brand / enterprise LOGO: the manufacturer of the product bearing the packaging (filler / brand owner) issues the DoC;

Only the packaging factory's test reports and material data can be borrowed; the DoC issued by the packaging factory has no legal validity and cannot be submitted directly to the EU importer — the DoC must be signed by the manufacturer of the product bearing the packaging (filler / brand owner) itself.

According to actual trade conditions, the nature of each party may change, and the allocation should be made according to the actual situation.

Q7: If the packaging is printed with the customer's (EU importer's) company information, who is the compliance subject and who issues the DoC?

Printing the importer's brand information makes the importer the 'manufacturer' under the PPWR Regulation; the importer is responsible for issuing the DoC and fulfilling compliance obligations.

According to actual trade conditions, the nature of each party may change, and the allocation should be made according to the actual situation.

Q8: In an OEM/ODM model, where we produce the product and the packaging is printed with the customer's LOGO, who makes the DoC?

With the customer's enterprise information printed on the packaging, the customer is the legal manufacturer and completes the full set of compliance; we only need to provide test reports and material technical data.

Q9: Must the packaging supplier information be filled in on the DoC?

The Regulation does not mandate it, but to achieve full-chain traceability of packaging, industry practice recommends filling in the supplier name and material source to facilitate tracing and rectification when problems arise.

Q10: What is the unique traceability identifier for packaging? Who sets it? Does it need to be printed on the packaging?

Batch number, model, and serial number can all serve as unique traceability identifiers, defined by the packaging manufacturer (brand exporter) itself; when it cannot be printed on the packaging surface, it may accompany the goods in the technical documentation or packing list.

IV. Recyclability & Reusability Clauses

Q1: From August 12, 2026, what testing / grading is required for recyclable packaging?

From 2026 to 2029, companies only need to issue a recyclability self-declaration — no third-party grading or testing is required; the grading standard will only become mandatory in 2030.

Q2: What are the timeline requirements for recyclability performance grading?

2030-01-01: packaging must reach Grade C (recycling rate >= 70%) to enter the EU;

2038-01-01: threshold raised to Grade B (recycling rate >= 80%);

Grade A: recycling rate >= 95%, a high-standard grade; the EU has not yet issued a unified calculation standard.

Q3: How is recyclability determined for inner drums of chemical raw materials / dangerous goods?

Packaging used for transporting dangerous goods is exempt from the recyclability requirements and the 2030/2038 recyclability grading indicators.

Q4: Are paper-plastic composite bags considered recyclable packaging?

Before 2030, all packaging is by default recyclable — a self-declaration is sufficient; after 2030, the recyclability of composite materials is re-evaluated according to the official grading standard.

Q5: Requirements for reusable packaging (tank drums, FIBC bulk bags)?

2030: reuse-rate target for transport reusable packaging is 40%;

2040: reuse-rate target is 70%;

Exemptions: packaging for hazardous-goods transport and corrugated cartons do not need to meet the reusability quantitative targets.

V. EPR (Extended Producer Responsibility) Registration

Q1: What is EPR? Who must do EPR registration?

EPR (Extended Producer Responsibility) follows the 'polluter pays' principle — the cost of packaging-waste treatment is borne by the enterprise that places packaging on the EU market. The first enterprise to introduce packaging or packaged products into an EU Member State is the 'Producer' as defined by the PPWR Regulation; the Producer must complete EPR registration in the EU Member State where it sells.

Q2: Is EPR a unified EU registration, or separate registration per country?

There is no EU-wide universal registration number — each EU Member State requires separate registration; Germany, France, Italy, etc. each have independent registration systems, websites, and producer-responsibility organizations (PROs).

Q3: If exporting to multiple EU countries, must all be registered for EPR?

Yes — whichever Member State the goods are sold to, EPR registration and the annual packaging-weight declaration must be completed in that country.

Q4: Can a European agent / importer act as the EPR authorized representative?

Yes.

Q5: How long is the EPR registration cycle? Is there still time to apply now?

Cycles vary greatly by country: Germany is the fastest at about 1 week; some countries have review cycles of 4-5 months; with the regulation about to take effect, registration applications have surged and cycles keep lengthening — it is recommended to start immediately.

Q6: Is EPR an obligation of the exporter or of the EU importer?

Based on the current interpretation and experience, the legal responsible party under the Regulation is the party that first places packaging on a given EU Member State. For B2B business of Chinese companies exporting to the EU, it is generally considered that the party responsible for customs clearance in the EU is responsible for EPR registration. For B2C or e-commerce-platform trade, it is generally considered that the Chinese company is the one first bringing the packaging into the EU Member State — in this case the Chinese company is responsible for EPR registration.

Q7: For a non-EU company, what are the steps for EPR registration?

Appoint an EPR authorized representative within an EU Member State;

The EPR authorized representative submits the company registration on the target Member State's official website;

Declare the packaging materials and weight data exported in the previous year before June 1 each year;

Cooperate with the EU authorities' data review and pay the fees.

VI. Supply-Chain Responsibility Allocation

Q1: What are the three major responsible parties under PPWR? What are their respective obligations?

Packaging / packaged-product Manufacturer (Manufacturer — collects packaging material data, issues the DoC):

• Ensure packaging complies with PPWR substance limits during the production stage;
• Collect and retain complete test reports, material drawings, and technical data;
• Transmit the DoC downstream.

EU Importer / Distributor (Importer / distributor — reviews the DoC):

• Verify that incoming packaging is accompanied by compliant TD and DoC documents;
• Urge upstream export companies to complete any missing documentation;
• Prohibit the sale of products without a DoC.

Producer (i.e., the party that first brings packaging into an EU Member State):

• Complete EPR registration;
• Make the annual declaration of packaging material and weight information;
• Pay the packaging-treatment fees.

Q2: Can electrical / chemical manufacturers request test reports from packaging suppliers?

Yes — and it is recommended to uniformly require suppliers to provide full material and heavy-metal test reports; the enterprise integrates the data and issues the DoC itself.

Q3: If an enterprise is both a packaging manufacturer and a brand-filling company, how should it comply?

It is recommended to manage it in two segments: the packaging-production stage provides material test data; the finished-product filling stage issues the DoC in the capacity of the brand owner; the two sets of data are archived separately.

VII. Cost, Timeline & Implementation

Q1: What is the price range for a full PPWR compliance service (testing + TD + DoC)?

Multiple categories can be bundled at a discount; the final quote is calculated precisely based on packaging material and quantity. Welcome to contact our staff for a quotation — see the contact details at the end of this article.

Q2: With only two weeks left before the August 12 mandatory implementation, is it still possible to start now?

Entrusting a third-party body can be expedited, but testing has a fixed laboratory cycle — the later the entrustment, the more likely delays become; it is recommended to send samples for testing immediately and prepare technical documents in parallel, to avoid goods being detained at port for non-compliance upon arrival.

Q3: What are the 5 core tasks included in a full PPWR compliance package?

• Four-heavy-metal testing of packaging; additional PFAS testing for food-contact packaging;
• Issue recyclability and reusability self-declarations;
• Compile the full set of packaging technical documentation (TD);
• Sign and issue the DoC (Declaration of Conformity);
• Arrange per-country EPR registration as needed.

Q4: If the importer does not proactively request PPWR compliance documents, must the enterprise still proactively prepare them?

Compliance must be completed proactively. EU importers can request a DoC at any time and may terminate trade in products without a DoC; the absence of compliance documents will lead to cargo detention and heavy fines, with all risks borne by the export enterprise.

VIII. Penalties & Regulatory Inspections

Q1: What are the penalties for PPWR non-compliance?

Fines: 2%-6% of the company's global annual turnover;

Market ban: products with serious violations are permanently banned from the EU market;

Cargo seizure: at port customs clearance, the lack of TD / DoC / test reports may cause port detention;

The enterprise bears the full cost of product recall and rectification.

Q2: How does the EU verify PPWR compliance documentation — customs spot-checks or self-checks?

Both regulatory approaches run in parallel:

• Random spot-checks at customs clearance, requiring on-site presentation of TD, DoC, and test reports;
• EU market-surveillance authorities conduct after-the-fact on-site audits of importer files;

There are no large-scale penalty cases yet, but enforcement will continue to tighten after the regulation takes effect.

Q3: How long must compliance documents be retained?

At least 5-10 years; EU authorities can trace past-batch packaging compliance documentation at any time, and the loss of documents is treated as non-compliance.

Recommendations from CIRS

The window before the August 12 mandatory implementation of the PPWR regulation is extremely tight. At this stage, prioritizing the completion of packaging heavy-metal testing, technical documentation, and the DoC is the core measure to ensure normal customs clearance of goods. If your enterprise has special scenarios such as multi-category packaging, multi-country export, hazardous-chemical packaging, or food-contact packaging, or has personalized questions about EPR registration, responsibility allocation, or sample submission, you can add a professional compliance consultant for one-on-one consultation to obtain a customized compliance plan, a full set of template documents, and an accurate quotation.

What CIRS can do for you?

CIRS owns a professional third‑party testing institution, and has built a one‑stop PPWR compliance service matrix to help companies achieve efficient, cost‑effective compliance:

1. Core testing services

2. Declaration of Conformity (DoC) services

• Compliance review: review of product technical documentation, supporting DoC preparation
• DoC drafting: preparation of formal Declaration of Conformity documents

3. EPR registration services

Fee structure based on target Member State – please contact us for details

4. Technical documentation and declaration services

• Technical dossier preparation: compilation of packaging design descriptions
• Reusability declaration: drafting of packaging reusability declaration documents

5. Our advantages:

End‑to‑end service coverage from testing, declaration, registration to technical documentation; in‑depth knowledge of EU regulatory requirements; reports are accepted as technical evidence for DoC – helping you face regulatory scrutiny with confidence.

Get In Touch

CIRS Group

✉️ Email: service@cirs-group.com

🌐 Website: www.cirs-group.com

Further Reading

EU PPWR: What Packaging Businesses Need to Do Now

Mandatory Enforcement in Less Than 2 Months! Is Your Packaging Ready to Pass the "PPWR Checkpoint"?

Under the EU PPWR, Is Medical Device Packaging Truly Exempt?