You are here: Home » News » Industry News » Interpretation of PPWR EU packaging and packaging waste regulations (1) Scope of application, core definitions and compliance time requirements

Interpretation of PPWR EU packaging and packaging waste regulations (1) Scope of application, core definitions and compliance time requirements

Views: 0     Author: Site Editor     Publish Time: 2026-08-21      Origin: Site


Preface

The EU's Packaging and Packaging Waste Regulation ( PPWR ) will be officially enforced from August 12, 2026 , and will replace the Packaging and Packaging Waste Directive (PPWD). Regulatory requirements cover many aspects such as packaging design, material safety, recyclability, recycled plastic content, packaging minimization, unified labeling, reuse targets, declaration of conformity and extended producer responsibility (EPR). For packaging companies, brands, manufacturing companies, cross-border e-commerce and foreign trade companies exporting to the EU, PPWR not only affects the packaging itself, but also affects product listing, customer review, platform operations, customs clearance and delivery, and member states' EPR compliance.

This article will sort out the scope of application, core definitions, main compliance requirements, procedural obligations and response paths of export companies around PPWR, providing a reference for relevant companies to understand regulatory requirements, identify compliance risks and formulate phased response plans.


1


1. Which companies and products need to comply with PPWR?

(1) Scope and coverage of PPWR

PPWR covers the entire chain of management and control from packaging design, production, circulation, use to waste. All packaging materials must meet the relevant requirements of PPWR, including plastic, paper, metal, glass and composite materials.

Regulations apply to packaging and packaging waste in all use scenarios, including industrial packaging, commercial packaging, consumer product packaging and logistics packaging. Only a few specific categories are exempt from some provisions, such as dangerous goods transport packaging and specific medical contact packaging.

(2) Scope of responsible entities

From the perspective of responsible entities, all companies that place packaged or pre-packaged products on the EU market are subject to restrictions. Coverage includes packaging manufacturers, manufacturers, EU domestic manufacturers, importers, distributors, offline retailers and cross-border e-commerce sellers.

This regulation does not impose restrictions on the location of enterprises. Whether enterprises are located within the EU or outside the EU, they must fulfill corresponding compliance obligations.

Quick judgment on suitability

Self-check questions If the answer is 'yes', it is recommended to pay attention
Does the product or packaging enter the EU market? PPWR basic suitability
Is it food contact packaging? PFAS, food contact materials (FCM), heavy metal requirements
Does the packaging contain plastic parts? Recycled plastic content, recyclability
Does it involve e-commerce packaging, transportation packaging or combination packaging? Void ratio, reuse goals
Is it sold through the platform or member states? EPR registration and declaration


2. What are the packaging, manufacturers and producers defined by PPWR?

(1) Packaging

Packaging is defined in the PPWR as: an article made of any material used by an operator to contain, protect, handle, distribute or display product for use by other operators or end users. The regulations also divide packaging into different categories, as shown in the table.


category illustrate Example
Necessities during the product life cycle Accompany the product throughout its life, but is not an integral part of the product. It is used together with the product, consumed and disposed of. Soy sauce bottles, toothpaste tubes, cosmetic bottles, plastic protective shells for toys
Integrated accessories Hang or stick directly on the product to serve as packaging Soy sauce bottle caps, toothpaste tube caps, perfume pump heads
Hanging or pasted appendages Components integrated into the body of the packaging Labels on clothes, price tags hung on products, sticker labels directly attached to fruits/vegetables
Service packaging Fill items to hold products at the point of sale Paper bags from delis, takeaway cups from cafes
Disposable point-of-sale items Sold at the point of sale and filled or intended to be filled at the point of sale Disposable tableware, takeout boxes
Tea/coffee bags and capsules A unit that is used and discarded together with its contents, whether permeable (e.g. tea bags) or impermeable (e.g. coffee capsules) Tea bags, coffee capsules, soft drinks single serving units


(2) Manufacturer

Manufacturer is a natural or legal person who produces packaging or packaged products. They are often the owners of the product brand and the manufacturer is responsible for the sustainability and labeling of the packaging.

(3) Manufacturer

Manufacturers or importers or distributors who place packages or packaged products on the market for the first time in a Member State are responsible for fulfilling the Member State's extended producer responsibility. There is always only one manufacturer in the supply chain, but there can be multiple producers, who may also be manufacturers, importers or distributors.


3. Critical Time for Compliance

Time node overview:


  • 2026 - Basic Compliance
  • 2028 - Labeling/Composting
  • 2030 - Indicator Upgrade
  • 2038 - Level Upgrade


Implementation date Corresponding regulatory provisions Compliance requirements content
2026.8.12 Article5

Hazardous Substance Restrictions:

1. The total content of the four heavy metals lead, cadmium, mercury and hexavalent chromium is ≤100mg/kg;

2. The PFAS limit for food contact materials officially takes effect.


Article6 All packaging placed on the EU market must be recyclable

Article39 Manufacturers need to prepare DOC and related technical documents that meet the requirements

Article45 Producers need to fulfill EPR responsibilities
2028.2.12 Article9 Tea and coffee filter bags, and self-adhesive labels for fruits and vegetables must be compostable packaging
2028.8.12 Article12 Packages must adhere to uniform labeling and marking requirements
2030.1.1 Article6 All packaging placed on the EU market must meet Grade C

Article7 Plastic packaging meets recycled plastic content requirements

Article10 Packaging weight and volume are reduced to the minimum necessary level while meeting basic functions.

Article24 The void ratio in combination packaging, transportation packaging and e-commerce packaging must not exceed 50%

Article11 Transport packaging, combination packaging and beverage sales packaging achieve packaging reuse rate
2038.1.1 Article6 All packaging placed on the EU market must reach Grade B


IQTC technical service support

The implementation of PPWR means that EU packaging compliance has entered a new stage that is more unified, mandatory and systematic. For packaging companies exporting to the EU, completing packaging sorting, EPR registration, testing and evaluation, document preparation and design optimization in advance has become a necessary action to defend the EU market. The earlier compliance preparations are made, the greater the initiative a company will have in customer review, platform operations, customs clearance delivery, and market competition.

IQTC (Guangzhou Customs Technology Center) focuses on PPWR Articles 5-12 and EPR compliance requirements to provide export companies with one-stop technical services covering material testing, compliance assessment, packaging optimization, document support and supply chain management, assisting companies to meet the compliance requirements of EU packaging regulations at all stages.



service module Service content Technical output
Hazardous substance detection Screening for high-risk substances such as heavy metals and PFAS in packaging materials Heavy metal detection report, PFAS/total fluorine screening report
Food Contact Materials Compliance Assessment Conducting regulatory compliance assessments for food contact packaging FCM test report and regulatory compliance assessment report
Packaging recyclability assessment Evaluate packaging structure, material combination and recycling performance, and identify design risks Recyclability assessment report, packaging optimization suggestions
Compostable packaging testing and certification Industrial composting performance verification for applicable packaging Compostability performance test report and certification support
Regeneration content verification Conduct PCR content verification and improve recycled material supply chain data PCR content verification report, supply chain document arrangement
Packaging label audit Track EU harmonized labeling requirements and assess label compliance Label review opinions and regulatory requirements updates
EPR and compliance document support Support enterprises to complete EPR contract performance and technical document management EPR registration application support, DoC and technical file arrangement


Contributed by: National Key Laboratory for Testing of Food Contact Materials (Guangdong), Technical Trade Measures Guangdong-Hong Kong-Macao Greater Bay Area Research Platform. The content is for reference only. If there is any adjustment, please refer to the latest requirements.


Source: Guanwu Xiaoer | If there is any infringement, please contact us to delete it