New EU PPWR Packaging Regulations
On August 12, 2026, the EU's new Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) will officially come into full force, directly repealing the long-standing former Packaging Directive 94/62/EC. From then on, unified new packaging compliance standards will be strictly enforced across all 27 EU member states. All product packaging entering the EU market must be fully compliant, with no grace periods or exceptions.
Requirements are being tightened across the entire supply chain, covering material toxicity restrictions, recycling grades, recycled content ratios, labeling and printing, and the prevention of excessive packaging. Non-compliant products will be denied entry, and violators will face substantial fines and full-scale product recalls.
01 Which products are regulated by PPWR?
Comprehensive coverage with no blind spots! The regulation applies to all packaging and packaging waste, regardless of material or scenario, and across all industries and categories:
1. Sales Packaging:
Packaging that directly wraps a single item, such as food bags, colorful mobile phone boxes, and toy packaging boxes.
2. Grouped Packaging:
Packaging that bundles multiple items together, such as shrink wrap for six-pack milk cartons and paper boxes for snack combinations.
3. Transport Packaging:
E-commerce express boxes, cushioning air bubble bags, and logistics outer boxes (excluding sea freight and air freight containers).
02 Key Compliance Requirements & Critical Deadlines
Contact our logistics expert to learn about shipping from China to Europe:
03 Deep Dive into Key Clauses
Article 5: Red Lines for Harmful Substances
1.General limits for heavy metals:The total amount of lead, cadmium, mercury, and hexavalent chromium in all packaging must be 100mg/kg (0.01%) or less.
2.Strict control of PFAS in food packaging:
1） Any single non-polymer PFAS must be less than 25ppb.
2） The total of all non-polymer PFAS must be less than 250ppb.
3） The total amount of polymer PFAS must be less than 50ppm. If the total fluorine is over 50mg/kg, a fluorine content test report is required.
3.Substances of Concern (SoC): There is no official list yet. For now, you can use the EN 13428:2004 standard to assess risks.
Article 6: Packaging Recyclability Grades (Rules get stricter over time)
From 2026, all new packaging must be recyclable. Recyclability is graded A, B, or C:
1) Jan 1, 2030: Only packaging graded C or higher can be sold.
2) Jan 1, 2038: Only packaging graded A or B can be sold in the EU.
Exempted items (to be reviewed before 2035):
Packaging for medicines, sensitive medical packaging, special food packaging for babies, packaging for dangerous goods, and retail packaging made of light wood, cork, textiles, ceramics, or wax.
Article 7: Mandatory Recycled Plastic Targets (Effective 2030)
Different plastic packaging must include a set percentage of recycled material. Products that do not meet these targets cannot be sold:
Exemptions for Recycled Materials:
Medicines, medical devices, compostable plastics, dangerous goods packaging, special baby food packaging, packaging where recycled material would affect food safety, and plastic parts that weigh less than 5%.
Preventing Over-Packaging: Void Space ≤ 50% (Mandatory from 2030):
For e-commerce boxes, gift sets, and shipping cartons, the empty space (including paper or foam fillers) cannot exceed 50%. This strictly targets over-packaging and oversized gift boxes. Packaging must also be lightweight, reducing weight and volume to the minimum needed to protect the product.
EPR (Extended Producer Responsibility) - Critical for Exporters:
1) All packaging sold in the EU must be registered for EPR in the country of sale. Cross-border sellers must appoint an EU Authorized Representative to handle this.
2) Starting February 2027, packaging must display a dedicated EPR compliance label to prove that recycling fees have been paid.
Major Update to Labeling System (Rolling out in 2028–2029):
1) Aug 2028: Unified pictograms for materials, recycled content labels, and sorting instructions. QR codes can be added to show disassembly and recycling info.
2) Feb 2029: A special label for reusable packaging to help consumers easily identify products meant for reuse.
04 Mandatory Obligations for Manufacturers & Importers (Both are required)
1. Manufacturer (Article 15)
1) Only packaging products that meet all standards can be sold.
2) Before shipping, complete the compliance check. You must issue a Declaration of Conformity (DoC) and a full set of technical documents.
3) Keep documents for 5 years for single-use packaging, and 10 years for reusable packaging.
4) Print the model/batch code, manufacturer name, address, and contact info on the packaging. If printing is not possible, attach a paper document with this information.
2. EU Importer (Article 18)
The importer is the first person responsible for compliance. The outer packaging must clearly show the company name, EU physical address, and email. If printing is not possible, a QR code or supporting documents can be used to show this information.
05 How Serious are the Consequences of Non-Compliance?
Under the new rules, enforcement will be much stricter. Penalties for violations include:
1) Customs detention of products.
2) Full batch recall and removal from the market.
3) High administrative fines (each EU member state sets its own high penalty standards).
4) Temporary or permanent bans on a company's products entering the EU market.
5) Damage to brand reputation, which will affect channel partnerships across the entire EU.
06 Action Plan for Businesses
1) Test Materials First: Test for heavy metals and PFAS early. Remove any materials that exceed the limits.
2) Redesign Packaging: Make packaging smaller and reduce empty space. Plan for a higher ratio of reusable packaging.
3) Upgrade Labels: Design the new compliant labels early. Leave space for printing to avoid changing all packaging after 2028.
4) Complete EU EPR Registration: Work with an EU Authorized Representative early. Finish the registration in each member state and plan ahead for the label printing time.
5) Archive Documents: Collect all test reports, DoC declarations, formula details, and recycling proofs. Keep these files for 5 to 10 years as required.
For any questions regarding freight services from China to Europe, please contact our logistics expert, Icey.
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Post time: Aug-17-2026
