PPWR – Packing and Packing Waste Regulation
This unified EU packaging regulation imposes mandatory requirements for all goods exported to the EU with packaging. Exporters need to clarify scope applicability, substance restrictions and EPR obligations to mitigate risks of customs detention and market penalties. Enforcement becomes mandatory as of 12 August 2026.
Ⅰ. Scope of Application
Applies to all packaging placed on the EU market, irrespective of materials including plastic, paper, glass, metal and wood.
Regulation covers packaging sold empty, packaging containing products, and packaging used for e-commerce delivery parcels.
II. Hazardous Substance Restrictions
① Heavy Metals (Lead, Cadmium, Mercury, Hexavalent Chromium)
Scope: All packaging and packaging components placed on the EU market.
Limit: The combined concentration of the four heavy metals shall not exceed 100 mg/kg (i.e. 100 ppm).
② PFAS (Per- and Polyfluoroalkyl Substances)
Scope: Food-contact packaging only.
Limits:
• Any individual non-polymeric PFAS ≤ 25 ppb
• Sum of all non-polymeric PFAS ≤ 250 ppb
• Total fluorine content including polymeric PFAS ≤ 50 ppm
Note: Compliance with substance concentration limits constitutes a fundamental market access requirement. It is separate from EPR registration, and the two cannot substitute for one another.
III. Extended Producer Responsibility (EPR)
EPR is the core compliance duty under PPWR, consisting of three sequential steps: registration, reporting and payment.
① Registration When launching products into any EU Member State for the first time, register with local authorities or authorised PROs to receive a dedicated national EPR number. EPR registrations are country-specific; one registration is not valid across all EU nations.
② Reporting File packaging data declarations on a regular basis (generally annually) for each market, covering material, weight and volume.
③ Payment Pay the applicable eco-contribution according to submitted data. These funds finance local packaging waste collection, sorting and recycling schemes.
IV. Practical Business Guidance
Testing is billed per material point, with a market reference rate of around RMB 200 per material point. Multiple models sharing the same material can be included in one report to cut repeated testing expenses. Standard lead time: 7–10 working days.
Important note: EPR registration alone cannot fulfil all PPWR obligations. In addition to EPR, packaging must comply with substance restrictions, hold a Declaration of Conformity (DoC), maintain technical files, and meet marking & traceability requirements. A full compliance dossier is mandatory.