From August 12, Non-Compliant Packaging Exported to the EU May Be Held at Customs!

From 12 August 2026, all packaging placed on the EU market (whatever the material) must come with a full set of "test report + technical documentation + EU Declaration of Conformity (DoC)". Without these files, your goods can be detained, returned, or even destroyed at EU customs.

This isn't scare-mongering — it's a hard requirement directly stated by the EU's new packaging regulation PPWR, with no transition period.

As an exporter, the question you should be asking right now is: "What documents does my packaging actually need?" This article answers it all in one go.

1. What is PPWR? Why the urgency?

PPWR = EU Packaging and Packaging Waste Regulation, regulation number Regulation (EU) 2025/40.

• Replaces the old Packaging Directive 94/62/EC
• In force since 11 February 2025
• Fully applicable from 12 August 2026 (the 18-month transition period has ended)

Key point: it's a "Regulation", not a "Directive". That means it applies uniformly and directly across all 27 EU member states — countries can't each interpret it their own way or dilute it. For you that means: one standard, one preparation, all 27 countries covered.

Even more importantly: it has shifted from "voluntary cooperation" to "mandatory compliance". In the past the EU relied more on each country's environmental obligations for packaging. Now national market surveillance authorities can spot-check any time, seize goods, require corrections, and they sample-check the authenticity of a portion of DoCs every year.

2. First, be clear: who needs to prepare these documents?

The most commonly misunderstood point: it governs "packaging", not "the product itself".

The criterion (Article 3) is simple: is this object used to "contain, protect, handle, or present" a product?

Another thing people mix up: who is the "manufacturer"?

Per the regulation, "manufacturer" = the entity whose name/brand is printed on the packaging. So:

• If your brand is printed on the packaging → you are the manufacturer, you issue the documents and you bear the responsibility
• If you're doing OEM for someone else and their brand is printed → they are the manufacturer, but they'll usually turn around and ask you for the technical data and test reports

So in most cases, Chinese exporters are the "packaging design/production side" and need to hand the technical documentation, test reports, and DoC to your EU customer (importer/brand owner) for them to sign. That's exactly why many European customers have been pushing their Chinese suppliers for these documents lately.

3. Which 3 documents exactly?

Core = "1 test + 2 documents", none of which can be omitted.

① Test report (prerequisite — must be done first)

Testing is done on the finished packaging, focusing on four heavy metals and PFAS (where applicable):

• Heavy metals (Article 5(4)): lead Pb + cadmium Cd + mercury Hg + hexavalent chromium Cr(VI) total ≤ 100 mg/kg
• PFAS (Article 5(5), applicable to food-contact packaging): single PFAS ≤ 25 ppb, total PFAS ≤ 250 ppb, polymer-containing ≤ 50 ppm

The report must come from an ISO/IEC 17025 accredited laboratory and must cite the correct regulation number: Regulation (EU) 2025/40. This is the foundation the DoC rests on.

② Technical documentation (corresponding to Annex VII)

This is the whole evidence package supporting the DoC. Core content:

• (a) General description of the packaging + intended use
• (b) Conceptual design, manufacturing drawings, and the material and grammage of all components/parts
• (c) Explanations needed to understand the drawings (layer structures, functions)
• (d) List of harmonized standards / common specifications / other technical specifications used
• (e) Qualitative statements on the recyclability, minimization, reusability, etc. assessments
• (f) Test reports (heavy metals, PFAS, etc.)

③ EU Declaration of Conformity (corresponding to Annex VIII)

This is the "one-page legal conclusion" and must strictly follow the structure set out in Annex VIII (8 elements):

1. Unique identification number (DoC number + packaging unique identifier)
2. Name and address of the manufacturer (and authorised representative, if applicable)
3. Statement that the manufacturer assumes full responsibility
4. The object of the declaration (traceable packaging identification + description)
5. Declaration of conformity: explicitly cite Regulation (EU) 2025/40 and list the applicable Articles 5-12
6. Harmonized standards / technical specifications used
7. Notified body: usually state "N/A (Module A internal production control, no notified body required)"
8. Place and date of issue + name, title and signature of the signatory

4. Pitfalls that sink you the moment you hit them (save this)

1. Wrong regulation number: writing "Regulation (EU) 2024/1935". That's the old directive number; the correct one is 2025/40. Many customers have it wrong in their template — always double-check before submitting.
2. Treating the manual as packaging: manual, warranty card, body sticker are not packaging; don't put them in the materials table, and don't send them for heavy-metal testing — mixing them in only inflates the total and causes a wrong classification.
3. One DoC for everything: each packaging type needs its own set of documents; you can't use "one DoC for the whole company". Different box styles or materials = different objects.
4. Substituting with another certificate: ISO 9001 or a food-contact declaration can't replace the PPWR DoC. The DoC must explicitly cite Regulation (EU) 2025/40.
5. Over-claiming "conformity to the whole regulation": over-declaring is actually dangerous. Only declare the provisions currently in force that actually apply (in 2026 mainly Article 5 substances, Article 10 minimization, Article 11 reusability where applicable). Recyclability and recycled-content are 2030 — don't claim those yet.
6. Missing language versions: the DoC should be in the importing country's language (or translatable). If you sell in multiple EU countries, prepare the corresponding language versions.

5. Timeline: what to do when?

In one line: the 2026 wave is "survival" (get compliant, get through customs); the 2030 wave is "upgrade" (reduce, recycle, be truly recyclable).

6. Your 5-step checklist right now

1. Inventory: for the products you export to the EU, what packaging do you have (outer box, color box, inner tray)? Treat each one as a "packaging type".
2. Classify: which count as packaging and which don't (manual/body label excluded).
3. Send for testing: do heavy-metal testing on finished packaging (≤100 mg/kg), add PFAS for food-contact; the lab must be 17025 accredited and the report must cite 2025/40.
4. Assemble the file: build the technical documentation per Annex VII (drawings, materials table, grammage, standards/specifications, assessment statements, test report).
5. Issue the DoC: draft per Annex VIII's 8 elements → give to the EU customer/importer to sign → archive (single-use packaging 5 years, reusable packaging 10 years).

Final thoughts

PPWR this time isn't "take it slow" — it's all-or-nothing on 2026-08-12. What you really need isn't "whether you understand the rules" but "whether your paperwork is complete and able to clear customs".

As an export certification consultancy, this is the one thing we do every day: help exporters get their EU/US/other-market compliance documents right and complete so goods clear customs smoothly.