🇪🇺 EU · New Regulation Alert

EU PPWR Packaging Regulation Guide

Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation. Compulsory from 12 August 2026, replacing the 94/62/EC packaging directive. All products with packaging exported to the EU must comply.

Regulation at a Glance

Item	Details
Full name	Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation
Short name	PPWR
Entry into force	11 February 2025
Compulsory	12 August 2026 (applied uniformly across the EU)
Replaces	94/62/EC Packaging Directive
Applicable to	All products entering the EU market with packaging
Legal nature	Regulation (not a Directive) — applies directly without national transposition
Penalties	Up to 4%-6% of global annual turnover / product delisting / customs detention

⚠️ Urgent reminder: Less than a month remains until PPWR becomes compulsory. Testing takes 5-7 working days and EPR registration 4-8 weeks per country. We recommend starting the compliance process immediately.

What Does Your Product Need to Do?

PPWR requirements differ by product type. The following refers to non-food general consumer goods (electronics, small appliances, daily-use items, etc.):

Requirement	Needed?	Description
Four heavy metals testing	✅ Required	Pb+Cd+Hg+Cr⁶⁺ ≤ 100 mg/kg
PFAS testing	❌ Not needed	Only food-contact packaging requires it
EU Declaration of Conformity (DoC)	✅ Required	Prepared based on the test reports
Technical documentation	✅ Required	Material list + test reports + supplier declarations
EPR registration	✅ Required	Registered separately per country of sale (Germany/France/Italy, etc.)
Recyclability assessment	⚠️ From 2030	Self-declaration is sufficient for now

Testing Core: Homogeneous Material Separation

PPWR tests by homogeneous material and cannot be mixed. Each material is sampled and reported independently. Here is a typical electronics packaging separation example:

Packaging component	Homogeneous material separation	Test groups
Outer shipping carton (kraft)	Corrugated board substrate + printing ink + packing tape	3
Colour box	Cardboard substrate + colour printing ink + laminate (if any) + glue	3-4
Instruction manual	Paper substrate + printing ink	2
Inner box insert	Paper tray / EPE foam / blister (depending on material)	1-2
Product sticker / label	Label substrate + printing ink + adhesive	3
Plastic bag (PE)	PE substrate + printing ink (if any)	1-2
Estimated total groups		13-16

Cost-saving grouping rule: All of the following must be met to group into one → same material composition, same inks/coatings, same supplier, same manufacturing process. The actual number of groups is confirmed against the material list.

Test Standards & Limits

Test item	Limit	Reference standard
Lead (Pb)	Sum of four ≤ 100 mg/kg	EN 71-3 / EN 1122
Cadmium (Cd)		EN 1122 / ICP-MS
Mercury (Hg)		EN 71-3 / ICP-MS
Hexavalent chromium (Cr⁶⁺)		ISO 17075 / EN 16342

⚠️ Note: Hexavalent chromium must be tested separately and cannot be extrapolated from "total chromium". This is a common testing mistake.

Compliance Process (5 Steps)

Material list + separation sample prep

The manufacturer provides the BOM; we separate the homogeneous materials and determine the number of test groups

Heavy metals testing

Third-party laboratory tests the four heavy metals, 5-7 working days

Prepare DoC + technical documentation

Prepare the EU declaration of conformity and technical documentation based on the test reports

EPR registration

Packaging licensing registration in countries of sale (Germany/France/Italy/Spain/Netherlands)

✓

Archive for record

Complete archive of test reports + DoC + EPR + material list

FAQs

What is the relationship between PPWR and CE certification?

PPWR is an independent regulation, not part of a CE directive. But the DoC framework used for the CE mark equally applies to PPWR compliance — you need to issue a separate declaration of conformity for the packaging. The two run in parallel: one is product certification and the other is a packaging regulation.

My product volume is very small. Do I still need to do it?

PPWR has no minimum-volume exemption. As long as the product enters the EU market (including e-commerce sales), it must comply. Small volumes can use grouping testing to reduce per-unit cost.

How much does the testing cost?

It depends on the number of homogeneous material groups. Typically electronics packaging has 13-16 groups, with testing costs of about CNY 3,000-6,000 (excluding service fees and EPR registration fees). An accurate quote requires confirming the material list first.

Do I need to register in every country?

Only register in the countries where you actually sell. If you only sell in Germany and France, register in those two countries. A single country takes about 4-8 weeks.

PPWR countdown — start compliance now

Provide your product packaging material list and we'll evaluate the test groups and quote for free

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