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The EU's strictest packaging regulation PPWR will be enforced on August 12, 2026! Strictly investigate the content of heavy metals and PFAS in food contact packaging

Time：

2026-06-25

Starting from August 12, 2026, the European Union's Packaging and Packaging Waste Regulation (PPWR) is mandatory and applies to all EU member states. If the packaging of all goods exported to Europe does not meet the PPWR standards, they will face risks such as customs detention, market bans, mandatory recalls, and huge fines.

Starting from August 12, 2026, the European Union's Packaging and Packaging Waste Regulation (PPWR) will be officially enforced, fully replacing the old packaging directive that has been in effect for nearly 30 years. The regulations are uniformly applicable to all EU member states, without the need for each country to transform legislation, and there are no longer differences in implementation among countries. They impose full chain compliance requirements on cross-border product packaging.

The new regulations apply to all enterprises that sell packaged or packaged products to the EU market, regardless of whether they are within the EU, whether they are FBA or self shipping models, and must comply with them. The EU has made it clear that companies violating regulations will have their goods seized by customs, and e-commerce platforms will be forced to remove their products. The maximum fine can reach 6% of the global annual revenue, and those with serious circumstances will be permanently banned from entering the EU market. As the effective date approaches, platforms such as Amazon, AliExpress, TEMU, SHEIN, etc. are also strengthening their strict compliance inspections.

Part 01

PPWR control scope

After the full implementation of PPWR on August 12, 2026, packaging produced in the EU or third countries, whether empty or fully loaded, must comply with regulations as long as it is placed on the EU market.

PPWR covers the entire lifecycle of packaging, from design, production, market launch to recycling, and specifies requirements for extended producer responsibility and packaging waste prevention. Its scope of application is extremely broad, covering all packaging and packaging waste placed in the EU market.

Control Subject

Any enterprise that sells packaged or packaged products to the EU market, regardless of whether it is within the EU or not, and regardless of FBA or self shipping mode, must comply. The controlling entities include manufacturers, importers, distributors, retailers, suppliers, cross-border sellers, export traders, etc. Cross border e-commerce platforms are required to bear joint and several liability for Extended Producer Responsibility (EPR). Non EU companies must have an EU authorized representative.

Control Products

Packaging for all materials (plastic, paper, metal, glass, composite materials, etc.) and all scenarios (industrial, commercial, consumer goods, logistics, e-commerce express delivery, etc.).

All packaging waste, whether sourced from factories, shops, offices, or homes, is included in the scope of control.

Part 02

PPWR Compliance Key Points

Strict control of hazardous substances

Heavy Metal Testing (Mandatory for All Product Packaging)

Testing items: lead (Pb), cadmium (Cd), mercury (Hg), hexavalent chromium (Cr (VI))

Compliance limit: Total content of four items ≤ 100 mg/kg

Applicable objects: all packaging materials such as plastic, paper, ink, glue, coating, metal, glass, etc

Reference standards: EN 1122, EN 12498, ISO 11885 (ICP testing method), etc

Comprehensive PFAS Testing (Mandatory for Food Contact Packaging)

PPWR has reached the strictest standard in history for the control of perfluorinated/polyfluoroalkyl substances (PFAS) in food contact packaging:

Non aggregated single PFAS: ≤ 25 ppb

Total amount of non polymerized PFAS: ≤ 250 ppb

Total PFAS (including polymer PFAS): ≤ 50 ppm

If the total fluorine content exceeds 50ppm, the supplier must provide proof of the fluorine content in PFAS or non PFAS upon request.

Packaging Recyclability

Starting from August 12, 2026: Packaging must be recyclable

Before January 1, 2028: The European Commission will release a unified "Guidelines for Recyclable Design" to replace the different standards of over 20 countries previously

Starting from January 1, 2030: All packaging must be recyclable, and packaging placed on the market must reach level C or above; If the recyclability is less than 70%, it is considered "technically non recyclable" and is prohibited from being released.

Starting from January 1, 2038, packaging for market entry must reach level B or above, and only level A and B packaging are allowed to enter the EU market.

Requirements for recycled content in plastic packaging

Starting from January 1, 2030, it is required that any plastic part of packaging placed on the market must contain a certain proportion of recycled plastic, such as disposable plastic beverage bottles that must contain 30% recycled plastic (calculated based on the average annual value of the factory).

The European Commission will pass an authorization bill by December 31, 2026, to determine the calculation and verification methods for recycled plastic content.

Compostable packaging

Starting from February 12, 2028, tea and coffee filter bags and adhesive labels for fruits and vegetables must be compostable packaging.

Packaging minimization

Starting from January 1, 2030, manufacturers or importers must ensure that the weight and volume of packaging placed on the market are reduced to the minimum necessary level while meeting basic functions. Double wall, false bottom, unnecessary packaging layers, and other packaging designs aimed at exaggerating the perceived volume of the product are prohibited. The vacancy rate of combination packaging, transportation packaging, and e-commerce packaging shall not exceed 50%. All filling materials (bubble film, foam, paper scraps, etc.) are included in the empty space. The primary goal of packaging design should be to meet the basic functions of product protection, transportation, and display, avoiding excessive packaging or adding unnecessary decorative elements.

Moreover, the European Committee for Standardization (CEN) is required to revise EN 13428:2004 by February 12, 2027, to establish clear weight and capacity limits for the vast majority of common packaging in the market.

Reusable packaging

2030年1月1日起，运输包装需确保至少40%为可重复使用包装；分组包装需确保至少10%为可重复使用包装；最终分销商需确保市场上至少10%的饮料采用可重复使用包装。

Unified Packaging Label

On August 12, 2028, or 24 months after the implementation of the law, all packaging placed on the market must uniformly use recyclability and classification labels, indicating the material composition. The requirement for reusable packaging labels will be implemented on February 12, 2029, or 30 months after the implementation of the law.

Plastic packaging must be additionally labeled with the content of recycled and bio based plastics. Compostable packaging should indicate that the material is compostable. Packaging containing substances of concern must be marked using standardized and publicly available digital labeling techniques. Reusable packaging should be labeled and informed of its reusability.

Prohibition of single-use plastic packaging

Starting from January 1, 2030, the following disposable plastic packaging is prohibited from being placed on the market:

Disposable plastic packaging;

Suitable for disposable plastic packaging of pre packaged fresh fruits and vegetables weighing no more than 1.5 kilograms

Instant food and beverage packaging in hotels and restaurants;

Single package seasonings, sauces, creamers, and sugar packs;

Small disposable cosmetics and toiletries in the accommodation industry;

A very lightweight plastic tote bag

Extended Producer Responsibility (EPR)

All sellers selling packaged products to the EU market must complete EPR registration and fulfill relevant obligations in each selling country, and each country must handle it separately. Non EU companies must have an EU authorized representative to fulfill EPR obligations on their behalf. EPR registration numbers are not universal, for example, those registered in Germany are not recognized in France. No registration, no listing.

manufacturer

Definition: Refers to the party that manufactures or commissions the manufacture of packaging and sells it under their own name, brand, or trademark.

Undertake obligations: Responsible for developing packaging specifications, conducting conformity assessments, drafting technical documents (TD), and EU Declaration of Conformity (DoC).

manufacturer

Definition: Refers to anyone who places packaging or packaged products on the market for the first time in a member state, regardless of whether they actually produce, import, or distribute these products.

Undertaking obligations: Responsible for the extended producer responsibility (EPR) obligation and must bear the cost of managing waste within the territory of the member state.

Part 03

PPWR Key Compliance Time Points

2026.08.12：

Restriction of harmful substances

Total amount of heavy metals (lead, cadmium, mercury, hexavalent chromium) ≤ 100mg/kg

PFAS limit for food contact materials takes effect

The packaging should have recyclability
Export enterprises must complete EPR registration, issue DoC compliance statements, and retain a complete set of technical files

2028.02.12：

Partial packaging must be compostable

Tea and coffee filter bags, fruit and vegetable adhesive labels, etc

2028.08.12：

Uniform packaging label requirements

Implementation of unified labeling and marking requirements

2030.01.01：

Requirements for recycled plastic content

The packaging plastic part that is put on the market must contain a certain proportion of recycled plastic

Minimum packaging requirements

The weight and volume of the packaging need to be reduced to the minimum necessary level while meeting the functional requirements

Reusable targets

Transport packaging ≥ 40%, group packaging ≥ 10%, beverage packaging ≥ 10%

Recyclability level reaches level C

All packaging placed on the market must meet the standard of Class C or above

Prohibition of disposable plastic packaging

Prohibit the use of specific types of disposable plastic packaging

2038.01.01：

Recyclability level reaches level B

All packaging placed on the market must meet the B-level or higher standards

Part 04

PPWR合规建议

PPWR is a major reform in the packaging industry of the European Union. Starting from August 12, 2026, all goods exported to Europe that do not meet the PPWR standard packaging will face risks such as customs seizure, market ban, mandatory recall, and huge fines. Cross border e-commerce platforms such as Amazon, AliExpress, and TEMU have tightened their audits. It is recommended that cross-border sellers take immediate action to upgrade packaging materials, complete EPR registration, and comply with regulations as soon as possible

1. Product handling: Immediately investigate harmful substances such as PFAS and heavy metals in the packaging, replace excessive components, and complete rectification before August 2026.

2. Design improvement: Upgrade packaging design, enhance recyclability, meet recycled material content, advance layout of A/B level recyclability levels, and meet the 2038 threshold.

3. Supply chain management: Require suppliers to provide compliance certificates, establish a recycled material system, and ensure that the content of recycled materials meets standards.

4. Label rectification: Design packaging labels according to EU unified standards, layout digital markings (QR codes, digital traceability), and complete the update of all category labels by 2028.

5. Compliance registration: Each sales country completes EPR registration separately, obtains a registration number, is equipped with European agents, and uploaded to the platform.

6. Data retention: Establish a retention system for compliance documents, production data, and recycled data to ensure traceability and respond to inspections by regulatory authorities.

As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CPSC, CCC, and has obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. The laboratory is strictly built and managed according to standards, equipped with advanced instruments and equipment, and has a skilled professional technical team with rich industry service experience and strong testing technology capabilities. It is proficient in various regulatory standards and can provide you with PPWR related compliance testing services, including but not limited to heavy metals PFAS、REACH、 Phthalates POPs、 We provide testing services for formaldehyde, VOC, and food contact materials to assist companies in actively responding to regulatory requirements, helping them achieve risk management of harmful substances, and effectively improving product compliance. Welcome to contact us at 400-9269-886 ！