PPWR Compliance Declaration for Packaging Materials

PPWR Compliance Declaration for Packaging Materials

Summary

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) is the new unified packaging law that replaces the former Packaging Directive (94/62/EC). Effective from February 11, 2025, with major compliance obligations becoming mandatory from August 12, 2026, PPWR applies directly across all 27 EU Member States without national variations.

PPWR stands for Packaging and Packaging Waste Regulation, officially designated as Regulation (EU) 2025/40.
It replaces the previous Packaging Directive (94/62/EC), which had been in force for nearly 30 years. The regulation officially entered into force on February 11, 2025, with its core provisions becoming mandatory on August 12, 2026.
Unlike the former directive, PPWR is a directly applicable EU regulation. All 27 EU Member States must implement the same requirements without national deviations, making it one of the most important compliance regulations for companies involved in cross-border trade, food products, consumer goods, and packaging materials.

1. Regulatory Framework


1.1 Scope and Objectives

Regulatory Upgrade
PPWR replaces the previous directive with a directly applicable regulation, creating a unified legal framework across all EU Member States.

Products Covered

The regulation applies to all packaging placed on the EU market, including:
1.Product packaging
2.Transport packaging
3.Secondary and auxiliary packaging
4.Cartons and corrugated boxes
5.Plastic bags
6.Adhesive tapes
7.Bubble wrap
8.Labels
9.Food-contact packaging
The regulation covers all packaging materials, including paper, plastic, metal, glass, and composite materials.

Responsible Economic Operators

Compliance obligations apply to:
1.Manufacturers
2.Importers
3.Cross-border sellers
4.Brand owners and retailers

Non-EU companies must appoint an Authorized Representative (AR) within the European Union to fulfill regulatory obligations. Certain exemptions may apply to micro-enterprises.

Key Objectives

1.Reduce packaging waste
2.Restrict hazardous substances
3.Promote recyclable packaging design
4.Strengthen Extended Producer Responsibility (EPR)
5.Increase the use of recycled materials

2. Key Compliance Timeline

Date
Milestone
Main Requirement
February 11, 2025
PPWR enters into force
Regulation becomes part of EU law
March 30, 2026
EU implementation guidelines and FAQs issued
Clarification of packaging definitions, PFAS restrictions, EPR requirements, and labeling rules
August 12, 2026
Core provisions become mandatory
EPR registration, PFAS restrictions, packaging labeling, and recycling obligations fully enforced
August 12, 2028
Unified packaging labeling requirements become mandatory
Producer information, batch identification, and compliance markings required
January 1, 2030
Recyclability grading and recycled-content requirements take effect
Packaging must achieve at least Grade C recyclability; plastic packaging must contain a minimum of 35% recycled content
January 1, 2040
Higher recycled-content and reuse targets apply
Increased recycled-content requirements and reuse obligations

3. Core Compliance Requirements


3.1 Extended Producer Responsibility (EPR)

All packaged products sold within the EU must be registered under the packaging EPR system of the destination country and obtain a valid registration number.
Major e-commerce platforms, including Amazon and AliExpress, require sellers to provide EPR registration numbers.
For Pan-European sellers, registration is generally required in key markets such as:
1.Germany
2.France
3.Italy
4.Spain
5.Netherlands

Failure to comply may result in product delisting, suspension of Pan-EU privileges, customs detention, or financial penalties.

3.2 Hazardous Substance Restrictions

Effective August 12, 2026:

Heavy Metals

The combined concentration of the following substances must not exceed 100 mg/kg (ppm):
1.Lead (Pb)
2.Cadmium (Cd)
3.Mercury (Hg)
4.Hexavalent Chromium (Cr⁶⁺)

PFAS Restrictions

Food-contact packaging is subject to strict PFAS limitations with no general transition period.
Products exceeding applicable PFAS limits may not be placed on the EU market.

3.3 Packaging Design Requirements

1.Excessive packaging is prohibited.
2.Empty space within e-commerce packaging is restricted.
3.Certain single-use plastic packaging formats will be phased out.
4.Low-recyclability packaging may be prohibited from the EU market beginning in 2030.

3.3 Packaging Design Requirements

1.Excessive packaging is prohibited.
2.Empty space within e-commerce packaging is restricted.
3.Certain single-use plastic packaging formats will be phased out.
4.Low-recyclability packaging may be prohibited from the EU market beginning in 2030.

3.4 Packaging Labeling Requirements

Packaging or accompanying documentation must include:
1.Producer name
2.Business address
3.Contact information
4.Batch or lot number
5.EU compliance declaration

For small packaging formats, QR codes may be used in place of certain printed information.

4. Greenwood Compliance Declaration


PPWR Compliance Statement

Regarding the requirements of the EU Packaging and Packaging Waste Regulation (PPWR), we hereby issue this Compliance Declaration and confirm the following:
1.All packaging materials supplied by Greenwood (Dalian) Industrial Co., Ltd. comply with the requirements of PPWR and all other applicable European Union regulations.
2.The chemical composition of our packaging materials fully complies with the applicable limits:

Heavy Metals

The combined concentration of the following substances does not exceed 100 mg/kg (ppm):

1.Lead (Pb)
2.Cadmium (Cd)
3.Mercury (Hg)
4.Hexavalent Chromium (Cr⁶⁺)

Bisphenol A (BPA)

Food-contact packaging supplied by Greenwood does not contain Bisphenol A (BPA).

PFAS Compliance

PFAS content in food-contact packaging complies with the following limits:
1.Individual non-polymeric PFAS: < 25 ppb
2.Total non-polymeric PFAS: < 250 ppb
3.Total PFAS including polymeric PFAS: < 50 ppm

We hereby certify the above statement to be true and accurate.
Greenwood (Dalian) Industrial Co., Ltd.
June 17, 2026