Packaging & Packaging Waste

Obligations attach through you as the EU importer or producer. Applicable since 12 August 2026.

FALLS ONSUPPLIERBUYER

This one falls on you directly.

THE OFFICIAL ARTIFACT

What the supplier must actually produce.

Not a materials list. A declaration backed by substance testing and a recyclability assessment of the packaging as it is actually placed on the market.

WHO SIGNS IT OFF

Self-declaration per packaging format, produced to national authorities on request. Extended producer responsibility means registration and reporting in every Member State you sell into, with fees modulated by recyclability. Packaging is not CE-marked.

REQUIRED ARTIFACT · PPWR6 ELEMENTS

EU declaration of conformity + technical documentation

REG. (EU) 2025/40 · ART. 5, 6, 38, 39 · ANNEXES VII, VIII

Heavy metalsLead, cadmium, mercury and hexavalent chromium, 100 ppm combined.

PFAS in food-contact packagingIntentionally added PFAS prohibited.

Whole-unit testingInks, coatings, adhesives and labels included — not the substrate alone.

Recyclability assessmentDesign-for-recycling performance grade.

Technical documentationThe Annex VII file standing behind the declaration.

EU declaration of conformityOn the Annex VIII model. No CE mark applies to packaging.

THE CHARACTERISTIC FAILURE

A substrate test report arrives, and it passes.

A specification sheet arrives where a conformity statement per format was needed.

WHAT USUALLY ARRIVESINSUFFICIENT

Substrate test report

ACCREDITED LAB · BASE MATERIAL ONLY · WITHIN LIMITS

Genuine laboratory data, correctly reported

Tests the board or film in isolation

Inks, coatings, adhesives and labels not included

NOT SUFFICIENT

A clean test of part of the packaging. The limit applies to the packaging unit as placed on the market, additions included.

WHAT THE REGULATION NAMESSUFFICIENT

Whole-unit conformity evidence

UNIT AS PLACED ON MARKET · 100 PPM COMBINED · NO CE MARK

Heavy metals across the complete unit, inks and coatings included

PFAS position stated for food-contact packaging

Recyclability grade assessed and documented

SUFFICIENT

Same packaging, same materials — tested as the unit the regulation actually regulates.

THE DELTA: THE SUBSTRATE ALONE VS THE PACKAGING UNIT AS PLACED ON THE MARKET

NEXT MILESTONE · PPWR

LAST VERIFIED 9 AUG 2026

NowIN FORCE

IN FORCEAPPLIES 12 AUG 2026

Regulation becomes applicable

Packaging placed on the EU market must meet the new recyclability and minimum-recycled-content regime, with staged design criteria after that.

Does PPWR reach your products?

Find out which of your packaging formats you can evidence, and in which Member States you are registered.

Request a demo