EU New Packaging Regulation PPWR Compliance

The EU Packaging and Packaging Waste Regulation (PPWR) requires that starting from August 12, 2026, all packaging placed on the EU market must prove compliance with the limits for four heavy metals and, for food contact packaging, PFAS/Total Fluorine (TF). Additionally, they must complete packaging registration and recycling declarations in the respective member states. Otherwise, they will face customs detention, removal from platforms like Amazon/eBay, and fines of up to 4%–6% of the annual turnover.

JJR LAB is a CMA and CNAS accredited laboratory, providing regulatory interpretation, packaging chemical compliance testing, and EU EPR packaging registration and declaration services for enterprises exporting to Europe.

What Packaging Does PPWR Regulate?

The regulatory scope of PPWR is very broad—all packaging and packaging waste on the EU market are included, regardless of material, industry, or product category. Based on application, they can be classified into four categories:

1.Primary / Sales Packaging: Packaging in direct contact with the product and intended for the end user, such as beverage cans and toothpaste tubes.

2.Secondary / Grouped Packaging: Packaging that groups multiple sales units together, such as the shrink wrap around a 6-pack of beverages.

3.Transport Packaging: Used for handling and protection during logistics, such as corrugated boxes, stretch wrap, pallets, and strapping bands.

4.Service Packaging: Used for filling at the point of sale, such as takeaway boxes and coffee cups.

Note: Transport and B2B industrial packaging (pallets, stretch wrap, cushioning materials, etc.) are also within the scope of PPWR and must be evaluated separately; however, road, rail, marine, and air shipping containers themselves are excluded—materials used inside the containers to secure and protect the products may still be regulated.

Heavy Metals Testing

Applicable Subjects

Sales packaging / Grouped packaging / Transport packaging (pallets, stretch wrap, strapping bands) / Service packaging / E-commerce packaging. Substrates, printing layers, coatings, and adhesives are disassembled and tested as homogeneous materials.

Statutory Limits

Fluoride and pfas testing

Food Contact Scenarios Covered

Tea bags, coffee capsules, baking paper, blister trays, composite films, greaseproof paper bags.

Trigger Logic

1.Total Fluorine (TF) Screening: ≤ 50 mg/kg (50 ppm) → Direct release.

2.Total Fluorine > 50 mg/kg → Proceed to organic/inorganic fluorine differentiation.

3.Organic Fluorine exceeds limits → Target PFAS monomer quantification.

PPWR Limits for Food Contact Packaging

Special Note: Although there are currently no numerical PFAS limits for non-food contact packaging, member state EPR and buyer factory audits have started collecting Total Fluorine reports. JJR LAB recommends issuing a "Heavy Metals + Total Fluorine" combo package in the same batch to avoid secondary sample submission.

EU EPR Packaging Registration and Declaration

PPWR does not exist in isolation; it is closely linked to the EPR (Extended Producer Responsibility) systems of EU countries. Having only a test report is insufficient for customs clearance and market entry; you must complete EPR registration in the target market and obtain a packaging recycling number.

1.Multi-Country Registration: Packaging law registrations in major EU countries such as Germany (LUCID), France (CITEO), Spain, Italy, and the Netherlands.

2.Compliance Declaration: Annual recycling volume declarations and guidance on recycling fee payments.

3.Data Integration: Seamlessly integrate your chemical test data into the EPR compliance database to handle spot checks and audits by market regulatory authorities.

Why Do Testing and EPR Together?

During audits, German customs and e-commerce platforms (such as Amazon) frequently require sellers to prove the environmental safety of their packaging materials (i.e., test reports). JJR LAB's "Testing + EPR" one-stop service ensures that your technical documentation (DoC) perfectly matches the administrative registration, eliminating the risk of account suspension due to missing documents.