Do I Still Need PPWR Compliance if I Have RoHS?

Are manufacturers engaged in EU foreign trade feeling overwhelmed lately by the endless stream of new regulations? With rapid regulatory updates, multiple dimensions of compliance, and continuously rising testing costs, the slightest negligence can lead to the risk of customs clearance detention, failed customer factory audits, or even hefty fines.

Recently, we have received a high frequency of questions from countless clients: "My products and packaging are already rohs compliant and meet all specifications. Does this mean I don't need to do PPWR anymore?"

Today, we give everyone a clear, unified answer: Absolutely not! Packaging materials with only RoHS Compliance cannot pass the EU PPWR audit; the two cannot replace each other!

Many foreign trade enterprises have suffered from customs delays, rework rectifications, and heavy losses simply because they confused the two regulations and mistakenly believed that "RoHS = PPWR compliance." The two only overlap in the control of a small amount of heavy metals. The control scope, compliance requirements, and audit standards of PPWR are far more stringent and comprehensive than those of RoHS. Today, this article will thoroughly explain the core differences, applicable scenarios, and practical compliance solutions to help you avoid the pitfalls of foreign trade compliance!

Similarities in Compliance Between RoHS and PPWR

The core reason many people confuse the two regulations is that they only see the overlapping parts in heavy metal control, while ignoring the fundamental differences in the overall control logic.

• RoHS Directive: Primarily controls the main body of electrical and electronic products, restricting a total of 6 hazardous substances: lead, cadmium, mercury, hexavalent chromium, PBB, and PBDE.

• PPWR (Packaging and Packaging Waste Regulation): Specifically controls all packaging materials exported to the EU. The core requirement for heavy metals is that the total content of lead, cadmium, mercury, and hexavalent chromium must be ≤100 mg/kg.

Simply put, the only overlap between the two is the control of these four heavy metals, with limit requirements essentially aligned.

In addition to this, there is a practical convenience point: if your packaging materials contain electronic components such as smart labels or electronic sensors, the EN 62321 series of testing methods corresponding to RoHS can be directly used as a reference basis for PPWR heavy metal testing, without the need to repeat basic testing.

However! This is the only intersection between the two. RoHS cannot completely cover all the remaining compliance requirements!

Mandatory PPWR Requirements That RoHS Cannot Cover

The compliance loopholes of the vast majority of enterprises stem from these three major dimensions, which are also the focus of current strict EU inspections. Each item is a hard, mandatory requirement!

1. New Exclusive Hazardous Substance Controls (No Requirement in RoHS)

RoHS only controls 6 conventional hazardous substances, whereas PPWR has added multiple specific control requirements for packaging materials:

• Food Contact Packaging: Total content of PFAS (per- and polyfluoroalkyl substances) ≤50 ppm.

• High-Risk Scenario Packaging: Mandatory control of sensitizing and hazardous chemicals such as BISphenol A and Phthalates.

None of these substances are within the scope of routine ROHS Testing. Even if a rohs report gets a perfect score, it will still directly result in a judgment of non-compliance for PPWR.

2. Mandatory Standards for Packaging Circularity Attributes (Completely Blank in RoHS)

RoHS only controls hazardous substances in products and does not involve the environmental circulation and design specifications of packaging at all. Conversely, PPWR has explicit mandatory standards for the "recyclability" of packaging:

• Recyclability Grade: Packaging must achieve a recyclability grade of C or above.

• Recycled Material Ratio: Mandatory enforcement of recycled material proportion requirements starting in 2030.

• Void Space Ratio: Strict control of packaging void space ratio ≤50% to eliminate over-packaging.

Simply understood: even if all the chemical substances in your packaging materials meet the standards, as long as there is over-packaging, un-recyclability, or the proportion of recycled materials is not up to standard, you still cannot pass EU customs.

3. Complete Compliance System Process (No Related Obligations in RoHS)

PPWR is not just simple material testing; it is a complete corporate compliance system. It has multiple process requirements that RoHS does not possess at all:

• EPR Registration: Must complete EU EPR (Extended Producer Responsibility) packaging registration.

• Recycling Labels: The packaging surface must be affixed with uniform EU recycling classification labels.

• Digital Product Passport (DPP): Gradual rollout of the Digital Product Passport starting in 2028.

Many enterprises have only done rohs testing, but lack EPR registration, labels, and circularity certification. While seemingly compliant, they are actually entirely unprotected and highly susceptible to being intercepted by customs and held accountable by customers.

Foreign Trade Enterprises Need to Supplement PPWR Compliance

There is no need to blindly redo the entire set of tests. Based on your existing RoHS compliance foundation, targeted filling of the gaps offers the highest cost-effectiveness and fastest implementation!

1. Testing Standards Compiling with EU Supervision

For conventional packaging made of ordinary paper, plastic, and metal, give priority to adopting the PPWR specific harmonized standard EN 13428 to complete heavy metal testing. Compared to applying the RoHS EN 62321 standard, it is more suitable for the latest EU regulatory requirements and has higher recognition.

2. Supplementary Chemical Compliance

On the basis of valid existing RoHS reports, conduct targeted supplementary testing for PPWR-exclusive hazardous substances such as PFAS, Phthalates, and Bisphenol A. There is no need to retest overlapping items, significantly reducing compliance costs.

3. Perfecting Certification and Registration

Separately entrust an EU-recognized third-party agency to issue a packaging recyclability grade determination report and recycled material traceability documents. Concurrently, complete EPR packaging registration for the corresponding EU countries, standardize the application of packaging recycling labels, and plan ahead for Digital Product Passport (DPP) compliance to completely avoid customs clearance risks.