PPWR Hazardous Substances Control, Recyclability, Labeling

On January 22, 2025, the Official Journal of the European Union officially published the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, referred to as PPWR), completely replacing the Packaging and Packaging Waste Directive (94/62/EC, PPWD) which had been implemented for nearly 30 years.

PPWR will be fully implemented starting from August 12, 2026, reshaping the entire lifecycle management rules for packaging in the EU.

Consequently, numerous Amazon sellers have consecutively received platform notifications requiring them to register and submit EPR registration numbers in every EU country where they sell packaging or packaged products.

Key Compliance Countries for Amazon

Amazon currently highlights PPWR compliance requirements for 9 major countries: Germany, Spain, France, Belgium, Italy, the Netherlands, Ireland, Poland, and Sweden.

Sellers who sell packaging or products containing packaging in the aforementioned countries must complete packaging law registration in those respective countries, obtain registration numbers, and upload them to the platform.

This is another mandatory compliance requirement following Amazon's comprehensive rollout of the EU New Battery Regulation compliance in 2025; failure to complete compliance will result in product suspension risks.

Who is Affected by PPWR?

PPWR affects almost every online or offline business that manufactures, sells, or imports packaged goods within the EU.

This includes: packaging manufacturers, brand owners, retailers, food and beverage producers, e-commerce enterprises, and logistics operators.

Companies with complex packaging systems or strict safety rules will face the greatest compliance challenges.

This regulation goes much deeper than previous packaging directives; it not only requires EU countries to establish producer registers and sellers to complete packaging law registration in destination countries of sales, but also impacts sellers' choices regarding materials and designs.

Analysis of PPWR Core Requirements

Main Compliance Obligations

Producers must fulfill multiple obligations, mainly including:

• Adjustment of packaging materials according to new requirements starting from August 12, 2026.

• Adjustment of labels according to new requirements starting from August 12, 2026.

• Registration in the national product registers provided by member states.

• Submission of annual reports.

Substance Control (Article 5 of EU PPWR)

Starting from August 12, 2026:

• The total concentration of lead, cadmium, mercury, and hexavalent chromium in packaging ≤ 100 mg/kg

• PFAS (per- and polyfluoroalkyl substances) limits in food-contact packaging:

• Quantifiable monomeric PFAS (non-polymeric) ≤ 25 ppb

• Sum of all monomeric PFAS (non-polymeric) ≤ 250 ppb

• Total fluorine content of polymeric PFAS ≤ 50 ppm (if exceeded, proof must be provided and technical documentation compiled)

Recyclable Packaging Requirements (Phased Implementation)

• From January 1, 2030: All packaging placed on the EU market must be recyclable, and their recyclability performance must reach Grades A, B, or C (recyclability < 70% is considered "technically non-recyclable" and is prohibited from being placed on the market).

• From January 1, 2038: Only Grade A and B recyclable packaging will be allowed into the EU market.

Recycled Content & Bio-based Requirements

Quantitative targets for recycled content in plastic packaging:

• Single-use plastic beverage bottles: ≥ 30% by 2030, ≥ 65% by 2040

• PET contact-sensitive packaging (excluding single-use beverage bottles): ≥ 30% by 2030, ≥ 50% by 2040

• Non-PET contact-sensitive packaging (excluding single-use beverage bottles): ≥ 10% by 2030, ≥ 25% by 2040

• Other plastic packaging: ≥ 35% by 2030, ≥ 65% by 2040

In addition, the EU will review the technical performance of bio-based plastic packaging by February 12, 2028, to formulate sustainability requirements for bio-based raw materials.

Compostable Packaging

• By February 12, 2026: The EU requires the formulation of unified technical specifications for compostable packaging.

• By February 12, 2028: Compostable packaging (including biodegradable plastics) must be designed with priority for material recycling and must not affect the recyclability of other waste streams.

Labeling and Labeling Information Requirements

• From August 12, 2026: Packaging must bear a detailed information label stating the manufacturer/importer name, brand, and address.

• From August 12, 2028: Packaging must be marked with a material composition pictogram to facilitate consumer sorting.

• From February 12, 2029: Reusable packaging must be labeled with a QR code.

• Environmental claims exceeding minimum requirements are permitted, but they must explicitly state whether they target the packaging as a whole or a part of it.

Obligations of Producers, Manufacturers, and Distributors

Producer Obligations

• Register packaging information in the producer register of each member state where packaging or packaged products are provided.

• Report annually to the competent authority the mass of packaging (broken down by type) or the total volume of packaging placed on the market for the first time in the corresponding member state.

Manufacturer Obligations

• Conduct conformity assessments in accordance with internal production procedures to prove compliance with regulatory requirements.

• Complete technical testing and prepare relevant documents, with the assistance of external scientific advisors if necessary.

• Issue an EU Declaration of Conformity after conformity assessment and properly keep documents and technical data.

Distributor Obligations

• Verify that producers and packaging labels comply with regulatory requirements.

Who is Responsible for Establishing the Producer Register?

EU member states are required to establish systems and infrastructure (producer registers) to monitor compliance, ensure that end-users return and separately collect all packaging waste (return and collection systems), while promoting the development of reuse and refill systems to support the packaging industry's transition to a circular economy.

Seller Compliance Strategies

• Clarify Identity and Initiate Registration: Confirm whether you qualify as a producer as defined by the EU PPWR, and initiate packaging law registration in the destination countries of sales.

• Upload Registration Numbers to Cross-Border E-Commerce Platforms: Sellers on platforms like Amazon should upload packaging law registration numbers for each country to the corresponding backend site; offline remote sellers can indicate it on sales invoices and other documents to cope with official inspections.

• Optimize Packaging Design and Materials

• Establish a Reclaimed Material Supply Chain

• Enhance Recyclability

• Improve Labeling and Traceability

• Plan Reusable Packaging Solutions in Advance

Note: PPWR fundamentally changes how packaging is designed, produced, labeled, and documented, applying to all packaging entering the EU market. Amazon's enforcement of PPWR requirements is essentially a response to EU regulations to meet packaging market access criteria.

It is highly recommended to initiate packaging law registration in destination countries as early as possible to ensure full compliance before the regulation takes effect, avoiding any disruptions to overseas market business.