PPWR Packaging Compliance
Your product is tested. Now test its packaging.
One law for every pack on the EU market.
Regulation (EU) 2025/40 · applies since 12 August 2026
Since 12 August 2026, every pack placed on the EU market falls under one law, wherever it was made. That includes packs made in Pakistan.
The list is wider than many expect. A hanger sold with a shirt is packaging, and so are hang tags and sticky labels. Dust bags for shoes and garments count too.
The PPWR at a glance
Regulation (EU) 2025/40 · status on 13 October 2026
4
Duties that apply now
100 mg/kg
Pb, Cd, Hg and Cr(VI), added together
25 ppb
Any one PFAS in food-contact packaging
7
Materials covered, plastic to composite
2030
Six single-use formats banned
Four duties apply now.
They apply to every pack placed on the EU market, wherever it was made. The PFAS limits cover food-contact packaging only. Every pack must also minimise substances of concern.
Heavy metals
Lead, cadmium, mercury and hexavalent chromium, added together: 100 mg/kg at most.
The limit covers all packaging and its components, printed board and inks included. It is not new: the old directive had the same figure. What changed is who holds the proof.
Two derogations stay
Glass, where recycled glass causes the excess and nothing is added on purpose. Plastic crates and plastic pallets.
At Tti Labs, in Lahore
Lead, cadmium and mercury by ICP-OES or ICP-MS, plus hexavalent chromium: the four results your file needs.
PFAS limits
Food-contact packaging only: 25 ppb for any one PFAS, 250 ppb for the sum and 50 ppm in total. A result on a limit fails.
Intentional and unintentional PFAS both count.
The whole unit counts: inks, varnishes, glues and adhesives too.
No list of PFAS will be published. Any CF3 or CF2 group counts.
Recycled board gets no exemption.
For imports, the customs release date counts. Older stock gets no sell-off period.
Step 1 is total fluorine
Below 50 mg/kg, the sample can be considered compliant. Above 50 mg/kg, methods such as pyrolysis-GC/MS show which kind. A direct TOP assay checks the 25 and 250 ppb limits.
The compliance file
There is no PPWR certificate. There is a file.
The manufacturer proves compliance with a technical file and an EU declaration of conformity. Test reports feed the file. The manufacturer signs the declaration.
Description and intended use
Design, drawings and component materials
Standards and specifications applied
Assessments under Articles 6, 10 and 11
Test reports
An analysis of the risk of non-conformity
A lab may carry out the conformity assessment for you. The technical file cannot be delegated, and the manufacturer still answers for the declaration.
The marking
A type, batch or serial number on every pack, plus the manufacturer's name and postal address.
5 years: keep the file for single-use packs
10 years: keep the file for reusable packs
10 days: to hand the file to an authority that asks
1 declaration per packaging type
On the pack, or behind a QR code or other data carrier. One component of the unit is enough.
Stock made before 12 August 2026 need not be destroyed or relabelled. An accompanying document can carry the ID and address.
Who does what
Every pack has one manufacturer. It may be you.
The manufacturer is whoever has the pack made under its own name or trademark. That is often not the factory.
Private label for an EU retailer: the retailer is the manufacturer; you are a supplier.
Plain export cartons: standard and unbranded, the carton maker is normally the manufacturer. Made to your order and design: you are.
Own brand, through an EU importer: you are the manufacturer.
Direct to EU consumers: you are the producer in each country you sell to.
Packaging converter: you are a supplier.
Food exporter: the PFAS limits apply now.
Goods only in transit through the EU need not comply. Exports outside the EU carry no EU EPR.
Recycling & reuse
Some duties apply now. Others follow in steps.
12 Feb 2028: sales packs, empty space cut to the minimum
12 Aug 2028 or later: harmonised sorting label; old material codes end
1 Jan 2030: six single-use formats banned; 40% reusable transport packs
1 Jan 2030 or later: grades A–C only; recycled content; 50% empty space
1 Jan 2038: grades A–B only
1 Jan 2040: higher recycled content; aim of 70% reuse
Grade A: 95% or more. Grade B: 80% or more. Grade C: 70% or more. Below 70%, a pack is not recyclable.
With 5% plastic or more, a paper-based pack counts as plastic for the bans. Tti Labs identifies materials by FTIR and weighs each component.
Test reports for your technical file.
How Tti Labs helps
PPWR need and service
PPWR need
Tti Labs service
Status
Heavy metals · Art. 5(4)
Pb, Cd and Hg by ICP-OES or ICP-MS; Cr(VI)
Available
PFAS step 1 · total fluorine
Total fluorine by combustion ion chromatography (CIC)
Available
PFAS limits · Art. 5(5)
Targeted PFAS by LC-MS/MS
Available
Materials · the 5% plastic line
FTIR identification; weighing of each component
Available
Minimisation · empty space
Packaging weight; dimensional checks
Available
Food-contact rules
Overall and specific migration; extractables and leachables
Available
Marking and packing
Checks at pre-final and pre-shipment inspection and at loading, by Tti Inspections Pvt Ltd (ISO/IEC 17020, PNAC IB-006)
Available
Supplier data
Supply chain mapping by Tti Labs Sustainability Center
Available
Recycled content · Art. 7
Recycled plastic verification
Partner labs
Recyclability · Art. 6
Recyclability assessment; documentation support
Technical support
File and declaration
Gap assessment; support with the Annex VII file and the declaration
Technical support
What Tti Labs does not do. Tti Labs reports results for the samples it tests. It is not the manufacturer and does not sign declarations. It issues no “PPWR certificate”, does not register producers and does not act as an authorised representative. It assigns no official recyclability grade. Status words describe availability, not accreditation scope.
Roles under the PPWR
Role, who it is, what it must do
Role
Who it is
What it must do
Manufacturer
Has the pack made under its own name or trademark. Without a brand, it orders the pack and sets the design. One per supply chain.
Conformity assessment, technical file, declaration and marking. Keeps the file for 5 or 10 years.
Supplier
Supplies packaging or packaging material to the manufacturer.
Hands over the information and documents the file needs (Article 16).
Importer
Established in the EU. Places packaging made outside the EU on the market.
Checks that the non-EU manufacturer did the assessment and declaration. Adds its own name and address, and keeps a copy.
Distributor
Makes packaging available after it was first placed on the market.
Checks the producer’s registration and the labels.
Producer (EPR)
First makes the pack available in an EU country, or sells direct to end users there.
Registers, reports and pays extended producer responsibility fees in that country.
Authorised representative
Optional for the manufacturer. Required for EPR when you sell direct to end users in another country.
Acts for the manufacturer, but cannot draw up the technical file.
Orientation only, not legal advice. Summaries of Regulation (EU) 2025/40, Commission guidance C/2026/3084 and the Commission’s PPWR FAQ (2nd edition), read 13 October 2026.
Recycled plastic content, minimum
Article 7
2030, or later
2040
30%
50%
10%
25%
30%
65%
35%
65%
Averages per manufacturing plant and year. Only post-consumer plastic counts. Factory scrap does not. Exempt, among others: plastic parts under 5% of the unit’s weight.
Certified, accredited & approved
ISO/IEC 17025 · PNAC Lab 022
ISO/IEC 17020 · PNAC IB-006
U.S. IAC certified microbiology lab
PSQCA approved
1995
In service since
1,500+
Tests a day
600+
Samples a day
Need more details?
PPWR · Regulation (EU) 2025/40
PPWR packaging compliance