SGS UK

Below are ten key questions that provide a clear and practical overview of what PPWR means in practice.

1. Who is responsible for packaging compliance under PPWR?

Responsibility depends on your role in the supply chain, but it is often broader than expected.

If you import packaged goods into the EU, you are typically considered the importer and must verify that the packaging complies before placing it on the market. However, if you influence packaging design, material selection or branding, you may legally be considered the manufacturer, which carries full responsibility for compliance.

In addition, the company that first places the product on an EU market is responsible for extended producer responsibility (EPR). This means registering in each Member State and financing the collection and recycling of packaging waste.

2. What counts as ‘packaging’ under PPWR?

PPWR takes a broad and functional approach to defining packaging.

It includes not only items like boxes, cartons and plastic wrap, but also secondary components such as:

• Hangtags
• Labels and adhesives
• Fasteners and clips

Any item performing a containment, protection or presentation function may qualify. However, durable goods (e.g. mugs or tableware) are not considered packaging unless they are used in a packaging or service context.

3. Are single-use items like cups and plates always in scope?

No. Classification depends entirely on how the product is used.

If items like paper cups or plates are filled at the point of sale, they are considered service packaging and fall under PPWR. However, if they are sold empty to the customer, they are treated as products and not packaging.

Regardless of this distinction, any outer packaging (e.g. shrink wrap or cartons) must comply with PPWR requirements.

4. What are the key chemical and material compliance requirements?

PPWR sets strict limits on substances of concern:

• The total concentration of lead, cadmium, mercury and hexavalent chromium must be below 100 ppm
• Per- and polyfluoroalkyl substances (PFAS) restrictions apply to food-contact packaging, with very low thresholds

To demonstrate compliance, companies must maintain:

• Laboratory test reports
• A full technical documentation (TD) file
• A signed EU Declaration of Conformity (DoC)

5. How should businesses approach PFAS and chemical testing?

Testing is not expected to be one-size-fits-all. Instead, regulators recommend a stepwise approach:

• Start with total fluorine (TF) screening
• If thresholds are exceeded, confirm whether fluorine is organic (PFAS)
• Only then perform detailed PFAS analysis at very low limits

To help balance compliance with cost and practicality, companies can also adopt efficient strategies such as:

• Testing representative materials (a ‘family approach’)
• Using supplier data where reliable

6. What documentation is required and how detailed does it need to be?

PPWR requires robust documentation to demonstrate compliance.

The TD must include:

• A complete bill of materials (BoM), covering all components (including inks, coatings and adhesives)
• Supporting test reports
• Recyclability assessments
• Justification of packaging design choices

The DoC is the formal legal statement confirming compliance, supported by the TD.

7. What labeling and traceability requirements apply?

From mid-2026 (18 months after entry into force), packaging must include:

• Name and address of the manufacturer or importer
• A traceability identifier (e.g. batch, serial or style number)

From 2028, harmonized EU-wide recycling pictograms will become mandatory.

It is important to note that not every component needs individual labeling. Information can be consolidated on the main packaging, potentially supported by a QR code. This will ensure traceability without compromising recyclability.

 market requires careful consideration of evolving safety legislation and testing requirements. We work with manufacturers, importers, retailers and brand owners throughout the product lifecycle, providing independent testing and technical expertise to help demonstrate compliance with UK and European safety standards.

8. What are the recyclability requirements and timeline?

PPWR introduces a two-step approach to recyclability:

"A practical guide to PPWR requirements, timelines and compliance steps for packaging across the EU market."

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FAQ: What You Need to Know About the EU Packaging and Packaging Waste Regulation (PPWR)

The EU Packaging and Packaging Waste Regulation (PPWR) introduces a comprehensive framework that reshapes how packaging is designed, tested, labeled and managed across its life cycle. With key deadlines beginning in August 2026 and further tightening in 2030, businesses should act now to ensure compliance.