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

Consumer CompactHardgoodsJuly 07, 2026

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.

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.

8. What are the recyclability requirements and timeline?
PPWR introduces a two-step approach to recyclability:

From 2026: packaging must be designed to be recyclable in principle
From 2030: packaging must meet minimum performance thresholds: at least 70% recyclable (Grade C)

Packaging that fails to meet these thresholds will not be allowed on the EU market. Therefore, businesses should proactively assess and improve packaging design now to avoid costly redesigns later.

9. How does PPWR address packaging design and empty space?
PPWR emphasizes minimization and efficient design.

A 50% empty space limit applies to:

Grouped packaging
Transport packaging
E-commerce packaging

For sales packaging, there is no fixed limit, but companies must:

Minimize empty space
Justify design decisions in their TD

It should be noted that void-fill materials such as bubble wrap and foam count toward empty space.

10. What should businesses be doing now and what happens if they don’t comply?
Ideally, businesses should already be preparing for PPWR.

Key actions include:

Building complete BoMs
Conducting chemical testing (heavy metals, PFAS, etc.)
Assessing recyclability at the design stage
Compiling the TD
Ensuring EPR registration in relevant markets

These are the important compliance dates:

From 2026, non-compliant packaging must not be newly placed on the market
From 2030, packaging that does not meet recyclability thresholds will be prohibited from the EU market

Conclusion

PPWR is more than an environmental regulation. It fundamentally changes how packaging is designed, documented and managed across its entire life cycle in the EU.

Businesses that take a proactive, structured approach now will be better positioned to:

Reduce compliance risk
Avoid last-minute redesigns
Strengthen sustainability credentials

Those who delay may face significant operational disruption and increased costs as deadlines approach.

SGS solutions

Navigating PPWR requirements can be complex, with new expectations across design, testing and documentation. We support manufacturers and suppliers with a range of testing, inspection and certification services to ensure packaging is both compliant and sustainable.

Our services cover primary, secondary and transport packaging, including:

Performance testing under transportation conditions
Physical and chemical material testing
Specialist food contact and PFAS testing
Recyclability and sustainability assessments
Labeling and traceability verification

We cover materials like paper, paperboard, corrugated, rigid plastics, textiles, glass, ceramics and more, helping businesses turn PPWR requirements into practical solutions. In the end, it’s only trusted because it’s tested.

More about SGS packaging services

IMPACT NOW

IMPACT NOW for sustainability consolidates our sustainability offerings under four strategic pillars: climate, nature, ESG assurance and circularity. Through these pillars, we offer trusted compliance solutions that directly help businesses address the key environmental and social challenges impacting the planet. Find out more at www.sgs.com/impactnow