EU PPWR Requirements & Compliance Solution

PPWR, Explained Simply

A short, plain-language guide to Europe's new packaging law, and what to do about it.

What is PPWR, in one paragraph?

The EU has a new law about packaging: the Packaging and Packaging Waste Regulation, PPWR for short. It says that any packaging sold in the EU must be safe, honest, and recyclable. Not the product, the packaging: the bottle, the box, the film, the label, the pallet wrap. It applies everywhere in the EU at once, with no local variations, and it applies to you even if your company is not in Europe. If your package crosses the EU border, the rules travel with it.

Does this apply to me?

One question decides it: does any packaging you make, fill, import, or sell end up on the EU market? That includes online sales shipped into the EU. If yes, PPWR applies to you. If no, you can stop reading, though the first deadline is close enough that future EU plans deserve attention now.

The dates that matter
Date	What happens
12 August 2026	• Meet the chemical limits: heavy metals capped, PFAS restricted in food contact packaging • Register for EPR in each EU country where you sell • Prepare a technical file (Annex VII) and sign a Declaration of Conformity (Annex VIII) • Show in that file that your packaging meets the applicable design requirements, such as recyclability, minimization, and reusability (if declared reusable), demonstrated through harmonized standards or recognized guidelines
12 August 2028	New EU-wide labels become mandatory, showing what the packaging is made of.
1 January 2030	Recyclability grades arrive: packaging below Grade C is banned. Plastic packaging needs minimum recycled content. Oversized and some single-use plastic packaging is banned.
2038 to 2040	The bar rises again: Grade B recyclability, higher recycled content targets.
_{Rule of thumb: chemicals and paperwork first (2026), labels next (2028), design and content rules after (2030).}

The rules in plain words, and how we help
The rule	In plain words	How Bureau Veritas helps
Know your role	Are you the maker, the importer, the seller? Each role carries duties, and one company often holds several at once.	We map your role and duties across your supply chain and train your team, so you focus effort where it matters and reduce wasted spend.
Safe chemicals	Four heavy metals capped at 100 ppm combined. PFAS (the 'forever chemicals') limited in food packaging. Other restricted chemicals apply too.	We test your packaging in our labs: heavy metals, restricted substances, and a tiered fluorine check, total fluorine first and deeper PFAS analysis only if needed, so compliance evidence is ready when customers or authorities ask.
Paperwork	You must test your own packaging, write a technical file, sign a Declaration of Conformity, and register for EPR in every EU country where you sell.	We create or review your technical file and DoC, register you for EPR, and guide non-EU sellers on representatives, reducing compliance risk and the burden on your team.
Honest labels	From 2028, every package needs a standard EU label showing what it is made of, so shoppers can sort it for recycling.	We check your labels against the EU specifications before you print, reducing the risk of non-compliant artwork and reprints.
Recyclable design	From 2030, packaging must actually be recyclable, graded A, B, or C. Below C means banned from the market.	We support your self-assessment now (EN 13430), evaluate your grade early, and advise on design changes while they are less costly.
Recycled content	From 2030, plastic packaging must contain a minimum share of recycled plastic, 10 to 35% depending on type.	We test the recycled share and certify it (GRS, RCS, ISCC), or verify claims per ISO 14021, proof your buyers and regulators can trust.
No waste, no tricks	Packaging must be as small and light as possible. False bottoms, useless layers, and half-empty boxes are out. Some single-use plastics are banned.	We assess your designs, run ISTA transport simulation tests, and verify reuse systems, giving you technical evidence for minimization and reuse, and confidence that lighter or higher-recycled designs still protect your product.

What happens if I ignore it?

Market exclusion. Packaging that fails the rules cannot be sold in the EU, and unregistered producers cannot sell at all. Customs and market surveillance authorities can check the paperwork, and retailers increasingly ask for it before they stock you. Non-compliance is not a fine you pay and move on; it is a door that closes.

Where do I start?

Find your role. Maker, importer, producer, or distributor. Your duties follow your role, and most companies hold more than one.
Test your packaging now. Heavy metals, restricted substances, and PFAS for food packaging. The August 2026 deadline comes first, and lab testing takes weeks, so start early.
Get the paperwork moving. Technical file, Declaration of Conformity, EPR registration in each country where you sell.
Look ahead to 2030. Check your recyclability grade and recycled content early, while design changes are still cheap.

Term	What it means
PPWR	Packaging and Packaging Waste Regulation (EU 2025/40). The law this guide explains.
REACH / SVHC	The EU's chemical rulebook. PPWR points to its Annex XVII restrictions and to the EU food contact rules.
PFAS	'Forever chemicals' used for grease and water resistance. Now strictly limited in food packaging.
EPR	Extended Producer Responsibility. You register in each EU country, report your packaging volumes yearly, and pay fees that fund recycling.
DoC	Declaration of Conformity. A signed statement that your packaging follows the rules.
Technical file (TD)	The evidence folder behind the DoC: designs, materials, test reports. Kept 5 to 10 years.
Module A	The self-assessment procedure. You check your own packaging; the market surveillance authorities check you.
Grade A / B / C	Recyclability scores, applied from 2030 (C is the entry ticket; B from 2038). Recyclability itself is required from August 2026.
PCR	Post-consumer recycled plastic. Recycled content targets count only this, not factory scrap.
GRS / RCS / ISCC	Certification schemes that prove recycled content claims are real.
Authorized representative	An EU-based partner who handles duties for sellers outside the EU. Mandatory for non-EU distance sellers under EPR.
Delegated act	Follow-up EU legislation filling in the details. Several land through 2027 and 2028, so the rules keep sharpening.

_{This guide is a simplified summary for orientation only and is not legal advice. Always check the regulation text (EU 2025/40) and official EU guidance for the full requirements.}

Not sure where your packaging stands?

Start with a gap analysis. We map your portfolio against every PPWR deadline and hand you a plan.

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EU PPWR SOLUTION