Check yourself now!New EU packaging regulations take effect today, and export compliance to Europe i
- Author:Maintenance network
- Source:Maintenance network
- Release Date:2026-08-13
Starting from August 12, the EU's Packaging and Packaging Waste Regulations (PPWR, Regulation (EU) 2025/40) officially entered the comprehensive application stage.This means that the packaging supervision in the European market has shifted from being mainly based on the rules of each member state and the EPR system to a unified regulatory framework covering packaging materials, chemical substances, compliance documents, recycling design and producer responsibility.It should be noted that PPWR did not “come into effect” until August 12.The regulation was officially adopted on December 19, 2024, published in the Official Journal of the European Union on January 22, 2025, and came into effect on February 11, 2025. However, Article 71 of the regulation stipulates that its general application date is August 12, 2026.01Which requirements actually enter the implementation stage?
Not all requirements of PPWR will be implemented at once on August 12, but will be implemented in stages.Among them, the ones that will have a greater impact on cross-border e-commerce, overseas warehouses and packaging supply chains in the near future are PFAS restrictions on food contact packaging, requirements for hazardous substances in packaging, and manufacturer compliance document systems.Article 5 of the regulations stipulates that the total concentration of lead, cadmium, mercury and hexavalent chromium in packaging and its components must not exceed 100 mg/kg.This requirement applies to packaging and packaging components, and together with EU REACH and food contact materials related regulations, constitute chemical substance compliance requirements.Of greater concern are PFAS.From August 12, 2026, food contact packaging will not be placed on the EU market if it meets or exceeds the following limits: Single PFAS: 25 ppb Total PFAS: 250 ppb Total fluorine: The regulations also set a corresponding 50 ppm limit. Therefore, packaging materials that were easily ignored in the past, such as cartons, food bags, greaseproof paper, and take-out packaging, have begun to enter the more stringent chemical substance compliance scope.DoC is not "one more certificate". Another important change in PPWR is to further extend packaging compliance from simple EPR registration to conformity evaluation and technical documents.According to Articles 15, 38, and 39 of the regulations, after the manufacturer proves that the packaging meets the relevant requirements, it needs to issue an EU Declaration of Conformity (EU Declaration of Conformity) and establish corresponding technical documents.In principle, the relevant technical documents and declaration of conformity of disposable packaging need to be kept for 5 years, and for reusable packaging, 10 years.Importers also need to confirm that the manufacturer has completed the corresponding conformity evaluation and prepared technical documents before putting it on the market.This means that in the future, packaging compliance in the European market is no longer just a matter of "whether there is an EPR number", but will gradually form a complete chain of: packaging materials → supplier data → testing/evaluation → technical documents → DoC → EPR responsibility → market launch.For Chinese export companies, the real difficulty has shifted from “registration” to whether supply chain data can be closed-loop.
02EPR is not “registered once and used throughout Europe”
PPWR also further unifies producer responsibility.Article 44 of the regulations clarifies that in principle, producers need to complete corresponding registration in each member country where they provide packaging or packaged goods for the first time; if the producer or its authorized representative fails to complete the registration as required, it shall not place the relevant packaged or packaged goods in that member state for the first time.This is particularly noteworthy for cross-border e-commerce.PPWR has not established a "unified European EPR number" similar to VAT IOSS.Member states still need to establish their own producer registration systems, and specific implementation procedures, declarations and fees still involve national competent authorities and their own EPR systems.At the same time, the regulations provide for authorized representatives in cross-border sales: in some cases, producers need to designate EPR authorized representatives in the member states where consumers are located; for third-country producers, member states can stipulate that authorized representatives must be designated.Therefore, the statement that "Chinese sellers must automatically hire a unified authorized representative covering the entire EU" is not rigorous, and the specific obligations still need to be judged based on the seller's establishment location, sales model, and member states' implementation rules.This is also the most easily interpreted part of PPWR on the market today.
03The real “big change” will still be in 2030
August 12 is not the end of PPWR, but more like the starting point of the entire regulatory cycle.The European Commission clearly stated that the general application date of PPWR is August 12, 2026, but a large number of structural requirements will be gradually implemented in the following years.For example: 2028: A unified labeling system for packaging will be gradually implemented to help consumers identify packaging materials and classify them for recycling.2030: Requirements such as recyclable packaging, packaging minimization, and restrictions on some disposable packaging will enter a more important stage.One of the regulations directly related to cross-border e-commerce is that Article 24 of the PPWR requires that by January 1, 2030 or 3 years after the relevant implementation law takes effect (whichever is later), the maximum proportion of empty space for e-commerce packaging, transportation packaging and combination packaging shall in principle not exceed 50%.The European Commission still needs to further clarify the calculation method through implementing law.In addition, the field of transportation packaging will also be significantly affected.Article 29 of the PPWR stipulates that from 2030 onwards, at least 40% of the transport packaging used by relevant economic operators should be reusable packaging systems; the target is further increased to 70% in 2040.This requirement covers some transportation packaging including e-commerce transportation scenarios.This means that not only the seller’s cartons and plastic bags will be affected in the future, but also the packaging operations of overseas warehouses, in-warehouse packaging changes, trunk transportation packaging, and last-mile delivery methods may all be redesigned.
04Supply chain management issues
This is also where PPWR deserves the attention of China’s shipping, logistics and cross-border industries.The European Commission disclosed that the current average per capita in the EU is about 180 kilograms of packaging waste per year.Reuters reported on August 11 that packaging accounts for about 40% of plastic consumption in the EU, and the recycling rate of plastic packaging waste derived from fossil fuels in the EU in 2023 will be about 42%.Therefore, the policy direction of PPWR is not to simply add a new registration project, but to promote the transformation of packaging from "low-value consumables" to a compliance object in the supply chain.For Chinese export companies, a more obvious trend may emerge in the future: the fact that the goods themselves meet the requirements does not mean that the entire supply chain of the goods has completed compliance.Packaging material source, composition, weight, testing data, supplier certification, EPR registration, authorized representative and technical documents may all become compliance data in cross-border business.For overseas warehouses, this means that the warehousing process may also extend from simple "inventory and delivery" to packaging replacement, packaging data management and compliance document collaboration.However, August 12 does not mean that all non-compliant packaging will be immediately detained by customs or stopped from sale.The European Commission recently emphasized that member states need to take measures based on risks and specific circumstances during the actual enforcement process; Reuters reported on August 11 that the EU also stated that it would not always take the most severe measures against non-compliant products immediately, and member states may first take warnings and other methods to give companies an opportunity to rectify.
Not all requirements of PPWR will be implemented at once on August 12, but will be implemented in stages.Among them, the ones that will have a greater impact on cross-border e-commerce, overseas warehouses and packaging supply chains in the near future are PFAS restrictions on food contact packaging, requirements for hazardous substances in packaging, and manufacturer compliance document systems.Article 5 of the regulations stipulates that the total concentration of lead, cadmium, mercury and hexavalent chromium in packaging and its components must not exceed 100 mg/kg.This requirement applies to packaging and packaging components, and together with EU REACH and food contact materials related regulations, constitute chemical substance compliance requirements.Of greater concern are PFAS.From August 12, 2026, food contact packaging will not be placed on the EU market if it meets or exceeds the following limits: Single PFAS: 25 ppb Total PFAS: 250 ppb Total fluorine: The regulations also set a corresponding 50 ppm limit. Therefore, packaging materials that were easily ignored in the past, such as cartons, food bags, greaseproof paper, and take-out packaging, have begun to enter the more stringent chemical substance compliance scope.DoC is not "one more certificate". Another important change in PPWR is to further extend packaging compliance from simple EPR registration to conformity evaluation and technical documents.According to Articles 15, 38, and 39 of the regulations, after the manufacturer proves that the packaging meets the relevant requirements, it needs to issue an EU Declaration of Conformity (EU Declaration of Conformity) and establish corresponding technical documents.In principle, the relevant technical documents and declaration of conformity of disposable packaging need to be kept for 5 years, and for reusable packaging, 10 years.Importers also need to confirm that the manufacturer has completed the corresponding conformity evaluation and prepared technical documents before putting it on the market.This means that in the future, packaging compliance in the European market is no longer just a matter of "whether there is an EPR number", but will gradually form a complete chain of: packaging materials → supplier data → testing/evaluation → technical documents → DoC → EPR responsibility → market launch.For Chinese export companies, the real difficulty has shifted from “registration” to whether supply chain data can be closed-loop.
02EPR is not “registered once and used throughout Europe”
PPWR also further unifies producer responsibility.Article 44 of the regulations clarifies that in principle, producers need to complete corresponding registration in each member country where they provide packaging or packaged goods for the first time; if the producer or its authorized representative fails to complete the registration as required, it shall not place the relevant packaged or packaged goods in that member state for the first time.This is particularly noteworthy for cross-border e-commerce.PPWR has not established a "unified European EPR number" similar to VAT IOSS.Member states still need to establish their own producer registration systems, and specific implementation procedures, declarations and fees still involve national competent authorities and their own EPR systems.At the same time, the regulations provide for authorized representatives in cross-border sales: in some cases, producers need to designate EPR authorized representatives in the member states where consumers are located; for third-country producers, member states can stipulate that authorized representatives must be designated.Therefore, the statement that "Chinese sellers must automatically hire a unified authorized representative covering the entire EU" is not rigorous, and the specific obligations still need to be judged based on the seller's establishment location, sales model, and member states' implementation rules.This is also the most easily interpreted part of PPWR on the market today.
03The real “big change” will still be in 2030
August 12 is not the end of PPWR, but more like the starting point of the entire regulatory cycle.The European Commission clearly stated that the general application date of PPWR is August 12, 2026, but a large number of structural requirements will be gradually implemented in the following years.For example: 2028: A unified labeling system for packaging will be gradually implemented to help consumers identify packaging materials and classify them for recycling.2030: Requirements such as recyclable packaging, packaging minimization, and restrictions on some disposable packaging will enter a more important stage.One of the regulations directly related to cross-border e-commerce is that Article 24 of the PPWR requires that by January 1, 2030 or 3 years after the relevant implementation law takes effect (whichever is later), the maximum proportion of empty space for e-commerce packaging, transportation packaging and combination packaging shall in principle not exceed 50%.The European Commission still needs to further clarify the calculation method through implementing law.In addition, the field of transportation packaging will also be significantly affected.Article 29 of the PPWR stipulates that from 2030 onwards, at least 40% of the transport packaging used by relevant economic operators should be reusable packaging systems; the target is further increased to 70% in 2040.This requirement covers some transportation packaging including e-commerce transportation scenarios.This means that not only the seller’s cartons and plastic bags will be affected in the future, but also the packaging operations of overseas warehouses, in-warehouse packaging changes, trunk transportation packaging, and last-mile delivery methods may all be redesigned.
04Supply chain management issues
This is also where PPWR deserves the attention of China’s shipping, logistics and cross-border industries.The European Commission disclosed that the current average per capita in the EU is about 180 kilograms of packaging waste per year.Reuters reported on August 11 that packaging accounts for about 40% of plastic consumption in the EU, and the recycling rate of plastic packaging waste derived from fossil fuels in the EU in 2023 will be about 42%.Therefore, the policy direction of PPWR is not to simply add a new registration project, but to promote the transformation of packaging from "low-value consumables" to a compliance object in the supply chain.For Chinese export companies, a more obvious trend may emerge in the future: the fact that the goods themselves meet the requirements does not mean that the entire supply chain of the goods has completed compliance.Packaging material source, composition, weight, testing data, supplier certification, EPR registration, authorized representative and technical documents may all become compliance data in cross-border business.For overseas warehouses, this means that the warehousing process may also extend from simple "inventory and delivery" to packaging replacement, packaging data management and compliance document collaboration.However, August 12 does not mean that all non-compliant packaging will be immediately detained by customs or stopped from sale.The European Commission recently emphasized that member states need to take measures based on risks and specific circumstances during the actual enforcement process; Reuters reported on August 11 that the EU also stated that it would not always take the most severe measures against non-compliant products immediately, and member states may first take warnings and other methods to give companies an opportunity to rectify.