How Exactly Will the EU PPWR Be Enforced? — Official Answers to 11 Frequently Asked Questions

The EU Packaging and Packaging Waste Regulation (PPWR) becomes generally applicable from August 12, 2026. To address some hot-button issues, CIRS Group has compiled the official FAQ content released by the EU, covering whether packaging from companies will be affected after the deadline, who handles EPR, PFAS testing, and other questions, for your reference.

1. If packaging does not comply with the rules applicable from August 12, 2026, will the products be prohibited from entering the EU market?

No. Enforcement of the obligations applicable from August 12, 2026 should not disrupt trade flows, supply chains, or consumer access to goods. Under Article 62 of the PPWR, if a Member State becomes aware of any instance of non-compliance set out in that Article, it must first require the relevant economic operator to bring such non-compliance to an end. In other words, the economic operator should first receive a warning about the identified non-compliance and have the opportunity to take corrective action before the Member State can take any other action. Only if the economic operator does not correct the non-compliance and instead continues the non-compliant behavior does the Member State have the right to take further action (such as prohibiting, recalling, or withdrawing the non-compliant packaging).

2. How should packaging that was produced or stocked before August 12, 2026 but not yet placed on the market by that date be handled? Are operators obliged to destroy, remanufacture, or relabel it?

Packaging that has not been placed on the market before August 12, 2026 but has already been produced and is in stock does not need to be destroyed, remanufactured, or relabeled. To meet the requirements of Article 15(5) and 15(6) that packaging bear a unique identifier and the manufacturer's name and address, the required information may be provided through accompanying documents. The same applies to reusable packaging already placed on the market. However, for packaging manufactured after August 12, 2026, accompanying documents may only be used where it is not possible to affix the unique identifier and the name and address directly to the packaging.

3. Who needs to fulfill EPR obligations?

Under the PPWR, EPR obligations need to be addressed by producers:

1. E-commerce platforms: Online platforms that allow consumers to conclude distance contracts with producers must obtain from the producer information confirming that the producer is registered in the EPR register of the Member State where the consumer resides, as well as a self-certification confirming that the producer's packaging EPR obligations have been fulfilled. The online platform must obtain this information before allowing the producer to use the platform's services. In other words, sellers on e-commerce platforms need to fulfill EPR obligations.
2. Chinese companies selling through EU importers: Since Chinese companies do not place products directly on the market, the relevant EPR obligations are typically fulfilled by the EU importer.
3. Chinese companies supplying directly to EU factories: This depends on whether the EU factory meets the definition of "end user." If it does, then the Chinese company meets the definition of "producer" and is generally responsible for compliance. If it does not meet the definition of "end user," then under the PPWR's definition of "producer," the EU factory qualifies as the producer and must address the EPR obligations.

4. Who is the manufacturer of packaging?

If the packaging bears no name or trademark, the decisive criterion for determining the manufacturer is who placed the order and decided the design specifications of the packaging. For unbranded packaging, this is usually the company that actually manufactures the packaging. If the packaging bears a name or trademark, the company to which that name or trademark belongs is the manufacturer.

5. How can manufacturers demonstrate compliance with Article 5(4) on limit values for heavy metals in packaging?

Manufacturers were already required to comply with this obligation under Article 11 of the repealed Packaging and Packaging Waste Directive. To demonstrate compliance, it is recommended to use CEN report CR 13695-1/2000 — "Packaging — Requirements for measuring and verifying the four heavy metals and other dangerous substances present in packaging and their release into the environment — Part 1: Requirements for measuring and verifying the four heavy metals present in packaging."

6. Given that there is no harmonized method at EU level for PFAS in food contact packaging, how will PFAS limit values be enforced?

According to the Commission's guidance document, the Commission is working to ensure that national market surveillance authorities adopt a harmonized approach to enforcing PFAS limit values. Industrial stakeholders, civil society groups, and Member State authorities are working intensively to deliver a harmonized testing protocol for PFAS in food contact packaging. This workstream includes collaboration with the EU Reference Laboratory for Food Contact Materials (EURL-FCM), which coordinates the network of national reference laboratories for food contact materials.

7. Since the starting point for enforcing PFAS limit values appears to be total fluorine analysis, which laboratories offer such testing methods?

A substantial number of commercial and university laboratories already offer total fluorine/total organic fluorine analysis. It can be expected that, given the PPWR PFAS limit values, many other commercial and accredited laboratories will invest in testing capacity, and those already offering such services will expand their capabilities.

8. In practice, does the requirement of Article 15(5) mean that every individual packaging unit must be traceable?

Article 15(5) requires packaging to bear information that makes it uniquely identifiable, such as a serial number, batch number, or other equivalent elements. The purpose of this provision is to facilitate the traceability of packaging placed on the market for conformity verification and market surveillance purposes — even if the packaging can be identified (e.g., by packaging type, model, or production batch), thereby allowing it to be linked to the relevant technical documentation and declaration of conformity.

The Regulation does not require every component of a packaging unit to be individually marked for traceability purposes. For example, for a yogurt cup consisting of a plastic cup, lid, and sleeve or label, it should be sufficient for the required information to appear on just one component of the sales packaging.

Furthermore, if the size or nature of the packaging does not allow the identifier to be placed on the packaging itself, Article 15(5) permits the information to be provided in documents accompanying the packaged product.

9. Should the conformity assessment be drafted for each individual part of the packaging (e.g., bottle, closure, and label), or for the entire packaging unit?

The conformity assessment must be carried out for the entire packaging unit, and the declaration of conformity must also be drawn up for the entire packaging unit. In other words, for a packaging unit consisting of a bottle, closure, and label, one conformity assessment and one associated declaration of conformity for the unit as a whole is sufficient, provided that the declaration includes relevant information on all the individual components used to make up the unit.

10. If packaging is made of the same material but in different sizes, is it necessary to draw up declarations of conformity for all sizes, or is one declaration for all sizes sufficient?

According to Annex VII, the manufacturer should draw up a written declaration of conformity for each packaging type. The declaration of conformity drawn up should correspond to the packaging in question. The documentation should make it possible to assess whether the packaging complies with the sustainability requirements set out in Articles 5–12. The technical documentation must list the applicable requirements and, to the extent relevant for the assessment, cover the design, manufacture, use, and operation of the packaging. Therefore, the declaration of conformity should be drawn up at the level at which the packaging has the same characteristics with respect to the applicable requirements and the packaged product. Accordingly, if products differ, the manufacturer should not draw up a single declaration of conformity for all packaging placed on the market. Specifically, if bottles differ in size but contain the same product, and the size difference does not affect compliance with any of the requirements in Articles 5–12, the manufacturer may draw up a single declaration of conformity for those bottles. Manufacturers must ensure that their range of packaging complies with the Regulation. They must consider whether changes in packaging design or characteristics, as well as changes in harmonised standards or other rules for declaring and verifying conformity, require a re-assessment.

11. How should the Declaration of Conformity (DoC) for packaging be drafted?

The packaging Declaration of Conformity is a statutory self-declaration document issued by the company, certifying that the packaging complies with Articles 5–12 of the PPWR (at present, primarily Articles 5, 6, and 11 first). The specific contents include:

1. Document number (unique identifier of the packaging);
2. Packaging type and descriptive information;
3. Manufacturer information or information on the manufacturer's authorized representative;
4. A statement declaring conformity with Regulation (EU) 2025/40, i.e., the PPWR;
5. References to the harmonised standards or common specifications used, or references to other technical specifications under which conformity is declared;
6. Signature information: place and date of issue; name, function/title; signature.

Why choose CIRS Group — CIRS Testing for EU Packaging Regulation PPWR compliance?

One-stop services covering Testing + Compliance + EPR Registration + Authorized Representative (AR), with globally leading technical capabilities and service scope.

The PPWR compliance chain is long and involves many links. Companies often have to coordinate back and forth between testing institutions, compliance consulting firms, and EPR service providers, resulting in low efficiency and information gaps. CIRS Testing has integrated the entire chain — one team takes full responsibility throughout:

With 19 years of regulatory expertise, CIRS Group is trusted by 50,000+ companies

The PPWR is not an isolated regulation — it is deeply interconnected with REACH, CLP, the Food Contact Materials Regulation (EU) No 10/2011, the Single-Use Plastics Directive (SUPD), and others. CIRS Group has been deeply engaged in EU regulations for 19 years, serving more than 50,000 domestic and international companies, including over 60 Fortune Global 500 companies.

CIRS Testing has a dedicated regulatory tracking team that continuously monitors updates from the European Commission, ECHA, CEN, and other official bodies, providing companies with timely interpretation of new regulatory changes and compliance impact assessments to ensure that compliance solutions do not become invalid due to regulatory iterations.

August 12 is not an endpoint, but the starting point of a long compliance journey. CIRS Testing offers you end-to-end PPWR compliance services that stand up to EU scrutiny — from testing to registration, from technical documentation to regulatory tracking.