PPWR Officially Takes Effect: Chemical Export Enterprises Please Note

On August 12, 2026, the EU PPWR (Packaging and Packaging Waste Regulation) officially took effect. This means that almost all products exported to the EU, if packaged, will be affected by the regulation. Therefore, all chemical enterprises exporting to the EU need to review the packaging of their core products in accordance with the regulation, so as to avoid obstacles to EU trade caused by non-compliance. Below are the most critical points that chemical enterprises should prioritize:

1. Who is the packaging manufacturer?

According to the latest PPWR Q&A document, if the packaging does not bear a 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 the name or trademark belongs is the manufacturer.

2. What tests are required?

Under Article 5 of the PPWR, in each homogeneous material of all packaging (e.g., plastics, coatings, etc.), the total content of lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr⁶⁺) must not exceed 100 ppm. If the packaging is intended for food contact, it must be ensured that the PFAS content does not exceed the limit, so PFAS content also needs to be tested (total fluorine may be considered).

3. What documents do enterprises need to prepare?

The most essential documents include the Declaration of Conformity (DoC) and the technical documentation. The DoC is issued by the packaging manufacturer and mainly includes:

1. Document number (unique packaging identifier);
2. Packaging type and description information;
3. Manufacturer information or information on the manufacturer's authorized representative;
4. A statement of conformity with Regulation (EU) 2025/40, i.e., the PPWR;
5. References to the harmonized standards or common specifications used, or other technical specifications referenced in the declaration of conformity;
6. Signature details: place and date of issue; name, position; signature.

The technical documentation is not just a test report, but a complete set of descriptive materials, including the packaging description and intended use, the conceptual design and materials of the packaging, harmonized standards, common specifications and technical specifications, test reports, and a qualitative explanation of how compliance with Articles 6, 10 (not yet initiated), and 11 of the PPWR is assessed.

4. Do enterprises need EPR registration?

EPR obligations are obligations of producers, so it is particularly important to determine who is the producer in the supply chain. For most chemical enterprises exporting to the EU, the usual trade scenarios are the following two:

1. Enterprises sell through EU importers: Since the enterprise does not directly place the product on the market and does not meet the producer definition, the EU importer is generally responsible for fulfilling the relevant EPR obligations.
2. Enterprises supply directly to an EU factory: This depends on whether the EU factory meets the definition of end user. If it does, the enterprise meets the producer definition and can generally handle the obligations itself. If it does not meet the end-user definition, then according to the PPWR producer definition, the EU factory is the producer and needs to address the EPR obligations.

5. My product is dangerous goods — can packaging obligations be exempted?

According to the PPWR, packaging for dangerous goods is exempt only from the recyclability requirements of Article 6, the minimum recycled content requirements for plastic packaging of Article 7, and the quantitative reuse targets of Article 29. Other obligations — such as heavy metal testing, DoC, technical documentation, and EPR registration — cannot be exempted.

6. Do pallets, strapping bands, and stretch film used during transport need to comply with the PPWR?

Pallets, strapping bands, and stretch film are also part of the packaging. They are exempt only from the reuse target requirements, so they must also comply with most other relevant PPWR obligations.

At present, chemical enterprises that have not yet addressed the PPWR should act as soon as possible: conduct self-inspection and testing of packaging, clearly determine who is the manufacturer and who is the producer, possibly initiate EPR registration if needed, and then prepare the most essential DoC and technical documentation. Only with these documents in place can packaging be ensured to meet PPWR requirements.

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