1. PPWR Is Here: Exporting Packaged Goods to the EU — Pass This Check First

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) entered into force on 11 February 2025 and will apply in full across the entire EU from 12 August 2026. Unlike the older Directive 94/62/EC, the PPWR is a directly applicable "Regulation" — it no longer needs to be transposed into national law by each Member State, but applies uniformly to all 27 Member States in a single step. As soon as a product enters the EU market with packaging, regardless of industry, material, or sales channel, the packaging itself becomes an independent compliance object.

Electrical & electronics, chemicals, consumer goods, textiles, food-contact materials, industrial products… no product category’s packaging is exempt.

Backed by CMA- and CNAS-accredited testing laboratories and years of cross-border compliance experience, CIRS Testing provides end-to-end PPWR compliance services for companies exporting to the EU — from regulatory interpretation → packaging testing → recyclability / reusability assessment → technical documentation and EU Declaration of Conformity (DoC) → EPR registration and reporting.

2. What Packaging Does the PPWR Cover?

The PPWR’s scope is very broad — all packaging and packaging waste on the EU market is covered, regardless of material, industry, or product category. By purpose it falls into four categories:

Sales / Primary packaging: in direct contact with the product and facing the end user, e.g. beverage cans, toothpaste tubes.

Grouped / Secondary packaging: groups multiple sales units together, e.g. the shrink film around a six-pack.

Transport packaging: used for logistics handling and protection, e.g. corrugated boxes, stretch film, pallets, strapping.

Service packaging: filled at the point of sale, e.g. takeaway containers, coffee cups.

Tip: Transport and B2B industrial packaging (pallets, stretch film, cushioning materials, etc.) is equally within the PPWR’s scope and must be assessed separately; however, the containers used in road, rail, sea, and air transport themselves are excluded — materials used inside containers to secure and protect products may still be covered.

3. First, Identify Your Role: Manufacturer, Importer, or Producer?

The PPWR splits compliance responsibilities across three types of entities based on the role the packaging plays in its circulation within the EU. The first step in compliance is figuring out "who am I".

Special reminder: In the PPWR context, "manufacturer" and "producer" are two different concepts. The manufacturer focuses on "compliance of the packaging itself", while the producer focuses on "waste management and EPR". A given packaging usually corresponds to only one manufacturer in the EU, but may correspond to multiple producers when sold in different Member States.

Note: Where a brand owner commissions a contract manufacturer for filling / production, as long as the packaging is marketed under the brand owner’s name / trademark and the brand owner determines the packaging specifications, the brand owner is generally regarded as the "manufacturer" under the PPWR — conformity assessment and DoC responsibilities follow.

4. From 12 August 2026, Prioritize These Five Tasks

The PPWR enters into force in phases. For companies intending to continue shipping to the EU after 12 August 2026, the following obligations should be prioritized:

Substance-of-concern limits and testing — All packaging must meet limit requirements for substances of concern such as heavy metals; food-contact packaging must additionally meet PFAS restrictions and have test reports ready.

Recyclability — From 12 August 2026, all packaging placed on the EU market must be recyclable. Before the EU’s official grading method is finalized, companies may first carry out assessments with reference to the relevant harmonized standards.

Reusability — For packaging claimed or designed to be reusable, the manufacturer must ensure it meets the regulatory requirements and conduct conformity assessment with reference to harmonized standards.

Conformity assessment and DoC — Before placing packaging on the market, the manufacturer must carry out conformity assessment item by item against the legal requirements already in force and prepare the EU Declaration of Conformity (DoC), together with the retained technical documentation.

EPR registration and data reporting — Based on country of sale, sales model, and supply-chain arrangements, confirm whether packaging EPR registration, authorized-representative appointment, data reporting, and fee payment need to be completed in the relevant Member States. For cross-border e-commerce, DTC brands, and multi-country sellers, the EPR registration number is often the first compliance credential demanded by platforms, customers, and regulators.

5. PPWR Key Timeline

Reduction targets: The Regulation also sets overall targets for reducing packaging waste: 5% by 2030, 10% by 2035, and 15% by 2040.

6. CIRS Group CIRS Testing — PPWR Compliance Service Content

7. Why Choose CIRS Testing?

CMA + CNAS dual-accreditation laboratory — test reports "carry weight by default".

This is CIRS Testing’s core advantage over pure consulting firms. We operate a third-party testing laboratory with CMA and CNAS accreditation; heavy-metal and PFAS tests are completed in-house with reports issued by us — data is traceable, and reports can be used directly as supporting material for PPWR compliance and technical documentation, closing the loop between test data and compliance determination under one roof.

Integrated testing + compliance + EPR.

From packaging testing and recyclability assessment to DoC preparation and EPR registration and reporting, enterprises complete the full "assess → evidence → document → comply" workflow within a single service framework, substantially cutting the cost and time of coordinating multiple parties.

CIRS Group’s cross-border compliance heritage.

Drawing on CIRS Group’s more than a decade of experience in EU chemical and product compliance services, serving 3,000+ cross-border enterprises and maintaining long-term cooperation with mainstream e-commerce platforms, CIRS is familiar with the packaging compliance priorities and high-frequency risk points across categories such as electrical & electronics, consumer goods, food contact, cosmetics, and chemicals.

Dual perspective on "product compliance" and "EPR fulfillment".

Help enterprises clarify the responsibility boundaries among manufacturers, importers, and producers, and build an integrated solution covering both product compliance and waste fulfillment.

Continuous tracking of regulatory developments.

Continuously track EU legislative progress, helping enterprises proactively adjust packaging design, testing arrangements, and documentation strategy as the regulation evolves.

8. Contact Us

Full implementation of the PPWR is imminent. Packaging compliance should not be left until a customer or platform demands documents — establishing your packaging inventory, supply-chain data, and technical documentation system early is the lowest-cost, lowest-risk path.

CIRS Testing

📞 Hotline: +86 571-87206587

✉️ Email: test@cirs-group.com

🌐 Website: www.cirs-testing.com

For PPWR testing or compliance support, feel free to contact us at test@cirs-group.com, or scan the QR code below to reach us via WhatsApp.