The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), will become mandatorily applicable across the entire EU from August 12, 2026, replacing the 94/62/EC Directive that has been in force for nearly 30 years. PPWR is upgraded into a directly applicable regulation and it imposes full-chain requirements on all packaging placed on the EU market, including:
- hazardous substance limits,
- design for recyclability,
- recycled-content ratios,
- packaging minimization,
- Extended Producer Responsibility (EPR), and
- Declarations of Conformity (DoC).
Non-compliant products will face delisting, fines, and customs detention.
As a third-party testing institution with both CMA and CNAS accreditations, CIRS Testing leverages the CIRS Group's global compliance network to provide one-stop PPWR packaging testing and compliance services for companies exporting medical devices, toys and children's products, electronics and electrical appliances, food contact materials, textiles, footwear and bags, jewelry, daily chemicals, and packaging materials to the EU.
Scope of CIRS Testing's PPWR Compliance Services
CIRS Testing provides a complete closed-loop service — from packaging testing to compliance implementation — built around the mandatory PPWR requirements:
(1) Hazardous Substances Testing for Packaging
Covers all packaging components including outer cartons, inner linings, labels, printing inks, sealing adhesives, cushioning foam, shrink-wrap bags, and pallets.
- Testing of the total concentration of four heavy metals — lead, cadmium, mercury, and hexavalent chromium — at ≤ 100 mg/kg (PPWR Article 5);
- PFAS screening for food-contact packaging.
(2) Packaging Recyclability Assessment
Provides recyclability grading (A/B/C) assessments and material upgrade recommendations for non-contact packaging in accordance with PPWR Article 6 and the upcoming design-for-recyclability standards (to be published in 2028)
(3) Packaging Material Safety Testing
For contact-sensitive packaging (e.g., sterile barrier systems for medical devices), material safety and leachables testing is conducted according to standards such as ISO 11607, GB 4806, and EU 10/2011.
(4) PPWR Compliance Closed-Loop Services
Through CIRS Group's global branch offices in Europe, Japan, and other regions, CIRS Testing provides a comprehensive suite of compliance services, including:
- Target-country Extended Producer Responsibility (EPR) registration and annual reporting.
- Appointment of an EU Authorized Representative (EC REP).
- Issuance of tDeclaration of Conformity (DoC) and compilation of required technical documentation.
- REACH compliance and Safety Data Sheet (SDS) authoring.
Why Choose CIRS Testing for PPWR
(1) CMA and CNAS Accreditations — Authoritative and Traceable Reports
CIRS Testing has obtained national- and provincial-level CMA qualifications and CNAS accreditation. Testing report data is traceable and is widely accepted by the EU market, e-commerce platforms, and customs authorities, providing authoritative underlying support for the PPWR Declaration of Conformity.
(2) Six Laboratories — Full Coverage of Packaging Hazardous Substances
With six testing laboratories — Physical, Chemical, Toxicological (in-vivo), Efficacy, Microbiological (P2), and In-vitro Alternative — CIRS Testing can complete multiple testing items under the PPWR framework (heavy metals, PFAS, material safety, etc.) in one stop, avoiding the need to send samples to multiple labs.
(3) High-End Equipment for Precise Quantification
Equipped with high-end analytical instruments including LC-MS/MS, GC-MS, ICP-MS, XRD, and X-ray fluorescence (XRF), CIRS Testing can precisely quantify trace hazardous substances in packaging, meeting PPWR's stringent limit requirements (e.g., heavy metals at 100 mg/kg, PFAS at the ppb level).
(4) Deep Understanding of the PPWR Regulation
The technical team accurately grasps the requirements of each PPWR provision, the effective timeline, and the boundaries of category-specific exemptions — for example, accurately distinguishing between the recyclability/recycled-content flexibilities for contact-sensitive medical-device packaging and the fully applicable obligations for outer and transport packaging, to prevent missed testing or misjudgment by companies.
(5) Testing + Compliance in One Stop
CIRS Group, the parent of CIRS Testing, is a National High-Tech Enterprise and a global chemical and product compliance service provider. After issuing the test report, it can seamlessly connect to compliance actions such as EPR registration, EU Authorized Representative, and DoC technical documentation, enabling companies to complete the full PPWR compliance process in a single pass.
(6) Rich Cross-Border Industry Experience
CIRS has served over 30,000 domestic and cross-border companies and maintains deep cooperation with mainstream e-commerce platforms such as Tmall Global, AliExpress, Amazon, TEMU, and SHEIN. It is well versed in the practical aspects of packaging compliance for cross-border e-commerce and brand globalization, and can provide actionable recommendations tailored to different business models.
Companies Need PPWR Compliance Services
Any company whose products are exported to the EU with packaging is advised to initiate PPWR compliance assessment in advance, with particular emphasis on:
- Medical devices and in-vitro diagnostics (contact-sensitive packaging enjoys partial flexibility, but general obligations such as heavy metals, EPR, DoC, and minimization are fully applicable)
- Toys and children's products, electronics and electrical appliances, food contact materials, textiles/footwear/bags, jewelry, and daily chemical products
- Packaging material manufacturers and suppliers (source-of-compliance responsibility lies with the manufacturer; overseas brands have already incorporated PPWR into supplier qualification)
- Cross-border e-commerce sellers (low-value, small parcels are not exempt; electronic reporting and compliance are still required)
Frequently Asked Questions on PPWR Compliance
Q: What is PPWR, and when does it become mandatory?
A: PPWR is the EU Packaging and Packaging Waste Regulation (EU) 2025/40. It entered into force on February 11, 2025, and becomes fully mandatory from August 12, 2026, replacing the 94/62/EC Directive.
Q: Is medical-device packaging exempt under PPWR?
A: Only the "contact-sensitive inner packaging" that directly contacts the product enjoys flexibility on three items: recyclability, recycled-content ratio, and labeling. General obligations — heavy metal limits, EPR registration, Declaration of Conformity, and packaging minimization — are mandatorily applicable to all packaging levels, with no industry-wide exemption.
Q: What testing items are required for packaging?
A: At minimum, the full set of packaging components must undergo heavy-metal testing for the four substances (total lead, cadmium, mercury, and hexavalent chromium ≤ 100 mg/kg); non-contact packaging requires a recyclability assessment; food-contact packaging involves PFAS screening; and contact-sensitive medical-device packaging additionally requires material safety testing.
Q: Does PFAS need to be tested?
A: The PPWR PFAS concentration limits (individual substance ≤ 25 ppb, sum ≤ 250 ppb, total organic fluorine ≤ 50 ppm) apply only to food-contact packaging; medical-device packaging is generally outside of the mandatory scope. If the packaging also contacts food, or if the client has forward-looking compliance requirements, testing can be added.
Q: How do I handle EPR, the EU Authorized Representative, and the Declaration of Conformity?
A: These can be handled by CIRS Group: target-country EPR registration and annual reporting, appointment of an EU Authorized Representative, issuance of the PPWR Declaration of Conformity (DoC) and construction of the technical documentation, forming a compliance closed loop together with the test report.
Service Process
Consultation & Communication → Proposal & Quotation → Sample Submission for Testing → Issuance of Test Report → Compliance Closed Loop (EPR Registration / EU Authorized Representative / DoC Technical Documentation) → Long-term Tracking and Re-inspection.
If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.
Further Information
Mandatory Enforcement in Less Than 2 Months! Is Your Packaging Ready to Pass the "PPWR Checkpoint"?
EU Publishes Packaging and Packaging Waste Regulation (PPWR) Guidance Document