Q&A: Compliance Roadmap for Packaging Exported to the EU (PPWR 2026)
The PPWR (Packaging and Packaging Waste Regulation) is one of the European Union's key regulations, aimed at promoting the use of sustainable packaging, strengthening recyclability, and reducing environmental impact across the entire product life cycle.
How will the PPWR compliance roadmap affect businesses exporting to the EU?
Here are the answers from Bureau Veritas experts.
Question 1: My company exports to the EU for customers (B2B), including PE bags (food contact) and auxiliary packaging: labels, shrink film, and wooden pallets. I have two questions:
(1) Are all these packaging items within the scope of the PPWR?
(2) Regarding regulated chemical content (BPA / heavy metals / PFAS): is the supplier required to demonstrate compliance with a test report? If the supplier commits that these substances are not added during production, or that there is no risk, is that acceptable?
Answer: Yes. Under the PPWR, the regulation applies to all packaging placed on the EU market, whether used for B2B or B2C. The PPWR covers the entire life cycle of the packaging. The PPWR requires businesses to hold technical documentation demonstrating compliance. A test report is the strongest form of evidence, particularly for risk-bearing materials or when the customer requests it. If the supplier merely commits that a substance is not added but has no technical basis to prove compliance, the business is potentially exposed to risk.
Question 2: Test reports are supporting documents for the DoC, but are they mandatory in order to demonstrate compliance?
Answer: The PPWR does not require a test report in every case. However, the business must hold technical documentation sufficient to demonstrate compliance. If a regulatory authority or a customer requests it and the business cannot prove compliance, it will be regarded as failing to meet the requirements.
Question 3: My factory only produces cartons according to the customer's design; its function is solely as secondary (outer) packaging. Under EU 2025/40 (PPWR), what documentation do we need to provide to the customer when they ask about compliance with this regulation?
Answer: This product is still within the scope of the PPWR, because the PPWR applies to all types of packaging placed on the EU market, including secondary and transport packaging. However, as a non-EU packaging supplier, the EU customer will generally not require you to fulfil all PPWR obligations on their behalf, but will instead ask you to provide the data and technical documentation they need to compile their compliance file and Declaration of Conformity (DoC).
Question 4: I have a question regarding the DoC from a supplier for controlling bisphenols. The supplier declares that they comply with (EU) 10/2011 as amended, but does not make a separate declaration for bisphenol. Is that valid?
Answer: Regulation (EU) 2024/3190 requires that all materials within its scope have a Declaration of Compliance (DoC) consistent with EU 2024/3190, and the DoC must state the name of the bisphenol used; even where no bisphenol is used, the absence of use must be declared.
Question 5: A food company exporting to the EU market using aluminium cans - is the DoC provided by the can supplier, or does my company do it itself?
Answer: Under EU 1935/2004, the DoC must be provided by the manufacturer of the packaging material.
Question 6: I would like to look up the updated PPWR regulations - which website can I access
Answer: You can refer to: https://eur-lex.europa.eu or https://environment.ec.europa.eu