EU PPWR Regulation Fully Enforced

Previously, the quality of paper was judged by metrics such as basis weight, brightness, and stiffness. Starting August 12, 2026, the European Union has introduced a new set of evaluation criteria for every exported sheet of paper: heavy metal content, PFAS levels, recyclability, and ingredient data. For paper suppliers, PPWR brings not only an increase in testing requirements but also a complete redefinition of product specifications.

I. Overview and Scope of the Regulation
The PPWR came into effect on February 11, 2025, with most substantive obligations taking force from August 12, 2026. The regulation classifies packaging into three categories: primary sales packaging, secondary combined packaging, and tertiary transport packaging, explicitly excluding road, rail, air, and maritime shipping containers. All packaging placed on the EU market—regardless of material—must meet lifecycle management requirements under the regulation, including restrictions on hazardous substances, recyclability, labeling, and conformity assessment. Affected companies include manufacturers and importers within the EU, as well as upstream OEM/ODM factories in overseas supply chains. Non-compliant products face risks such as customs detention, market withdrawal, or penalties.

II. Key Compliance Requirements for Paper Exporters
1. Hazardous Substance Limits
The total concentration of four heavy metals—lead, cadmium, mercury, and hexavalent chromium—in all packaging must not exceed 100 mg/kg. If paper packaging is intended for food contact, additional PFAS restrictions apply. Exporting companies must rigorously screen inks, coatings, and water- or oil-repellent additives for these hazardous substances.

2. Declaration of Conformity and Technical Documentation
Manufacturers are required to prepare a Declaration of Conformity and comprehensive technical documentation demonstrating compliance with all PPWR requirements. Documentation for single-use packaging must be retained for five years, while that for reusable packaging must be kept for ten years, and both must be available for inspection upon request.

III. Recommendations for Compliance
First, immediately conduct screenings for hazardous substances in packaging materials, particularly focusing on heavy metals and PFAS, to ensure current products meet regulatory standards. Second, collaborate with third-party organizations to assess recyclability, optimize composite paper structures, and avoid coatings that hinder recycling. Third, establish a supply chain traceability system to prepare for potential future requirements on recycled content or to support corporate environmental claims. Proactive compliance and early strategic planning will enable businesses to seize opportunities amid the wave of the EU’s green new deal.