Home » Services » Industrial Certification

PPWR Compliance: EU Packaging and Packaging Waste Regulation

Q: Who is required to issue the Declaration of Conformity?

Anyone placing a product on the EU market. The manufacturer, importer, and brand owner are each individually liable, and having the packaging produced by a supplier does not transfer this responsibility. Starting August 12, 2026, an EU Declaration of Conformity is required for each unit of packaging. Those selling from outside the EU must also designate a responsible party established in the EU.

Q: Is a supplier's declaration sufficient, or is a test report required?

A supplier’s declaration alone is not sufficient for compliance with substance limits. A report from an accredited laboratory must demonstrate that the total heavy metal content (Pb+Cd+Hg+CrVI) is below 100 mg/kg. Failure to provide the required documentation may result in the shipment being rejected at the border.

Q: Does the PFAS ban apply to us?

If you use food-contact packaging, then yes; the ban takes effect on August 12, 2026, the same day as the general implementation. The limit for targeted PFAS is 25 ppb; the scope also includes grease-resistant paper and cardboard coatings.

Q: Is third-party certification required for PPWR?

No. Conformity is demonstrated through a manufacturer’s declaration based on internal production control and the technical file. Documented evidence, however, is mandatory; voluntary schemes such as EN 15343, RecyClass, GRS, and RCS provide a significant portion of this evidence.

Q: How long do we need to keep the technical file?

5 years for single-use packaging, 10 years for reusable packaging. The file must be submitted within 10 days upon request by the market surveillance and control authority.

Q: How is our recyclability class determined?

The class is determined based on the recyclable weight percentage of the packaging unit: A ≥ 95%, B ≥ 80%, C ≥ 70%. Detailed design criteria will be established by delegated acts by January 1, 2028; until that date, the assessment is based on the RecyClass methodology, with EN 13430 and ISO 18604 also being used.

Q: How will EPR fees be calculated?

Fees will be determined based on the packaging’s recyclability class (A through E), the percentage of recycled content, its reusability, and the presence of substances of concern. Companies that certify their designs as Class A or B early will pay lower fees, while those that delay will pay higher fees.

Q: We export from Türkiye to the EU—what should we do?

You must appoint a responsible party established in the EU and issue a Declaration of Conformity for each packaging unit. After submitting your packaging information, you will receive your PPWR Status Assessment Report within 3 business days; you will see which of your packaging is ready and which requires testing.

The general implementation of the EU Packaging and Packaging Waste Regulation (EU) 2025/40 begins on August 12, 2026. The Regulation applies to everyone who places packaging on the EU market, including manufacturers, importers, brand owners, and distributors. After August 12, packaging without a Declaration of Conformity and test evidence may be rejected at the border.

Please provide us with your packaging information; the PPWR Status Assessment Report we will prepare within 3 business days will indicate which of your packaging is compliant and which requires testing.

Apply Now
[email protected]

Free Support
+90 232 446 44 16

An editorial, high-quality photograph of a minimalist arrangement of sustainable packaging prototypes on a clean, white architectural surface. The scene features a sleek, recycled cardboard shipping box, a clear glass bottle, and a container made from high-quality recycled plastic, all designed with precise, efficient shapes that eliminate excess volume and empty space. On the packaging, subtle and modern universal recycling icons and a small, clean QR code are visible, representing standardized labeling. The setting is a bright, professional design studio with soft, natural daylight, emphasizing the textures of the eco-friendly materials—the fine grain of the paper and the clarity of the glass. The color palette is composed of neutral whites, soft greys, and muted forest greens, conveying a sense of environmental responsibility, industrial precision, and a circular economy. The composition is balanced and elegant, with a shallow depth of field focusing on the high-quality craftsmanship of the sustainable containers.

Legal Transformation

From the Directive to the Regulation

Regulation (EU) 2025/40 replaced the 94/62/EC Packaging Directive. The Regulation was adopted on December 19, 2024, published in the Official Journal of the EU on January 22, 2025, and entered into force on February 11, 2025. At the end of the 18-month transition period, full implementation will begin on August 12, 2026.

EPR New Era in Packaging Waste Management

Why It Matters: The Regulation is directly applicable in every Member State; it is not expected to be transposed into national law. It covers all packaging and packaging waste, regardless of the material used. It also applies to non-EU actors placing packaging on the EU market. Non-compliant packaging may be withdrawn from the market.

Scope of Liability

The PPWR imposes obligations on all actors in the packaging supply chain, including those outside the EU.

Who Is Required to Comply

Manufacturers

It designs and manufactures packaging or packaged products that meet the requirements.

Importers

It is responsible for ensuring that the imported packaging it places on the EU market complies with regulations.

Distributors

It supplies only appropriate and properly labeled packaging.

Online Marketplaces

It verifies that the products sold on its platform meet PPWR requirements.

Brand Owners / Private Label

The manufacturer is responsible for packaging sold under its own brand.

Non-EU Actors

It designates a responsible party for sales to the EU and ensures compliance.

Basic Requirements

Each package must meet six design requirements supported by extended producer responsibility.

Design Requirements and Manufacturer Liability

Recycling

Packaging is designed to be recyclable and is classified on a scale from A to E.

Recycled Content

Plastic packaging must meet minimum recycled content requirements based on type.

Reuse and Refill

Transportation, grouping, and beverage packaging are subject to reuse targets.

Reduction

Packaging must not be heavier or bulkier than required by its function.

Labeling and Information

Material and separation labels will be standardized across the EU.

Substances and Safety

Limit values apply for heavy metals and PFAS.

Extended Producer Responsibility (EPR): Producers finance collection, sorting, and recycling; the fee is determined based on the packaging design.

Are You Ready for August 12, 2026?

Testing, redesign, and supplier data take time; the process must begin today—not as the deadline approaches—to be completed on time. You can consolidate all evidence—from evaluation to testing, and from validation to reporting—under a single accredited umbrella.

Call Us Now Send Email

Recyclability: Classes A through E (Article 6)

Starting in 2030, every packaging unit will be classified based on its recyclability. The minimum classification required to remain on the market will increase gradually from 2030 to 2038.

A — ≥ 95% recyclable

Top-of-the-line; the packaging is designed to be fully recyclable.

B — ≥ 80% recyclable

The packaging is well-designed for recycling.

C — ≥ 70% recyclable

The minimum requirement for remaining in the market starting in 2030.

D – E — < 70% recyclable

Below the threshold: first restricted, then gradually lifted.

How Is the Bar Being Raised?

Starting in 2030, only Class A–C packaging may be placed on the EU market.
Starting in 2035, packaging must also be recycled on a large scale (in practice, approximately 55%).
Starting in 2038, only Class A–B packaging will remain compliant.
Design criteria for recyclability will be established by delegated acts by January 1, 2028; until then, assessment will be based temporarily on the RecyClass methodology.

Recycled Content in Plastics (Article 7)

A minimum post-consumer recycled (PCR) content requirement has been established for each type of plastic packaging. These requirements will increase significantly from 2030 to 2040.

Type of plastic packaging	2030	2040
Single-use beverage bottles	30%	65%
Touch-sensitive, weighted PET	30%	50%
Touch-sensitive, other plastics	10%	25%
Other plastic packaging	35%	65%

How it is measured: Only post-consumer recycled (PCR) content is counted, and the percentage is calculated based on the facility’s annual average. This requirement applies when the plastic content exceeds 5% of the packaging weight. Medical and certain pharmaceutical packaging are exempt; mass balance accounting is accepted.
Proof of the PCR percentage: Demonstrated through GRS/RCS chain-of-custody certification and EN 15343 traceability.

Reuse and Refill

PPWR shifts packaging from single-use to reusable through industry targets and refill obligations.

Shipping and Sales

The goal is to achieve a 40% reuse rate for transport packaging covered by this initiative by 2030.

Grouped Packaging

The target for grouped (secondary) packaging is 10% reuse by 2030.

Beverages

The goal is to achieve a 10% reuse rate for beverage packaging by 2030.

Inter-Facility Transportation

Transport packaging used between facilities within the same business must be 100% reusable within 18 months.

HoReCa Filling

Customers may bring their own containers; businesses must offer a refill option.

Pallet Wrapping Exemption

Certain shipping packaging materials, such as pallet wrap and tape, are exempt from these requirements.

Reduction and Vacant Space (Article 10)

The weight and volume of the packaging are reduced to the minimum level required for functionality and safety.

≤ 50% Maximum Empty Space Ratio

This applies to grouped, shipping, and e-commerce packaging effective January 1, 2030.

Items Banned Starting in 2030

Double walls, false bottoms, and hidden fillers. Misleading sizing that exaggerates the product’s volume. Unnecessary layers that serve no functional purpose. Features that add material solely for marketing purposes. Single-use formats listed in Annex V.

The reduction is verified using the EN 13427 / EN 13428 methodology.

Substances of Concern (Article 5)

PPWR restricts hazardous substances in packaging with strict limits on heavy metals and PFAS.

Heavy Metals

Σ Pb + Cd + Hg + Cr(VI) ≤ 100 mg/kg. The limit applies to all packaging materials; it is verified by XRF screening and ICP analysis.

PFAS in Food-Contact Packaging

As of August 12, 2026, PFAS will be prohibited in food-contact packaging. The target PFAS limit is ≤ 25 ppb for a single substance and ≤ 250 ppb for total PFAS; total fluorine, including polymeric fluorine, must not exceed 50 ppm.

The List of Substances of Concern Will Expand

A more extensive list of concerning items is expected toward the end of 2026.

Evidence: Certificate of Analysis (CoA) from an Accredited Laboratory

Conformity is demonstrated by the Certificate of Analysis (CoA) issued by an accredited laboratory.

Labeling and Digital (Articles 12–13)

Standardized labels and digital media help consumers sort their waste properly and also reduce greenwashing.

Material and Separation Label

Harmonized labels will be mandatory on packaging starting August 12, 2028.

Reuse Label

Reusable packaging will bear a reuse label starting February 12, 2029.

Digital QR Carrier

QR codes and similar data carriers provide access to information on recycling, reuse, and package contents.

No Permission for Green Paint

Environmental claims must be verifiable; vague or misleading labels may not be used.

Compostable packaging is labeled in accordance with EN 13432.

EPR and Eco-Modulation

Manufacturers cover the costs of collecting and recycling packaging at the end of its useful life. The fee is determined based on how well the packaging is designed.

Fees Are Determined Based on the Following

Recyclability class.
Recycled content percentage.
Reusability.
Content of substances of concern.

What Does This Mean in Practice?

A lower EPR fee is charged for well-designed packaging.
Poor recyclability or the presence of concerning substances increases the fee.
Design decisions directly affect the fee paid each year.
Verifiable packaging data is required to determine the fee accurately.
Eco-modulation rewards early and evidence-based improvements.

When Is Testing Necessary?

PPWR is based on the manufacturer’s own declaration. For the declaration to be valid, it must be supported by concrete evidence at every point where a risk exists.

If There Is a Risk, Testing Is Necessary

New or modified materials, inks, or coatings.
Recycled content claims for which the percentage must be substantiated.
Food-contact packaging (PFAS, migration, heavy metals).
Suppliers who cannot fully document their inputs.
Materials with uncertain recyclability, mixed materials, or multi-layered materials.
Any claim that a market surveillance authority could challenge.

The Principle of Documented Evidence

A declaration alone is not sufficient.
Supplier declarations must be supported by evidence.
A Certificate of Analysis (CoA) from an accredited laboratory is standard.
A good report includes the method, LOD/LOQ values, and the result.

Product Testing

Laboratory testing is not required for every package, but only at points where there is a risk; the tables below show which tests are performed using which methods.

Chemical Tests

The tests are conducted in two stages: rapid screening identifies risk indicators, while accredited methods confirm and quantify them.

Goal	Method (screening → verification)	Criterion
Heavy metals (Pb, Cd, Hg, Cr VI)	XRF screening → ICP-OES / ICP-MS confirmation; Cr(VI) by colorimetry / UV-VIS; Hg by CV-AAS; IC for Br.	Σ ≤ 100 mg/kg
PFAS	Total fluoride screening → py-GC/MS → targeted LC-MS/MS analysis.	≤ 25 / 250 ppb; TF < 50 ppm
Substances of Concern	Multi-residue GC-MS and LC-MS/MS profiling.	Below the applicable limits
Food-related migration	General and specific migration testing of food-contact packaging.	Within the FCM boundaries

USB’s ISO/IEC 17025 laboratory scope includes analyses for Cr(VI), heavy metals, and substances covered by REACH. The recognized EN 62321 family of methods is used for heavy metal determinations.

Physical and Recyclability Tests

These tests provide evidence of the design pillars: recyclability, recycled content, compostability, and reusability.

Test	Standard / Method	Output
Recyclability Assessment	EN 13430 · ISO 18604 · RecyClass methodology.	% recyclable / A–C
Recycled content and traceability	EN 15343 — Chain of Custody and Mass Balance.	Confirmed PCR %
Paper recyclability	Re-doughing and fiber yield test.	Recyclability
Compostability	EN 13432 — industrial compostability.	Pass / Fail
Reusability	Cycle, durability, and washing test.	Reuse cycle

USB tests more than 700 packaging parameters in a single laboratory under ISO/IEC 17025 accreditation and presents the results in a single report.

Test Matrix by Packaging Type

The matrix below shows which tests are typically performed for each packaging family; the scope of testing is determined accordingly.

Type of packaging	Heavy metals	PFAS	Recyclability	Recycled content	Compostability
Plastic — food-contact	●	○	●	●	–
Paper / cardboard	●	●	●	○	○
Multi-layer laminate	●	○	●	○	–
Glass / metal	●	–	●	○	–
Compostable	●	○	○	–	●

● typically required · ○ risk-dependent · – generally not required

How Does Compliance Work?

PPWR compliance is demonstrated by a manufacturer’s declaration based on internal production controls and the technical file.

1 · In-House Quality Control

Keep production under control in a manner that meets the requirements (Article 38, Module A, Annex VII).

2 · Technical Documentation

Compile the technical file: evaluations, test evidence, and design records (Annex VII).

3 · EU Declaration of Conformity

Prepare and sign the EU Declaration of Conformity (DoC) for each packaging unit (Article 39, Annex VIII).

PPWR does not require third-party certification; it requires documented evidence. Retain records for 5 years in single-use packaging and 10 years in reusable packaging; you must submit the technical file within 10 days upon request by the authority.

Voluntary Guarantee

Voluntary schemes are not required under the PPWR; however, they provide all the evidence required by the technical file.

CERTIFICATION STRENGTHENS EVIDENCE OF COMPLIANCE

GRS / RCS

It verifies claims about recycled content using a chain of custody.

EN 15343

It documents the traceability of recycling and the calculation of recycled content.

EN 13430 / ISO 18604

It demonstrates recyclability in accordance with material recycling criteria.

RecyClass

The delegate provides a temporary basis for the recyclability classification prior to the savings.

Accredited Laboratory Certificate of Analysis (CoA)

It supports limits for heavy metals, PFAS, and other substances with laboratory evidence.

Preliminary Eligibility Review

It reviews the technical file and the DoC prior to market surveillance.

Note: GRS/RCS is in the process of transitioning to the Textile Exchange Materials Matter Standard.

Frequently Asked Questions