PPWR 2025/40: what packaging documentation an EU customer will request from you

What PPWR is and since when it applies

PPWR, meaning Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, replaces the earlier Packaging Directive. This distinction is not a formality. A directive only takes effect once it has been implemented into the national law of each state, so the rules in Poland, Germany or France can differ in detail. A regulation works differently: it applies directly, in the same wording, in every member state, without a national law in between.

For an importer of magnets, separators or any other goods sourced from outside the EU, this means one thing: there is no point looking for a Polish law that specifies the requirements differently from the regulation. The text is shared across the entire EU market.

Obligations arising from PPWR enter into force in stages, and the exact application dates of individual provisions must be checked in the text of the regulation itself or with an advisor dealing with this subject. We do not give specific dates here, because in a text about legal compliance a wrong date is worse than no date at all.

Four heavy metals and the 100 mg/kg threshold

Article 5(5) of the regulation sets a threshold for four heavy metals: lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr VI). Their sum in the packaging or a packaging component must not exceed 100 mg/kg.

In the papers we receive from suppliers, two misunderstandings come back regularly. First: this is the sum of four metals, not a separate limit for each of them. A report showing 90 mg/kg of lead separately and 90 mg/kg of cadmium separately does not prove compliance, because together that is already 180 mg/kg. Second: the threshold is calculated from the mass of the packaging itself or its component, not from the mass of the goods it contains. A report relating the result to the mass of the whole shipment including its contents is calculated from the wrong basis and cannot be directly translated into the regulation's requirement.

What the regulation requires from a supplier outside the EU

This is the core of the whole matter for anyone importing goods from outside the EU. A supplier operating outside the EU is not directly subject to PPWR - the regulation binds parties placing packaging on the EU market, and that party is the importer, not the foreign manufacturer.

In practice this means the entire burden of demonstrating compliance falls on the company that brings the goods into the EU. Article 16 of the regulation describes the obligations of a supplier in this chain, but a supplier outside the EU is not directly its addressee - it is the importer who must gather the documentation and, if it is missing, request it themselves. Annex VII describes what the technical documentation of the packaging should look like in order to demonstrate this compliance. If a supplier from Asia does not know what we are asking about, or replies with a general statement, that does not release the importer from the obligation - it only means the question needs to be asked more precisely.

We went through this on two tracks: for packaging bought from Polish suppliers, the documentation is simpler to obtain, because the supplier itself is subject to the same regulation. For packaging arriving together with goods from China, you have to ask directly, and often more than once, before the answer is complete.

How PPWR differs from REACH and RoHS

Customers often ask for a document using the word certificate, and do not always know which of three legal regimes the question concerns. These are three separate acts, with different thresholds and a different subject matter.

A document confirming compliance with one of these acts does not replace a document for the other two. A RoHS report on an electronic component says nothing about the packaging in which that component travelled, and a REACH declaration for the article itself does not answer a question about heavy metals in the carton.

What is usually missing in papers from a supplier

Having gone through many such documents, recurring patterns of gaps become visible, regardless of which supplier is asked.

A test report concerns a different material or a different article than the one we actually receive - a different carton grammage, a different type of film, a different print colour, which may contain different pigments. The test does not state the applied standard or method, so it is impossible to assess whether it answers the question posed by the regulation at all. A declaration of conformity is general and does not specify which part of the packaging it concerns - the outer packaging, the inner liner, the tape, or the whole. There is no link between the test report number and the number of a specific batch or delivery, which makes it impossible to demonstrate that the report even relates to the goods that arrived at our warehouse.

None of these gaps implies bad faith on the supplier's part. More often it results from the fact that the PPWR question is new to them, and no one has previously specified exactly what such documentation should cover.

What to do before a customer asks

From our own experience it is better to prepare this set in advance than to gather it under time pressure once a customer is already asking as part of their own audit.

Frequently asked questions