How to apply for testing under the new EU PPWR packaging regulations?
Date：2026-07-22 09:31:24 Classification
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The Packaging and Packaging Waste Regulation (PPWR), adopted by the European Union in 2024 and fully implemented on February 11, 2026, will replace the previous Packaging and Packaging Waste Directive (94/62/EC). It imposes stricter requirements on the sustainability, recyclability, compostability, and hazardous substance restrictions of packaging.
I. Overview of the PPWR Compliance Framework
1. Core Differences from the Old Directive
Upgraded from "Directive" to "Regulation"—Directly applicable across all Member States, no conversion required.
Introduced mandatory recycling quotas, compostable packaging, and reuse targets.
Strengthened full life-cycle environmental impact assessment.
Coverage of all packaging placed on the EU market.
2. Applicable Entities
All forms of packaging: retail packaging, combination packaging, transport packaging, e-commerce packaging.
All materials: plastics, paper, metals, glass, composite materials, wood, textiles.
All business roles: manufacturers, importers, distributors, e-commerce platforms.
II. Mandatory Testing Items
1. Hazardous Substance Restrictions
PPWR has strict limits on the following substances in packaging:
| Substance Category | Limit Requirements | Testing Methods
| PFAS (Per- and Polyfluoroalkyl Substances) | Food Contact Packaging: Prohibited or below a specific threshold | LC-MS/MS
| Heavy Metals (Lead, Cadmium, Mercury, Hexavalent Chromium) | Total less than 100 ppm | ICP-OES / XRF
| Phthalate | Restriction of Certain Phthalates | GC-MS
| BPA (Bisphenol A) | Strict Restrictions on Food Contact Packaging | HPLC
| Mineral Oil (MOSH/MOAH) | Food Packaging Restrictions | Online HPLC-GC
2. Recyclability Assessment
Compliant with EN 13430 (Energy Recovery), EN 13431 (Material Recovery), etc.
Assess the proportion of recyclable components
Submit a Recyclability Design Declaration
3. Compostability Testing (where applicable)
EN 13432 (Industrial Composting) Certification
EN 14995 (Household Composting) Certification
Report issued by a third-party certification body
4. Bio-based Content Testing
ASTM D6866 or EN 16640 (C14 Isotope Determination)
Verify the proportion of bio-based carbon in the total carbon
5. Reuse Performance Testing
EN 17383 (Performance of Reusable Packaging)
Testing cycle count and cleaning/disinfection tolerance
III. Testing and Processing Procedures
Step 1: Packaging Classification and Regulatory Applicability Determination
Identify packaging type (single-use/reusable)
Determine if it falls under mandatory compostability (e.g., tea bags, coffee capsules, fruit and vegetable patches)
Identify high-risk categories (food contact, children's products, medical)
Step 2: Choosing a Compliance Path
| Path | Applicable Situation | Core Requirements
| Self-Declaration of Conformity | General Packaging | Manufacturer's Self-Declaration, Retention of Technical Documentation
| Third-Party Testing Report | Most High-Risk Products | Engagement of a GLP/ISO 17025 Laboratory
| Certification | Compostable, Recyclable Design | EN 13432, PEFC, FSC, etc. Certifications
Step 3: Engaging a Testing Agency
Select an ISO-certified testing agency 17025 accredited laboratory
(e.g., Dezewei Testing CNAS registration number: L8083)
Step 4: Sample Submission and Testing
Provide representative samples (including complete label, composite layer, ink)
Indicate usage conditions (temperature, contact time)
Prepare a raw material list (including supplier, brand, and content information)
Step 5: Report Acquisition and Document Collection
Laboratory issues test report (Chinese/English/European languages)
Company prepares technical documentation – to be kept for at least 5 years
Issuance of EU Declaration of Conformity (DoC)
Step 6: Labeling and Market Surveillance
Apply CE marking (mandatory packaging)
Indicate recycling classification and reuse information
Register product in the EU database (to be online in 2026)
IV. Key Compliance Points
1. Mandatory Quotas for Recycled Components
| Packaging Type | Target Year | Recycled Plastics Percentage
| Plastic Packaging for Contact Sensitive Products | 2030 | ≥30%
| PET Contact Sensitive Products | 2030 | ≥30%
| Other Plastic Packaging | 2040 | ≥50%
2. Packaging Weight Reduction and Volume Minimization
Meet EN 13428 (Minimization of Packaging Volume/Weight)
E-commerce Packaging: Vacancy Rate ≤40%
3. Reuse Targets
Transport Packaging: Mandatory Reuse Rate from 2030
Some Sales Packaging (e.g., Beverage Bottles, Food Service): Deposit Refund System
4. Labeling Requirements
QR Code Provides Ingredients and Recycling Instructions
Uniform EU Recycling Label (Implementation in 2027)
Prohibition of False Environmental Claims (Greenwashing)
V. Testing Cycle and Cost
| Testing Module | Cycle | Estimated Cost (RMB)
| Heavy Metals + Phthalate | 5-7 Working Days | 1,000-3,000 RMB
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