Processing EU PPWR Reports for Cardboard Box Packaging
Date:2026-09-21 09:26:46 Classification
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Guide to EU PPWR Compliance for Cardboard Packaging
I. Applicability Assessment: Does your cardboard packaging require compliance?
Almost all cardboard packaging falls under the scope of the PPWR. Specific categories include:
| Packaging Type | Applicability | Notes |
| Corrugated cardboard boxes (courier/logistics boxes) | ✅ Applicable | Most common; a key focus of regulation |
| Gift boxes and color boxes (cosmetics, electronics, etc.) | ✅ Applicable | Compliance is more challenging if inks or laminations are used |
| Honeycomb board, paper edge protectors, paper void-fill | ✅ Applicable | Ancillary packaging is also regulated |
| Paper bags (including carrier bags) | ✅ Applicable | Specific restrictions apply to single-use paper bags |
| Reusable cardboard boxes | ✅ Applicable | Must additionally meet reuse requirements |
⚠️ Key Note: While cardboard packaging is relatively "encouraged" under the PPWR compared to plastic, it is not exempt. Even cardboard packaging must meet various requirements regarding heavy metals, recyclability, carbon footprint, and more. II. Core Testing/Assessment Requirements for Carton Packaging
Carton reports typically comprise the following five core modules, listed in order of importance:
Module 1️⃣ Heavy Metal Migration Test (Essential Requirement)
Standards: EN 13428, EN 13695-1
Test Parameters: Lead (Pb), Cadmium (Cd), Mercury (Hg), Hexavalent Chromium (Cr⁶⁺)
Limit: Total ≤ 100 ppm (aligned with Directive 94/62/EC)
Module 2️⃣ Recyclability Assessment (New Focus of PPWR)
Standards: CEN/TR 15321 Design for Recycling Guidelines; New PPWR Annex II Recycling Grading Standards
Assessment Scope:
Fiber recyclability rate (key metric for cartons)
Interference of inks, adhesives, or laminates with recycling processes
Separability (ease of separating paper from plastic film)
Grading Results: Grades A, B, C, and D (Grade D to be phased out by the EU)
Module 3️⃣ Carbon Footprint Calculation (New PPWR Requirement)
Standards: ISO 14067, PEN/PRC 04002
Scope: "Cradle-to-Grave" (raw material acquisition → production → transportation → disposal)
Mandatory Date: From August 2026, all packaging must be declared using the CFF (Carbon Footprint Formula)
Module 4️⃣ Fiber Sourcing Sustainability (Highly Recommended, Though Not Mandatory)
Certification: FSC / PEFC certification recommended
While not mandated by PPWR, EU buyers generally treat this as a procurement prerequisite
Module 5️⃣ Reusability Performance (Applicable to Returnable/Reusable Boxes Only)
For reusable packaging: Proof of reuse cycles required (typically ≥ 5 cycles)
Requirement: Establishment of a system for recovery, cleaning, and re-introduction into the supply chain
III. Application Process (6 Steps)
[1] Product self-assessment and classification
[2] Selection of a third-party laboratory or Notified Body (Dezewei Testing CNAS Registration No.: L8083)
[3] Sample submission + provision of technical documentation (material composition, manufacturing process, supply chain details)
[4] Laboratory testing + Assessment (4–6 weeks)
[5] Report issuance + Drafting of Declaration of Conformity (DoC)
[6] Registration in the EU packaging database + Affixing compliance markings
Processing time: 5–7 working days for standard cardboard boxes;
IV. Cost Reference
| Report Type | Cost Range (RMB) | Notes
| Basic Test Report (Heavy Metals + Recyclability) | 500 – 800 | Suitable for standard corrugated cardboard boxes