Limits on Heavy Metals
Article 5(4) of EU 2025/40 (PPWR) maintains the total concentration limit of 100 ppm for lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr(VI)) in packaging materials. This requirement remains unchanged from the previous directive.
PFAS Restrictions for Food-Contact Packaging
Article 5(5) sets strict limits on PFAS concentrations in food-contact packaging, prohibiting market placement if PFAS exceeds:
- 25 ppb for individual PFAS tested using target analysis (excluding polymeric PFAS).
- 250 ppb for the sum of individual PFAS, where applicable with prior degradation of precursors (excluding polymeric PFAS).
- 50 ppm for total PFAS, including polymeric PFAS. If total fluorine content exceeds 50 mg/kg, manufacturers provide technical documentation (Annex VII) to confirm whether fluorine originates from PFAS or non-PFAS sources.
Labeling and Marking Requirements
To enhance sorting and recycling, Article 12 mandates:
- A harmonized label indicating the material composition of packaging by 12 August 2028 or 24 months after the relevant implementing acts come into force, whichever is later.
- Standardized digital markings for packaging containing Substances of Concern (SoC).
- A defined digital marking format under delegated acts, including the name and concentration of any SoC(s) present in each material within a packaging unit.
Mandatory Recyclability and Reuse Standards
PPWR enforces binding recyclability criteria, requiring electronics manufacturers to:
- Use packaging with a minimum recycled content.
- Meet reusability targets for specific packaging types.
Increased Reporting and Compliance Obligations
Companies selling in the EU market submit detailed packaging composition reports and demonstrate compliance with recyclability and reuse criteria. Stricter supply chain documentation impacts manufacturers’ sourcing of packaging from multiple suppliers.
Declaration of Conformity (DoC) Requirements
Per Article 39 & Annex VIII, manufacturers provide a Declaration of Conformity (DoC) confirming compliance with the regulation. The DoC includes:
- Packaging identification, manufacturer details, and a statement of responsibility.
- Relevant EU legislation and standards applied.
- Any certifications issued by a notified body (if applicable).
If packaging or the packaged product falls under multiple EU regulations requiring a DoC, manufacturers prepare a single DoC covering all relevant Union acts or compile individual declarations into a compliance dossier.
PPWR’s Impact on Electronics Manufacturers
The Packaging and Packaging Waste Regulation (PPWR) imposes additional compliance requirements on electronics manufacturers, including:
- Providing technical documentation for SoC restrictions and labeling requirements.
- Reassessing packaging materials for recyclability and compliance.
- Collaborating with suppliers to obtain verified compliance documentation.
- Updating regulatory reporting processes to align with EU-wide standards.