Packaging Compliance: EPR, Substance Restrictions, Labeling and Recycling
Manufacturers, importers, distributors and online sellers should evaluate packaging separately from the product it contains. A compliant product may still be placed on the market in non-compliant packaging.
What Counts as Packaging?
Packaging generally includes products made from materials of any nature that are used to contain, protect, handle, deliver or present goods.
Common packaging levels include:
Closures, labels, adhesives, inks, coatings, barriers, inserts and cushioning materials may be considered packaging components and should be included in the assessment.
What Does Packaging Compliance Cover?
A complete packaging assessment may address several distinct regulatory layers.
Substance restrictions
Packaging design
Design requirements may address:
- Packaging weight and volume;
- Unnecessary layers;
- Empty space;
- Recyclability;
- Material compatibility;
- Component separability;
- Recycled content;
- Reuse and refill;
- Compostability;
- Restricted packaging formats.
Producer responsibility
EPR requirements may include:
- Producer registration;
- Joining a producer responsibility organization;
- Reporting packaging quantities;
- Classifying packaging by material;
- Paying environmental or recycling fees;
- Financing collection and waste management;
- Appointing an authorized representative;
- Maintaining reporting records.
Labeling and environmental claims
Packaging may require or display:
- Material-identification codes;
- Sorting instructions;
- Recycling symbols;
- Deposit-return markings;
- Reusability information;
- Compostability certification;
- Recycled-content information;
- Country-specific environmental labels.
Recyclable, biodegradable, compostable and environmentally friendly claims should be accurate, specific and supported by appropriate evidence.
European Union Packaging Compliance
Packaging and Packaging Waste Regulation
The EU Packaging and Packaging Waste Regulation—Regulation (EU) 2025/40, or PPWR—has generally applied since August 12, 2026. It introduces requirements covering:
- Substances in packaging;
- PFAS in food-contact packaging;
- Recyclability;
- Recycled plastic content;
- Packaging minimization;
- Empty-space limits;
- Harmonized labeling;
- Reuse and refill;
- Restricted packaging formats;
- Conformity assessment;
- Technical documentation;
- EU Declarations of Conformity;
- Extended producer responsibility.
Many requirements are phased in through 2028, 2029, 2030, 2038 and 2040.
Consult our detailed EU PPWR compliance guide for the applicable obligations, deadlines and documentation requirements.
EU Extended Producer Responsibility
Companies selling packaged products in the EU may need to register and report packaging in each Member State where they qualify as a producer.
Although PPWR harmonizes parts of the regulatory framework, EPR systems continue to operate nationally. Registration procedures, reporting categories, producer responsibility organizations, fees and authorized-representative requirements can therefore differ between Member States.
A company should determine, country by country:
- Whether it qualifies as the producer;
- Whether a registration threshold or exemption applies;
- Which packaging materials must be reported;
- Whether it must join a producer responsibility organization;
- Whether an authorized representative is required;
- How frequently reports and payments must be submitted.
National EU Packaging Labels
National packaging labels and sorting instructions may apply in addition to EU-wide requirements.
For example, France uses the Triman symbol accompanied by Info-tri sorting instructions for packaging and other products covered by applicable EPR programs. The information may need to distinguish between packaging components when they have different sorting routes.
Companies should review labeling separately for every country in which packaged products are sold rather than assuming that one recycling symbol is valid throughout the EU.
United States Packaging Compliance
Packaging regulation in the United States involves both federal requirements and state-specific laws. There is no single national packaging-compliance system equivalent to the EU PPWR.
Depending on the product and market, companies may need to consider:
- State toxics-in-packaging laws;
- State PFAS restrictions;
- Packaging EPR programs;
- Minimum recycled-content requirements;
- Plastic and single-use packaging restrictions;
- Resin-identification codes;
- Environmental marketing requirements;
- Food-contact requirements;
- California Proposition 65;
- State-specific labeling and reporting rules.
Toxics in Packaging
Laws based on the Toxics in Packaging Clearinghouse model generally restrict the intentional introduction of:
- Lead;
- Cadmium;
- Mercury;
- Hexavalent chromium.
They also generally establish a combined incidental concentration limit of 100 ppm for these four metals.
The 2021 TPCH Model Legislation added PFAS and ortho-phthalates. However, model legislation is not automatically law. Each state must enact its own requirements, and the regulated substances, limits, scope and exemptions must be verified under the law of the applicable state.
Packaging EPR in the United States
Packaging EPR programs are established at the state level. Depending on the state, producers may be required to:
- Register with a state authority or producer responsibility organization;
- Join or finance an approved stewardship program;
- Report packaging quantities and materials;
- Pay fees based on packaging volume or environmental performance;
- Support collection, sorting and recycling;
- Meet reduction, recycling or recycled-content targets.
Because state programs are evolving, companies should conduct a current assessment based on where products are sold rather than relying on a static list of states.
California SB 54
California finalized the implementing regulations for Senate Bill 54—the Plastic Pollution Prevention and Packaging Producer Responsibility Act—on May 1, 2026.
SB 54 transfers significant financial and operational responsibility for single-use packaging and plastic food-service ware to producers. Depending on the product and supply chain, the responsible producer may be a manufacturer, brand owner, licensee, importer, or distributor.
Affected businesses must participate in the approved producer responsibility organization, Circular Action Alliance (CAA), unless they qualify for an exemption or receive approval to operate as an independent producer.
The initial reporting requirements included:
- 2023 Baseline Supply Data
- 2025 California Producer Report
- 2025 Annual Source Reduction Report
These reports were due May 31, 2026. Companies that missed the deadline should determine their obligations and address any incomplete registration or reporting immediately.
Under California law, CalRecycle may issue administrative civil penalties of up to $50,000 per day for each violation. Penalties generally begin accruing 30 days after the agency provides notice of a violation, increasing the importance of responding promptly to any compliance notice. Noncompliance may also affect a producer’s ability to lawfully sell covered materials in California.
Learn more from CalRecycle and Circular Action Alliance.
Oregon SB 582
Oregon’s Plastic Pollution and Recycling Modernization Act, established through Senate Bill 582, requires producers of covered packaging, paper products, and food-service ware to help fund and modernize the state’s recycling system.
Affected producers must register with Circular Action Alliance, Oregon’s only approved Producer Responsibility Organization, report the supply of covered products, and pay applicable producer fees.
Reporting requires companies to develop a detailed inventory of packaging supplied into Oregon. Depending on the applicable reporting rules, this may include primary, secondary, and tertiary packaging components; material and resin types; component weights; formats; and recyclability classifications.
Oregon’s modernized recycling system began operating on July 1, 2025. The Oregon Department of Environmental Quality can take enforcement action against obligated producers that fail to register or participate in the approved program. Failure to register or join a PRO is classified as a Class 1 violation and may result in penalties of up to $25,000 per day.
Oregon also provides producer compliance-status information, making unresolved registration and reporting issues a potential reputational and commercial risk.
Learn more from the Oregon Department of Environmental Quality.
Canadian Packaging Compliance
Packaging EPR requirements in Canada are primarily administered by provinces and territories. The entity considered the producer may vary based on brand ownership, residency, importation, distribution and sales model.
Potential obligations include:
- Registering with a provincial authority or stewardship organization;
- Reporting packaging and paper-product quantities;
- Paying material-specific fees;
- Maintaining records;
- Meeting management or recovery requirements;
- Providing consumer information.
Federal Plastics Registry
Canada’s Federal Plastics Registry collects information from organizations across the plastics value chain. Reporting may cover plastic placed on the Canadian market and how that plastic is managed through its life cycle.
Federal Plastics Registry reporting is separate from provincial EPR reporting. A company may therefore have both federal and provincial obligations.
Learn more in our Federal Plastics Registry guide.
Packaging Requirements in Other Markets
Packaging requirements also exist in markets including China, Japan, South Korea, the United Kingdom, Australia and other jurisdictions.
These requirements may cover:
- Heavy metals;
- Packaging material standards;
- Plastic restrictions;
- Recycling symbols;
- Material-identification markings;
- Excessive packaging;
- EPR registration and reporting;
- Food-contact substances;
- Recycled content.
For example, China has packaging and environmental standards that address material use, pollution prevention and certain substance limits. Some Chinese standards are voluntary while others are mandatory or apply only to particular packaging categories. Their status and scope should be verified for the specific product and packaging.
Heavy Metals in Packaging
The restriction of four heavy metals is a common packaging-compliance requirement in several jurisdictions:
- Lead;
- Cadmium;
- Mercury;
- Hexavalent chromium.
A frequently used limit is a combined incidental concentration of 100 ppm by weight in each package or packaging component.
However, companies should not automatically apply one global rule. The following may vary:
- Whether intentional addition is prohibited;
- Whether the limit applies to each component or the complete package;
- Available exemptions;
- Documentation requirements;
- Testing methods;
- Enforcement responsibility.
Packaging components that may require particular attention include:
- Printing inks;
- Pigments;
- Colorants;
- Coatings;
- Adhesives;
- Metal closures;
- Plastic additives;
- Recycled materials.
PFAS in Packaging
PFAS restrictions increasingly affect food packaging, paper and board, surface treatments, grease-resistant coatings, molded fibre products, inks and other packaging materials.
The applicable restriction may be based on:
- Intentional use;
- Individual PFAS concentrations;
- The sum of targeted PFAS;
- Total organic fluorine;
- Total fluorine;
- Packaging material or function;
- Food-contact status.
Testing strategies can include targeted PFAS analysis and total-fluorine screening. Results must be interpreted against the applicable jurisdiction’s definition, scope, exclusions and analytical requirements.
Learn more about PFAS testing and compliance.
Do REACH and POPs Apply to Packaging?
Are Recycling Symbols Mandatory?
There is no single recycling symbol that satisfies packaging-labeling requirements worldwide.
Common symbols include:
- Resin-identification codes for plastics;
- Material-identification codes;
- Mobius-loop recycling symbols;
- Deposit-return markings;
- Compostability marks;
- National sorting symbols;
- Country-specific EPR labels.
A resin code identifies a plastic material but does not necessarily prove that the package is recyclable in a particular market. Similarly, the Mobius loop should not be used to make an unsupported recyclability or recycled-content claim.
Before applying a symbol, companies should determine:
- Whether the marking is mandatory, voluntary or prohibited;
- Whether a prescribed format, colour or minimum size applies;
- Whether sorting instructions are required;
- Whether the symbol must appear on each component;
- Whether the recyclability claim is substantiated;
- Whether local collection and recycling infrastructure supports the claim.
What Documentation Is Needed?
A packaging compliance file may contain:
- A packaging bill of materials;
- Packaging-component weights;
- Material specifications;
- Supplier declarations;
- Full material declarations;
- Substance test reports;
- Recycled-content evidence;
- Recyclability assessments;
- Packaging-minimization assessments;
- Labeling artwork;
- Environmental-claim substantiation;
- EPR registrations;
- Packaging reports and fee records;
- Certificates or declarations of compliance;
- Technical documentation;
- EU Declarations of Conformity where required.
Documentation should identify each packaging component separately. A single supplier statement covering only the main box may not adequately address labels, inks, adhesives, cushioning, plastic film, closures or other components.
When Is Packaging Testing Appropriate?
Testing may be appropriate when:
- Supplier documentation is unavailable or incomplete;
- Recycled material creates a higher contamination risk;
- Inks, pigments or coatings may contain restricted substances;
- Food-contact packaging may contain PFAS;
- A customer or authority requests analytical evidence;
- A declaration does not identify the applicable substances or limits;
- Material composition cannot otherwise be confirmed.
Potential methods include:
- XRF screening for regulated metals;
- ICP-MS or other quantitative metal analysis;
- Targeted PFAS analysis;
- Total-fluorine analysis;
- GC-MS or LC-MS/MS for organic substances;
- FTIR for polymer identification.
Testing should be selected according to the packaging material, suspected substances and applicable legal limits.
A Practical Packaging Compliance Process
1. Identify every packaging component
Create an inventory covering primary, secondary, transport and e-commerce packaging.
2. Record materials and weights
Document the material, supplier, part number and weight of each packaging component.
3. Identify destination markets
List every country, state, province, or territory where the packaged product will be sold.
4. Determine company roles
Identify the manufacturer, importer, producer, distributor and responsible EPR entity in each market.
5. Map applicable requirements
Assess substance restrictions, EPR, reporting, labeling, recycled content, recyclability and documentation.
6. Collect supplier evidence
Obtain declarations, material specifications, recycled-content evidence and test reports.
7. Address information gaps
Conduct supplier follow-up, risk assessments or targeted laboratory testing where necessary.
8. Review packaging artwork
Confirm required symbols, sorting information and environmental claims before printing.
9. Prepare compliance documentation
Compile declarations, technical documentation, EPR records and supporting evidence.
10. Monitor regulatory changes
Packaging rules, substance lists, EPR programs and labeling requirements change frequently. Review the compliance file regularly and whenever the packaging, supplier or destination market changes.
How Enviropass Can Help
Enviropass can help manufacturers, importers and producers:
- Identify applicable packaging requirements;
- Prepare packaging bills of materials;
- Assess EU PPWR compliance;
- Determine EPR obligations;
- Review supplier documentation;
- Follow up with packaging suppliers;
- Evaluate substance restrictions;
- Coordinate packaging testing;
- Review recycling symbols and sorting information;
- Prepare technical documentation;
- Draft declarations of conformity;
- Monitor regulatory changes.
Our assessments can cover individual packaging components, complete packaging systems or packaging used across multiple product families and markets markets.
Contact Enviropass to discuss your packaging-compliance requirements.
Packaging Compliance - FAQ
