Important Note: PPWR only regulates packaging materials, not the product itself! Many foreign trade clients often confuse this. Even if the product complies with RoHS and REACH, it does not automatically mean the packaging meets PPWR requirements.
Regulatory Background: The PPWR (EU 2025/40) will be fully enforced on August 12, 2026, replacing the old Packaging Directive 94/62/EC. Heavy Metal Control Rules: The total sum of lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr (VI)) must be ≤100mg/kg, with no material exemptions for any packaging.
1. List of Packaging Subject to Heavy Metal Testing
Sales packaging (directly wrapping the product)
Color boxes, white boxes, blister packs, plastic bottles, packaging bags, aluminum foil bags, glass bottles, metal cans, tubes, gift boxes, blister packaging, and more.
2. Logistics and Transportation Packaging
Express delivery outer carton, stretch film, EPE bubble bag, pearl cotton, corner protector, strapping band, pallet wrapping film, cushioning filler.
3. Easily Overlooked Packaging Accessories (High Frequency Exceedance!)
Adhesive labels, printing inks, sealing tapes, packaging box adhesives, surface coatings, bottle caps, sealing strips, inner gaskets.
Risk Warning: Ink, color paste, and recycled plastic are high-risk areas for heavy metal exceedance. Ensure thorough testing!
2. Full material coverage, without category restrictions
Regardless of the material type, all packaging materials require inspection:
▪ Paper-based: cartons, corrugated board, kraft paper, laminated paper
▪ Plastic-based: PE, PP, PET, PVC, composite films
▪ Metal-based: aluminum boxes, tin cans, metal fasteners
▪ Glass and ceramic containers
▪ Composite materials, bamboo and wooden packaging, etc.
III. Clarification of Common Misconceptions
Misconception 1: Only food packaging requires heavy metal testing. Correction: All packaging is subject to mandatory heavy metal testing; PFAS restrictions apply only to food-contact packaging. Do not confuse the two! Food packaging must undergo both heavy metal testing and PFAS testing!
Misconception 2: Testing the entire packaging as a whole is sufficient. Correction: Regulations require homogeneous materials to be tested separately! For example, printed cartons must have their base material and ink layers tested separately; mixed testing reports are not accepted by customs.
Misconception 3: If the product itself passes inspection, packaging does not need testing.
Correction: The two sets of regulations are independent—PPWR governs packaging, while RoHS regulates electronic products, and neither can replace the other.
IV. Consequences of Non-Compliance
The goods were detained at EU ports, platform listings were removed, hefty fines were imposed, and product recalls occurred, severely impacting overseas orders.
