On August 12, 2026, the EU’s Packaging and Packaging Waste Regulation (PPWR) officially came into full force. This regulation replaces the ”Packaging and Packaging Waste Directive” (94/62/EC), which had been in effect for more than 30 years. The upgrade from a ”directive” to a “regulation” means that all 27 EU member states must implement it uniformly; national transposition and flexible enforcement are no longer permitted. For cross-border sellers, this is not merely another piece of paperwork to comply with—major platforms such as Amazon, Temu, and SHEIN have simultaneously launched packaging compliance screenings, and listings that fail to pass the review will be directly restricted or even delisted. The consequences of non-compliance extend far beyond platform penalties: customs authorities have the right to detain incoming goods that do not comply with the PPWR, and regulatory agencies in each member state may impose fines on a per-item basis based on the number of non-compliant packages; in severe cases, companies face fines of up to 4% of their global annual revenue.

The core requirements of PPWR cover the entire life cycle of packaging—from material selection, design, and manufacturing to disposal and recycling. Heavy metal content must not exceed 100 mg/kg (i.e., 0.01%), the use of PFAS (per- and polyfluoroalkyl substances) in food-contact packaging is strictly restricted, the void ratio of packaging must not exceed 50% to curb excessive packaging, and all packaging must bear information labels in accordance with regulations and be accompanied by a declaration of conformity. For non-EU companies without an established presence in the EU, the regulation requires them to appoint an authorized representative located within the EU who is responsible for EPR registration, compliance declarations, and the fulfillment of recycling obligations. Taking Germany as an example, packaging products from non-EU companies that have not appointed a local authorized representative will not be able to clear customs.

Product and packaging compliance standards are rapidly rising worldwide, and cross-border sellers need end-to-end compliance support—from product selection to packaging design. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the U.S., Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as annual company audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong identity application, renewal, and permanent residency services; Singapore EP application services; and cross-border e-commerce mentoring and managed operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

I. The Six Core Requirements of PPWR: A Point-by-Point Breakdown of Compliance Key Points

The PPWR covers the entire packaging lifecycle, from production to disposal, and cross-border sellers should pay close attention to the following six key requirements.

Requirement 1: Limits on heavy metal content. All packaging materials entering the EU market must not exceed a total content of 100 mg/kg for the four heavy metals: lead, cadmium, mercury, and hexavalent chromium. This limit applies to all components of the packaging, including ink, adhesive, labels, and fillers. Cross-border sellers should take special note: Many commonly used domestic packaging materials (especially color-printed cardboard boxes and plastic bags made from recycled materials) may exceed heavy metal limits. It is recommended that you request third-party test reports (from SGS, TÜV, etc.) from your suppliers to ensure that the packaging materials are compliant.

Requirement 2: PFAS Restrictions. PFAS (per- and polyfluoroalkyl substances) are known as ”forever chemicals,” and the PPWR imposes strict restrictions on the use of PFAS in food-contact packaging. This requirement primarily affects cross-border sellers of food products—PFAS-containing packaging materials such as takeout containers, food storage bags, and grease-proof paper must be replaced with alternatives. Biodegradable materials and PFAS-free coating technologies are currently available as substitutes, but they come at a slightly higher cost, so sellers should evaluate this in advance when selecting products.

Requirement 3: One EPR registration per country. The Extended Producer Responsibility (EPR) system requires that an EPR number be registered separately in each EU member state. In other words, if a product is sold in four countries—Germany, France, Italy, and Spain—an EPR number must be registered in each of these four countries, and recycling fees must be paid separately in each. You cannot omit registration in other countries on the grounds that ”registration in Germany is valid throughout the EU.” During the review process, the platform requires sellers to provide EPR registration numbers for each country to which products are sold; if the registration number for any country is missing, the corresponding listings on that marketplace will be delisted.

Requirement 4: The declaration of conformity must be retained for 10 years. A declaration of conformity must be prepared for each type of packaging, including information on the composition of packaging materials, recyclability assessments, declarations of compliance regarding heavy metals and PFAS, EPR registration information, and more. Declarations of conformity must be retained for 10 years and made available for inspection at any time. This document is not submitted to the government but is archived by the company as evidence of compliance. However, if a regulatory authority requests it during a random inspection and the company is unable to produce it, the company will face penalties for noncompliance.

Requirement 5: The packaging void ratio shall not exceed 50%. PPWR explicitly restricts excessive packaging—the void area inside the packaging must not exceed 50%. This requirement primarily addresses the phenomenon of ”oversized boxes containing small items,” which is common in e-commerce packages. For example, if a small product is packed in a cardboard box significantly larger than its own volume and filled with a large amount of bubble wrap, resulting in a void ratio exceeding 50%, this constitutes a violation. Sellers need to optimize their packaging design, select packaging materials that match the product’s dimensions, and reduce unnecessary fillers.

Requirement 6: Label Information Compliance. All packaging must bear the required information labels, including: material classification symbols (to help consumers sort waste), recyclability symbols, and EPR registration numbers. The size, placement, and format of these labels are clearly specified; cross-border sellers must design their packaging labels in accordance with the legally mandated templates to ensure that product packaging information is complete and compliant when entering the EU market.

II. Platform Compliance Screening and Consequences of Violations: More Than Just Fines

Since the PPWR took effect, major cross-border e-commerce platforms have fully implemented compliance screening mechanisms, and the consequences of non-compliance are far more severe than one might imagine.

Amazon: Mandatory EPR Compliance Portal Review. Amazon has launched the EPR Compliance Portal on its European sites (Germany, France, Italy, Spain, etc.), requiring sellers to provide the corresponding EPR registration number for each country where they sell. Sellers who fail to provide a registration number will have their ASINs for the corresponding country delisted. Regarding the new packaging label and declaration of conformity requirements under the PPWR, Amazon expects to launch the second round of audits in Q3 2026, requiring sellers to upload packaging compliance declaration documents.

Temu and SHEIN: Proactive Compliance Measures. Temu and SHEIN have adopted a more proactive compliance screening mechanism—requiring sellers to provide a packaging compliance declaration as early as the product listing review stage. Temu has issued a notice stating that products that have not passed the PPWR compliance review will not be allowed to go live on its European site after August 12. SHEIN, meanwhile, has added a packaging inspection step to its logistics process, and non-compliant packaging will be returned.

Customs Seizure of Goods and Administrative Penalties. As a regulation, the PPWR has direct legal effect, and customs authorities in all EU member states have the authority to detain incoming goods that do not comply with the PPWR. For non-compliant packaging that has already entered the market, member state regulatory agencies may impose fines on a per-item basis; in severe cases, fines may amount to 4% of the company’s global annual revenue from the previous year. For large cross-border brands with annual sales exceeding 100 million, a fine of 4% could amount to several million euros.

Mandatory requirement for authorized representatives in Germany. Germany was one of the first countries to implement the requirements for PPWR authorized representatives. Non-EU companies selling products on the German market must designate an authorized representative registered in Germany to handle EPR registration, declarations of conformity, and recycling obligations. Authorized representatives must possess relevant professional qualifications and enter into a written authorization agreement with the manufacturer. Products from companies that have not designated an authorized representative cannot clear German customs.

Cross-border sellers require a comprehensive compliance service system covering the entire supply chain—from packaging compliance to EPR registration, and from European VAT to setting up overseas companies. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and more. We also offer a full range of corporate services, including annual reviews and audits, bookkeeping and tax filing, tax compliance, business information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong identity application, renewal, and permanent residency services; Singapore EP application services; and cross-border e-commerce mentoring and agency operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

III. Corporate Compliance Action List: Five Preparations That Must Be Completed in August

PPWR has taken effect, and cross-border sellers must complete the following five compliance preparations as soon as possible.

Item 1: Testing of packaging materials. Immediately collect packaging samples of products currently on the market and send them to a third-party laboratory for testing of heavy metal content and PFAS. After obtaining the compliance test reports, require suppliers to continue supplying products in accordance with the same standards, and include a ”packaging material compliance” clause in the procurement contract to extend compliance responsibilities upstream in the supply chain.

Item 2: EPR Registration. Compile a list of EU countries where the product is sold and complete EPR registration in each target country. An authorized representative in Germany must be designated simultaneously. It is recommended to engage a professional compliance service provider to handle this process to avoid registration rejections due to non-compliant documentation, which could delay the product’s launch.

Item 3: Preparation of a Declaration of Conformity. Prepare a Declaration of Conformity (DoC) for each type of packaging, including information on the composition of packaging materials, declarations of compliance regarding heavy metals and PFAS, the EPR registration number, and recyclability assessments. The documents must be prepared in English or the language of the target country and retained in the company’s records for at least 10 years.

Item 4: Optimization of packaging design. Review the packaging designs of products currently on the market, focusing on void ratio and label compliance. Optimize the dimensions of packaging with a void ratio exceeding 50% to reduce the use of filler material. Redesign packaging labels according to regulatory templates to ensure that information regarding material classification, recyclability, and EPR registration numbers is complete.

Item 5: Supply Chain Contract Renewal. Update the procurement contract with the packaging supplier to explicitly require the supplier to provide heavy metal compliance test reports and PFAS compliance statements, and stipulate that the supplier shall be liable for any losses resulting from non-compliant packaging materials. For packaging made from recycled materials, additional testing for heavy metal migration levels is required.

IV. From Passive Compliance to Proactive Planning: The Long-Term Value of Packaging Compliance

The mandatory implementation of the PPWR marks a new phase in EU packaging regulation characterized by ”end-to-end traceability and stringent penalties.” However, this represents not only compliance pressure but also an opportunity for businesses to upgrade their operations.

The core logic behind packaging compliance is ”addressing the issue at its source”—that is, considering material safety, recyclability, and reduction of packaging volume during the design phase, rather than implementing remedial measures at the end of the production process. This logic is highly consistent with the green packaging standards China is currently promoting and the global trend toward plastic restrictions. Sellers who complete their packaging compliance upgrades ahead of schedule will not only gain smooth access to the EU market but will also be able to apply their packaging design experience to meet compliance requirements in other markets, thereby reducing the marginal cost of compliance across multiple markets in the future.

At a deeper level, packaging compliance is one of the ”infrastructures” for brands expanding into international markets. Consumer awareness of eco-friendly packaging is rapidly increasing—more than 70% of European consumers say they are more likely to choose brands that use eco-friendly packaging. Compliant packaging design is not only a regulatory requirement but also a key element in building brand image and consumer trust. As ”green compliance” becomes the new standard in global trade, companies that proactively invest in packaging upgrades will reap long-term rewards in terms of brand premium and consumer loyalty.

From EPR registration to product compliance, and from European VAT to setting up overseas companies, Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and more. We also offer a one-stop suite of corporate services, including annual reviews and audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI and FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore Employment Pass (EP) application services; and cross-border e-commerce mentoring and managed operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

August 12 is not the deadline for PPWR compliance, but rather the starting point for full-scale enforcement. Sellers who complete packaging testing, EPR registration, and design optimization ahead of schedule will gain a head start in the upcoming shake-up of the European market; those who remain on the sidelines, however, may soon discover that their non-compliant listings have been quietly removed during platform screenings, while bills for customs detentions and administrative penalties are on their way. The speed of compliance is the speed of global expansion.