PPWR: No Packaging Is Inherently Compliant

For packaging manufacturers and foreign trade business owners exporting to the EU, bear one key point in mind: under PPWR, no packaging is “inherently compliant”. The two categories with the highest risk of non-compliance are corrugated packaging and bio-based packaging.

First, corrugated packaging. Many assume corrugated board is simply paper that can be recycled, so there should be no issues. The risks lie in additional materials applied. Lamination or extrusion coating creates composite layers that hinder the regeneration of paper fibres, immediately downgrading its DfR recyclability rating. Heavy metals and PFAS present in inks, adhesives and coatings are priority items for customs sampling inspection. Testing only base paper while overlooking auxiliary materials may result in container detention or even return shipment.

Next, bio-based packaging — this is the biggest misconception trap. Bio-based does not equal automatic compliance under PPWR. PPWR assesses design for recyclability, not whether raw materials are biodegradable. Bio-based raw materials are not the same as post-consumer recycled (PCR) materials and cannot be counted towards recycled content targets.

Therefore, bio-based packaging still needs full compliance procedures: DfR classification, hazardous substance testing, EPR registration, plus complete DoC declaration documents. None can be omitted.

Corrugated packaging and bio-based packaging follow two entirely separate compliance logics; never evaluate them using the same criteria!

Vopak specialises in PPWR compliance for corrugated and bio-based packaging. Our services include corrugated structure assessment, DfR rating, PFAS and heavy metal testing, bio-based material identification, recyclability evaluation and technical document guidance. We uphold the principle of “design for recycling” to eliminate hidden risks in advance and secure your EU orders.

For EU export packaging compliance, turn to Vopak!