Understanding the EU PPWR: Navigating the Future of Sustainable Packaging in Toys & Hardgoods Products

For brand owners, manufacturers, and retailers in the toys and hardgoods sector, the European Union's Packaging and Packaging Waste Regulation (PPWR) represents a fundamental shift in packaging compliance requirements. Moving far beyond voluntary green initiatives, the PPWR introduces legally binding mandates that directly impact how toys, games, and durable goods are packaged, shipped, and sold across the EU.  

Packaging waste remains a significant environmental challenge in the EU. In 2022, the EU generated approximately 83.4 million tonnes of packaging waste, equivalent to an average of 186.5 kg per person, highlighting the need for more stringent and harmonized packaging requirements. To maintain market access and prepare for future compliance obligations, toy and hardgoods brands should begin evaluating and adapting their packaging strategies now.

What the PPWR Means for Brands

The regulation introduces rigorous requirements across the entire packaging lifecycle, presenting unique challenges—and strategic opportunities—for consumer goods:

1. Strict Chemical Limits (Article 5): Effective August 12, 2026, packaging must comply with ultra-low chemical thresholds. This means heavy metals (a total concentration limit of 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium) and targeted PFAS (<25 ppb) for food-contact packaging are heavily restricted, making chemical compliance assessment increasingly important for toy, game, and hardgoods packaging that utilizes coatings, inks, adhesives, laminates, or food-contact materials.
2. Design-for-Recycling (Article 6):  From 2030, packaging placed on the EU market will need to comply with applicable design-for-recycling requirements and achieve the required recyclability performance grade. Subject to the detailed criteria, methodology, exemptions and implementation provisions, packaging will generally need to achieve Grade C or higher, corresponding to a recyclability assessment of at least 70%. Further requirements relating to recycling at scale will apply subsequently.

    

3. Mandatory Post-Consumer Recycled Content (Article 7):   From 2030, applicable plastic packaging must contain specified minimum percentages of post-consumer recycled plastic. The applicable percentage depends on the packaging category, and the Regulation includes specific exemptions and calculation rules.

    

4. Biobased Feedstock in Plastic Packaging (Article 8): By 12 February 2028, the European Commission is required to review the state of technological development and environmental performance of biobased plastic packaging and prepare a report. Depending on the outcome, the Commission may consider further measures concerning sustainability criteria, targets or the potential contribution of biobased feedstock to plastic packaging requirements. Businesses making biobased-content claims should maintain suitable evidence to substantiate those claims.
5. Compostable Packaging (Article 9): Certain packaging applications, including specific food-related packaging and labels, may be required to be compostable under harmonized EU criteria. Businesses using biodegradable or compostable packaging claims should carefully evaluate material selection and ensure supporting evidence is available to demonstrate compliance.
6. Packaging Minimization and Space Efficiency (Articles 10 & 24): Packaging weight and volume must be reduced to the minimum necessary to maintain functionality. From 2030, grouped packaging, transport packaging and e-commerce packaging will generally be subject to a maximum empty-space ratio of 50%, in accordance with the applicable methodology, exemptions and implementation provisions.
7. Reusable Packaging (Article 11): Packaging placed on the market as reusable must be conceived, designed and placed on the market to be reused multiple times and must meet applicable requirements for repeated use, safety, hygiene, reconditioning and recyclability. Separate reuse targets under Article 29 apply to specified packaging categories and economic operators. Businesses considering reusable packaging should assess both the packaging design and the systems required for effective collection, reconditioning and reuse.
8. Harmonized Packaging Labelling (Article 12): The PPWR introduces harmonised labels to communicate the material composition of packaging and facilitate consumer sorting. Certain information may also be provided through a QR code or other standardised digital data carrier. The detailed label design, specifications and application timetable will be established through implementing acts and the transitional provisions of the Regulation. 

How SGS Empowers Businesses in the Toys & Hardgoods Sectors

Meeting the evolving requirements of the PPWR requires a thorough understanding of packaging materials, design considerations, and regulatory obligations. SGS offers a comprehensive range of services to support toy and hardgoods brands throughout their packaging compliance journey.

1. Chemical Testing & Compliance Assessment
   • SGS provides testing and assessment services for packaging materials, including heavy metals, regulated substances, and PFAS where applicable. These services help businesses evaluate compliance with PPWR substance requirements and identify potential risks associated with packaging materials, coatings, inks, adhesives, and food-contact applications.
2. Design-for-Recycling (DfR) Assessments
   • Drawing upon recognized industry methodologies and applicable standards, SGS evaluates packaging designs to support recyclability objectives. This includes assessments of multi-material packaging commonly used in toys and hardgoods products, helping brands improve material compatibility and recycling performance.
3. Recycled Content Verification
   • SGS supports businesses in verifying recycled content claims through testing, certification, and supply chain verification programs. Leveraging internationally recognized schemes such as GRS and RCS, SGS helps organizations demonstrate the use of post-consumer recycled (PCR) materials with credible supporting evidence.
4. Packaging Optimization & Performance Evaluation
   • SGS assists companies in assessing packaging minimization opportunities while evaluating packaging performance through testing such as drop, vibration, and compression assessments. These services help brands balance sustainability objectives with the need to protect products during storage, handling, and transportation.
5. Technical Documentation & Regulatory Support
   • SGS can assist businesses in preparing technical documentation and supporting evidence relevant to PPWR compliance. Our experts help organizations understand applicable requirements, compile supporting documentation, and prepare information that may be used to support Declarations of Conformity and other compliance-related activities.

By partnering with SGS, businesses can turn the complexities of the PPWR into a powerful differentiator, proving to eco-conscious consumers that their favorite toys and hardgoods are built with a truly sustainable future in mind.  

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