Exporting to the EU? PPWR Is Coming: What Textile, Apparel & Footwear Companies Need to Know

The European Union is raising the bar for packaging sustainability, and businesses exporting to Europe need to start preparing now.

On 22 January 2025, the EU officially published the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40. The new regulation will replace the current Packaging and Packaging Waste Directive (PPWD) and will begin to apply progressively from 12 August 2026.

As an EU Regulation, PPWR will apply directly across all EU Member States, helping to reduce differences in national packaging requirements. Unlike the previous Packaging and Packaging Waste Directive (PPWD), which focused primarily on the management of packaging waste after use, PPWR incorporates requirements for packaging design, material selection, recyclability, recycled plastic content, labeling, and technical documentation into the market access framework. In other words, packaging is no longer merely an accessory to a product; it has become a critical compliance element that can influence whether a product can be successfully placed on the EU market.

What Is PPWR and Why Does It Matter?

Unlike the previous PPWD, which focused largely on packaging waste management, PPWR introduces requirements that cover the entire packaging lifecycle, from design and material selection to recyclability, labeling, and documentation.

As an EU Regulation, PPWR will apply directly across all EU Member States, helping to harmonize packaging requirements and reduce regulatory differences between countries.

The regulation introduces requirements in areas including:

• Packaging design
• Material selection
• Recyclability
• Recycled plastic content
• Labeling
• Technical documentation

In short, packaging is no longer a secondary consideration. It is becoming an essential component of product compliance and EU market access.

Which Types of Packaging Are Affected?

PPWR applies to virtually all packaging placed on the EU market, regardless of the material used.

This includes packaging made from:

• Paper and cardboard
• Plastics
• Metals
• Glass
• Wood
• Composite materials

Any item used to contain, protect, transport, deliver, or present products may fall within the scope of PPWR, provided it is not an integral part of the product itself.

Common Packaging Used in the Textile, Footwear and E-commerce Industries

Examples include:

✅ Shoe boxes

✅ Hangtags, labels and stickers

✅ Dust bags

✅ Protective films and wraps

✅ Corrugated shipping cartons

✅ Courier bags and mailing envelopes

✅ Packaging tapes

✅ Transport and logistics packaging

This means exporters must not only ensure that their products comply with regulations such as REACH and POPs, but also verify that the associated packaging materials meet PPWR requirements.

Key PPWR Requirements Businesses Should Focus On

PPWR establishes a comprehensive compliance framework covering the entire packaging lifecycle. Companies should pay particular attention to the following key requirements:

1. Substance Restrictions

PPWR maintains strict controls on hazardous substances in packaging.

The combined concentration of:

• Lead (Pb)
• Cadmium (Cd)
• Mercury (Hg)
• Hexavalent Chromium (Cr(VI))

must not exceed 100 mg/kg.

In addition, food-contact packaging will be subject to specific restrictions on substances such as PFAS.

Companies should strengthen supplier management and material testing programs to ensure compliance.

2. Packaging Minimization Design

Companies must ensure that packaging weight and volume are reduced to the minimum necessary to fulfill their intended function, while avoiding unnecessary packaging layers, excessive empty space, and over-packaging.

3. Recyclability and Recycled Content

The EU is driving the transition toward Design for Recycling (DfR) in packaging.Starting in 2030, packaging recyclability will be assessed according to performance criteria and gradually linked to market access requirements.

For plastic packaging, minimum recycled content requirements will be introduced in phases, companies should proactively establish sources of recycled materials and maintain supporting supply chain documentation.

4. Labeling and Information Requirements

Manufacturers responsible for packaging design and branding should also pay close attention to requirements related to harmonized labeling, material composition identification, waste sorting and recycling information, and digital information carriers. These measures are intended to ensure that packaging information, waste separation practices, and consumer identification align with future EU requirements.

5. Technical Documentation and Declaration of Conformity

Before packaging can be placed on the EU market, manufacturers must perform a conformity assessment and prepare the necessary technical documentation.

Key compliance documents include:

• Technical Documentation
• Declaration of Conformity (DoC)

These documents will serve as evidence that packaging complies with applicable PPWR requirements.

Establishing a documentation framework early can help businesses meet customer requirements and respond efficiently to regulatory inspections.

6. Extended Producer Responsibility (EPR)

Producers that place packaged products on the market in an EU Member State for the first time, or sell packaged products directly to end consumers, are required to complete Extended Producer Responsibility (EPR) registration, submit packaging data reports, and pay applicable fees in accordance with the requirements of the target market.

How SGS Can Support Your PPWR Compliance Journey

As packaging regulations become increasingly stringent, businesses should start reviewing their packaging portfolios, identifying compliance gaps, and preparing supporting documentation.

SGS offers a comprehensive range of PPWR-related solutions to help companies navigate evolving EU packaging requirements.

Compliance Testing Services

• Heavy metals testing
• PFAS testing
• REACH Annex XVII testing
• SVHC testing
• POPs testing

Sustainable Packaging Services

• Packaging recyclability assessments
• Recycled PET, PE and PP verification
• Global Recycled Standard (GRS) services
• Bio-based content testing
• Compostability and biodegradability testing

Technical Documentation Support

• Technical Documentation preparation
• EU Declaration of Conformity (DoC)
• Packaging label review and regulatory compliance assessment

SGS is committed to helping businesses understand and meet PPWR requirements through trusted testing, verification, and compliance solutions, ensuring both products and packaging are ready for the European market.

For more information about PPWR and its business impact, please subscribe and contact us at TIC Mall for more details.

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