Among the PPWR requirements, several articles are particularly important for packaging data management and compliance activities. The following articles introduce key requirements related to substances in packaging, recyclability, recycled content, packaging minimization, and labeling.
- Article 5: Substances in Packaging
Article 5 addresses substances in packaging. Article 5.4 limits the sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium in packaging or packaging components. Article 5.5 addresses per- and polyfluoroalkyl substances (PFAS) concentration limits in food-contact packaging.
Organizations need packaging-specific evidence, such as supplier declarations, certificates, material information, or test reports, to support the relevant assessment.
- Article 6: Recyclable Packaging
Article 6 establishes that packaging placed on the market needs to be recyclable. Detailed design-for-recycling criteria, performance grades, and assessment methodologies are introduced through later regulatory measures and phases. Recyclability depends on packaging material and design characteristics, including combinations of materials, labels, closures, adhesives, coatings, inks, barriers, and product residues.
- Article 7: Minimum Recycled Content in Plastic Packaging
Article 7 introduces minimum recycled-content requirements for specified categories of plastic packaging. Targets begin in later phases and become more demanding over time. Organizations need to identify which components are in scope and maintain evidence for the recycled content used.
- Article 10: Packaging Minimization
Article 10 establishes packaging-minimization requirements that apply according to the PPWR implementation timeline. Packaging weight and volume must be reduced to the minimum necessary while maintaining required functionality. Organizations need information to support design decisions and to demonstrate why the packaging is appropriate for its intended purpose.
- Article 12: Labeling of Packaging
Article 12 of Regulation (EU) 2025/40 establishes labeling requirements intended to provide harmonized packaging information, facilitate consumer sorting, identify reusable packaging, and regulate how certain environmental information is communicated. Many requirements depend on implementing acts and phased application dates.
The next lesson, Preparing for Circular Packaging Requirements, expands on recyclability and recycled content under Articles 6 and 7 and examines labeling requirements under Article 12.
Connect Requirements with Evidence
Evidence can include supplier declarations, laboratory reports, certificates, applicable standards, and documented internal assessments. The relevant evidence depends on the packaging, intended use, applicable requirement, and the organization’s compliance process. Evidence should be connected to the packaging element or packaging composition it supports. This improves traceability and helps users determine whether evidence remains applicable after a packaging change.
Lesson Summary
- Article 5 addresses specified substances in packaging, including heavy metals and PFAS in food-contact packaging.
- Article 6 establishes phased recyclability requirements that depend on packaging materials and design characteristics.
- Article 7 introduces recycled-content requirements for specified categories of plastic packaging.
- Article 10 addresses packaging-weight and volume minimization.
- Article 12 establishes labeling and information requirements for packaging.
- Addressing these requirements requires relevant packaging information and, where applicable, supporting evidence.