PPWR and EUDR: The Packaging Documents to Collect in 2026

Topic type: Compliance guide |

Two European rules now decide whether your packaging can be sold in the EU. Neither is satisfied by a price list. The Packaging and Packaging Waste Regulation has applied since 12 August 2026, with no transition period. The deforestation regulation reaches large and medium operators on 30 December 2026. Most of the evidence your importer needs sits with the factory that makes the box, so the paperwork conversation belongs at the quotation stage, not after the order is confirmed.

What the two rules now require
PPWR. Regulation (EU) 2025/40 replaces the 1994 packaging directive. It applies to all packaging placed on the EU market, wherever the manufacturer is established.

Obligations that took effect on 12 August 2026 include a conformity assessment and an EU declaration of conformity, which the manufacturer must draw up before the packaging reaches the market (Art 15). The packaging itself must carry a type, batch or serial identifier plus the manufacturer's name, trademark and postal address. Importers add their own name and address. There is also a general duty to minimise substances of concern, and Article 5(4) caps the combined content of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg.

PFAS in food-contact packaging is restricted from the same date: no more than 25 ppb for any individual non-polymeric PFAS, 250 ppb for their sum, and 50 ppm for total fluorine (Food Packaging Forum, August 2026; Intertek, May 2026; Mérieux NutriSciences, July 2026). 

Recyclability requirements apply from 12 August as well. Traceability records on suppliers and customers must be kept for five years on single-use packaging and ten years on reusable packaging (Freshfields, July 2026).

EUDR. The deforestation regulation covers wood-based products. Its entry into application is 30 December 2026 for large and medium operators and 30 June 2027 for micro and small ones (European Commission). Packaging is less exposed here than most buyers assume. The Commission's July 2026 Delegated Act confirms that packing materials and containers used exclusively to support, protect or carry another product are not relevant products and sit outside the regulation. A box sold to you as part of your goods falls in that category. A box you sell onward as a product in its own right does not.

Seven documents to request before you order
Part of your compliance file can only be filled by the factory that makes the box. Ask for these seven items in writing:
•The conformity assessment and EU declaration of conformity for the packaging
•Identification data ready for print: manufacturer name, trademark, postal address, and a type, batch or serial reference
•A substances statement covering PFAS and other substances of concern, at minimum for food-contact packaging
•Documentation supporting the general recyclability requirement
•Traceability records that let you retain supplier and customer data for five or ten years
•Material evidence for the board: chain of custody or recycled-content documentation
•EPR support: the producer registration numbers held for each Member State you ship into

Our side of the file
Tianjin FUSSEN keeps the following on file and sends it on request with a quotation. PPWR testing is complete, and the report goes out with the quote:
•PPWR heavy-metals testing to Article 5(4) of Regulation (EU) 2025/40, completed by SGS on a paper packaging box (reports SHAEC26029013201 and SHAEC26029013202, 14 September 2026): cadmium, lead, mercury and hexavalent chromium not detected against the 100 mg/kg combined limit
•FSC Chain of Custody certificate ESTS-COC-250662, valid to 15 May 2030, covering cardboard packaging, paper bags and other pulp and paper products
•ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018 certificates, valid to 26 August 2029
•SGS REACH screening on a rigid gift box (report SL92619311613601TX, June 2026), with all 253 candidate-list substances below 0.1%
•SGS RoHS test report on a rigid gift box (report CANEC26013757703, June 2026)
•Packaging EPR registrations in Germany (LUCID DE2179760823192), France (Citeo 566296) and Spain (ENV/2024/000044711)
•An EU authorised representative registered under GPSR, valid to 28 October 2027
•A SMETA (Sedex) initial audit completed on 7 and 8 August 2026

Two limits on that list need to be stated plainly. Our FSC certificate covers chain of custody as a trading activity; on its own it is not proof that any particular box is FSC-certified. That depends on the board you specify. Our ISO certificates cover the design and sale of paper packaging boxes, inserts and bags.

The duties that stay in your name
The PPWR puts EPR obligations on the producer, defined as the party that first makes packaging available in a given Member State. That registration goes in your name, not ours. National registers under the new regulation are expected to be operational from around mid-2027 (Freshfields, July 2026).

Your name and address go on the packaging as importer. You verify that the manufacturer carried out the conformity assessment, you keep the traceability records, and where EUDR applies you file the due diligence statement.

More arrives around 2030: design-for-recycling criteria, recycled content rules for plastic packaging, reuse targets, and bans on six single-use formats.

Data sources: European Commission, Regulation on Deforestation-free Products (entry into application, accessed 19 September 2026). Freshfields, "An overview of the new EU Packaging Regulation (PPWR)", July 2026. European Commission, July 2026 Delegated Act on EUDR scope (as reported by Interu, July 2026). PFAS limits under PPWR as reported by Food Packaging Forum (12 August 2026), Intertek (6 May 2026) and Mérieux NutriSciences (23 July 2026). Certificate and test report details are from Tianjin FUSSEN records, verified September 2026.

What to send us
Four things are enough for a quotation that includes the document pack:
•The structure you want and the board weight you are considering
•Dimensions, quantity and whether food or cosmetics contact applies
•The destination markets, so we match EPR registrations to the right countries
•Your target launch or in-store date

We answer the same working day with a quote, a tiered price list for 500, 1,000 and 5,000 pieces, and the compliance documents above in PDF, the PPWR test report included. Samples follow in two to three days. Dispatch runs seven days from artwork approval, and express shipping reaches the US in as little as two to four working days. If your compliance team needs anything added to the file, say so in the first message and it will travel with the quotation.

Tianjin FUSSEN is a digital printing and packaging manufacturer in Tianjin, China, with more than ten years of export experience and brand collaboration cases we can share under agreement. Printing, finishing and assembly are carried out in-house.

Tianjin FUSSEN | www.fussenpackaging.com | [email protected] | tjfssm.en.alibaba.com