Industry Insights

On August 12, 2026, the EU's Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) officially entered into full force. This new regulation replaces the nearly 30-year-old directive (94/62/EC), upgrading it from a "directive" to a "regulation" that is directly applicable in all EU member states. It is now uniformly enforced, with no room for transitional implementation at the national level.

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This means that any non-compliant packaging or packaged products cannot be legally placed on the EU market from today onward. As a supplier of molds and injection-molded products, Haina Molds would like to remind our customers: packaging compliance is now a "gateway ticket" for exporting products to Europe, and it must be taken with the utmost seriousness.

Understanding Supply Chain Roles: Who Bears Primary Responsibility for Compliance?

The PPWR clearly defines the roles and responsibilities across the supply chain. For companies exporting products to the EU, clarifying whether they are a "manufacturer" or a "producer" is the first step toward compliance:

"Manufacturer": Refers to the operator who places packaging or packaged products on the market under their own name or trademark. This entity is the sole compliance responsible party at the EU level, responsible for issuing the Declaration of Conformity and preparing the technical documentation. Under contract manufacturing arrangements, even if products are produced by a third party, the brand owner placing the order remains the manufacturer.

"Producer": Refers to the operator who first makes packaging available within the territory of an EU member state and is obligated to fulfill Extended Producer Responsibility (EPR) requirements—namely, registering, reporting, and paying recycling fees in the country of sale.

A key point to note: non-EU based companies typically fall under the "manufacturer" category and must issue a DoC, while EPR registration must be completed separately in each country of sale. In some countries, an authorized representative can be appointed to handle this.

Four Core Requirements That Must Be Met from Day One

1. Strict Control of Hazardous Substances

Four Heavy Metals: The total content of lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr VI) in packaging shall not exceed 100 mg/kg.

PFAS Restrictions: For food contact packaging, PFAS content is subject to extremely stringent limits. Any individual PFAS substance (non-polymer) shall not exceed 25 ppb, and total fluorine content shall not exceed 50 ppm. This restriction has no inventory transition period — after August 12, even stock packaging produced before this date cannot be used if it does not meet the requirements.

2. EU Declaration of Conformity (DoC)

The PPWR requires that all packaging be accompanied by an EU Declaration of Conformity (DoC). This declaration, issued by the "manufacturer," is a legally binding self-declaration document confirming that the packaging meets PPWR requirements. The DoC must be supported by comprehensive technical documentation — retained for 5 years for single-use packaging and 10 years for reusable packaging, available for inspection by customs or market surveillance authorities.

3. EPR Registration

Producers must complete separate EPR registration in each country of sale, obtain the unique registration number for that country, and regularly report packaging placed on the market and pay the corresponding eco-contribution fees.

4. Operator Identification

Packaging shall bear the name, registered trade name or trademark, and address of the manufacturer, along with traceability identifiers such as model and batch numbers. If packaging size or nature does not allow for direct printing, such information may be included in the accompanying documentation.

A Message from Haina Molds to Our Customers: Packaging Compliance Is No Small Matter

As a company deeply engaged in mold manufacturing and injection molding, Haina Molds continuously monitors regulatory developments across the industry supply chain. Though packaging may seem like a "supporting role," under the PPWR framework it has become as critical to EU market access as the product itself.

We recommend that our customers take immediate action in the following areas:

■Screen for hazardous substances: Conduct a comprehensive review of existing packaging materials, with a focus on heavy metals and PFAS parameters.

■Initiate EPR registration: Complete or begin EPR registration in key sales countries (e.g., Germany, France, Spain, etc.) as soon as possible.

■Prepare DoC and technical documentation: Prepare DoCs and supporting technical files for each type of packaging.

■Request compliance documentation from packaging suppliers: Ask suppliers to provide material composition reports, test reports, and other compliance documents—this is also a clear requirement under the PPWR for all suppliers.

The full implementation of the PPWR signifies that the EU's oversight of packaging has shifted from "advisory guidelines" to "mandatory market access conditions." For Chinese companies exporting to Europe, the compliance window is urgent — only by taking action now can they ensure smooth customs clearance and secure their presence in the European market.

If you have any questions regarding packaging compliance for molds or injection-molded products exported to Europe, please feel free to consult Haina Molds. We are here to help you meet this challenge.

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