PPWR – PFAS and heavy metals testing and EU Declaration of Conformity

Regulation (EU) 2025/40 on packaging and packaging waste – PPWR (Packaging and Packaging Waste Regulation) introduces new obligations for packaging manufacturers and importers.

The PPWR applies to a broad range of packaging, including plastic and paper packaging, films, bags, bottles, closures, cartons, grouped and transport packaging, pallets and other packaging materials.

Manufacturers must be able to demonstrate that their packaging complies with the applicable requirements of the new Regulation. Supporting documentation may include technical documentation, information on materials used and, depending on the type of packaging, laboratory test results.

PFAS testing under the PPWR

One of the significant new PPWR requirements concerns restrictions on PFAS – per- and polyfluoroalkyl substances in food-contact packaging.

PFAS may be relevant in particular for paper, cardboard and multilayer packaging where surface treatments are used to provide resistance to grease or moisture.

Where supplier documentation is not sufficient to clearly demonstrate compliance, we can arrange laboratory PFAS testing in the required scope and subsequently assess the results as part of the PPWR documentation review.

Heavy metals testing in packaging

The PPWR also contains requirements concerning selected heavy metals in packaging and packaging components.

Depending on the material used, it may be necessary to verify the presence of:

• lead,
• cadmium,
• mercury,
• hexavalent chromium.

Testing may be relevant, for example, for plastics, coloured packaging, printed materials, closures, multilayer packaging or other components.

We can also arrange the required laboratory testing for heavy metals and assess the results together with the other technical documentation available for the packaging.

A test report alone is not enough

Laboratory testing by itself does not automatically mean that the packaging documentation is fully compliant with the PPWR.

Before preparing the Declaration of Conformity, the available documentation should also be reviewed, including the material composition, individual components, supplier documentation and existing test reports.

Based on the documentation provided, we can first review the available technical documentation and identify what needs to be supplemented or tested.

This helps avoid unnecessary testing. The required test scope is determined according to the specific packaging type, material composition and documentation already available.

EU Declaration of Conformity under the PPWR

Once the documentation has been reviewed and any necessary testing has been completed, we can prepare the EU Declaration of Conformity in accordance with Regulation (EU) 2025/40 – PPWR.

The Declaration of Conformity must be supported by relevant technical documentation. Simply adding the number of the new Regulation to an existing document or relying on a general supplier statement is not sufficient.

For food-contact packaging, it is also important to distinguish between PPWR requirements and the requirements applicable to food contact materials and articles. These are separate areas of EU legislation and the documentation must reflect the requirements actually applicable to the specific packaging concerned.

Complete PPWR documentation support

For packaging manufacturers and importers, we can provide the complete process required for preparing PPWR documentation, including:

• review of existing technical documentation,
• assessment of which PPWR requirements apply to the packaging,
• determination of the required testing scope,
• arrangement of PFAS testing,
• arrangement of heavy metals testing,
• review and completion of technical documentation,
• preparation of the EU Declaration of Conformity under the PPWR.

If you already have test reports or technical documentation from your supplier, we can first assess whether they are sufficient and applicable. Where additional documentation or testing is required, we can define the necessary scope and, once completed, prepare the EU Declaration of Conformity for placing the packaging on the EU market.