PPWR 2026 Practical Compliance Guide for Paper Packaging Exporters

The EU packaging industry is entering a new compliance era. With the Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) becoming applicable from 12 August 2026, companies exporting paper-based packaging products to Europe need to prepare beyond traditional quality reports.

A key question for exporters is: Are we only providing test reports, or are we building a complete compliance system?

PPWR compliance is not a single certificate. It requires a complete connection between:

1. Start With the Complete Packaging Structure

Many companies focus only on the base paper. However, modern paper packaging usually contains multiple components:

• 📄 Base paper
• 🌱 Barrier coating
• 🎨 Printing ink
• 🔗 Adhesive
• 📦 Functional layers

For example, a food paper cup is not only paper. Its compliance may depend on:

• ✔ Raw materials
• ✔ Coating system
• ✔ Printing process
• ✔ Converting conditions
• ✔ Final application environment

A supplier material report can support compliance evaluation, but it does not automatically represent the compliance of the final packaging.

2. Understand What Needs to Be Controlled

Under PPWR, companies need to pay attention to several key areas.

Heavy Metals

Packaging materials need to control restricted substances such as:

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

The focus is not simply obtaining a report, but ensuring that the tested sample represents the actual packaging structure.

PFAS Requirements for Food Contact Packaging

For food-contact packaging, PFAS restrictions introduce additional challenges. Companies need to understand:

• What substances are being tested
• Which testing methods are used
• Whether detection limits are suitable
• Whether the tested sample represents the final product

A “pass” result is meaningful only when the testing scope and method are clearly defined.

3. Water-Based Coatings Need Scientific Evaluation

Water-based coatings are becoming increasingly important in paper packaging applications. However, water-based does not automatically mean compliant.

It does not automatically represent:

• ❌ Zero VOC
• ❌ Food contact compliance
• ❌ Migration safety
• ❌ PFAS-free performance

A coating solution needs evaluation from:

• ✔ Raw material selection
• ✔ Formulation control
• ✔ Coating process
• ✔ Drying conditions
• ✔ Final packaging performance

The future competition will not only be about choosing sustainable materials, but choosing the right materials for the right application.

4. Build a Complete Compliance Evidence Chain

For paper packaging suppliers, the future challenge is creating traceable documentation. A practical compliance system should include:

• ✔ Material information
• ✔ Supplier declarations
• ✔ BOM structure
• ✔ Risk assessment
• ✔ Testing reports
• ✔ Technical documentation
• ✔ Declaration of Compliance (DoC)

The goal is not collecting more certificates. The goal is making sure every document can answer:

• What material was used?
• Where did it come from?
• How was compliance verified?

5. Recommended Preparation Steps for Exporters

For companies supplying the EU market:

Step 1 - Identify your real product structure

Example: Paper + coating + ink + adhesive + final conversion process.

Step 2 - Review supplier documentation

Confirm: material composition, compliance statements, test scope, and version control.

Step 3 - Evaluate product-specific risks

Different products require different focus:

• ☕ Paper cups → food contact & barrier performance
• 📦 Packaging board → recyclability & material composition
• 🌱 Coated paper → coating chemistry & process control

Step 4 - Maintain long-term traceability

Material changes, coating changes, and process changes may require compliance reassessment.

The Salon Paper Perspective

The future of paper packaging is moving from price competition to compliance & value competition. Global customers are looking for suppliers who can provide not only materials, but also:

• ✔ Stable quality
• ✔ Technical support
• ✔ Transparent information
• ✔ Long-term cooperation

At Salon Paper, we continue monitoring global packaging regulations and developing professional paper packaging solutions for international markets. Our solutions include:

• 📦 Cupstock Paper
• 🌱 Barrier Coated Paper
• 🃏 Playing Card Paper
• ✨ Metallic Paperboard