EU packaging rules now apply: the PPWR check an Indian exporter should run first

Separate today's rule from later milestones

The PPWR entered into force in February 2025 and applies across the EU on a phased basis from 12 August 2026. The Commission highlights the restriction on PFAS above the applicable limits in food-contact packaging as a measure entering application now.

Other major measures follow later. The Commission points to harmonised packaging labelling from 2028 and to measures such as limits on empty space, restrictions on certain single-use plastic packaging, reuse targets, recycled-plastic requirements and recyclability requirements from 2030. A credible readiness note records each relevant date instead of collapsing the regulation into one deadline.

Evidence: European Commission: Environment · European Commission: Environment

Map the packaging system around one SKU

List the primary, secondary and transport packaging used for the product: container, cap, liner, label, adhesive, insert, protective material, retail carton and shipping carton. Record material, weight, supplier, intended use, food-contact status and existing evidence for each component.

The same product may use different packaging for DTC, marketplace, retail and distributor routes. The route memo should therefore tie the component list to one channel and destination rather than approve a brand's packaging in the abstract.

• Packaging bill of materials with component weights
• Supplier declarations and food-contact evidence
• PFAS statement or test question where relevant
• Claims, labels, disposal instructions and language set
• Importer, producer-responsibility and record owner

Evidence: EUR-Lex · European Commission: Environment

Ask a laboratory or compliance provider a narrow question

Do not ask whether the whole brand is PPWR compliant. Give the provider the product, material list, packaging drawings, supplier evidence, intended use, channel and EU market. Ask which documents, tests, registrations, labels or redesign decisions are required now and which are future milestones.

The written quote should identify the facility, test or review method, samples, turnaround, exclusions, retest/failure charges and the professional conclusion the provider will actually issue. Sartha can coordinate this hand-off but should not make the laboratory or regulatory determination itself.

End with Go, Fix, Wait or Stop before printing inventory

The useful decision is whether the current pack can enter the chosen route, needs evidence, needs redesign, should wait for a later milestone plan or should be stopped before a large print run. That decision should include cost, lead time, responsible party and the version of packaging being assessed.

For a first engagement, screen one packaged SKU and one EU market. Scale to the catalogue only after the evidence template and provider hand-off work on a real case.