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February 20, 2025 | Written by GreenSoft Technology, Inc.

Navigating the New EU Packaging Regulation: Key Changes for Electronics Manufacturers

New Packaging Regulation (EU 2025/40) Replaces existing Packaging Directive (94/62/EC)

On January 22, 2025, the EU Official Journal formally published Regulation (EU) 2025/40 on packaging and packaging waste. The Packaging and Packaging Waste Regulation (PPWR) will take effect August 12, 2026 and will replace the existing Packaging and Packaging Waste Directive (Directive 94/62/EC).  

Unlike its predecessor, which allowed for national variations in implementation, PPWR applies directly and uniformly across all EU member states. The regulation introduces stricter requirements on recyclability, reusability, and the restriction of hazardous substances, including per- and polyfluoroalkyl substances (PFAS). These changes will impact the entire supply chain, requiring companies to assess and adjust their packaging materials and compliance strategies. 

Key Changes in the New EU Packaging Regulation 

Limits on Heavy Metals

Article 5(4) of EU 2025/40 (PPWR) maintains the total concentration limit of 100 ppm for lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr(VI)) in packaging materials. This requirement remains unchanged from the previous directive.  

Potential Future Restrictions on Substances of Concern (SoC)

• Article 6(4) directs the EU Commission to publish new supporting regulations which may introduce restrictions on substances of concern (SoC). The Commission is directed to adopt these new delegated acts by January 1, 2028.  
• Substances of Concern includes EU REACH SVHCs, Persistent Organic Pollutants, as well as substances meeting certain hazard categories in Part 3, Annex VI of the EU CLP Regulation.  
• Substances which negatively affect the reuse and recycling of packaging materials are also considered SoCs for the purpose of this regulation. 

New PFAS Restrictions for Food-Contact Packaging

Article 5(5) sets strict limits on the presence of PFAS in food-contact packaging, prohibiting market placement if PFAS concentrations exceed: 

• 25 ppb for individual PFAS tested using target analysis (excluding polymeric PFAS). 
• 250 ppb for sum of individual PFAS, where applicable with prior degradation of precursors (excludes polymeric PFAS).  
• 50 ppm for total PFAS, including polymeric PFAS. If total fluorine content exceeds 50 mg/kg, manufacturers must provide technical documentation (Annex VII) to demonstrate whether fluorine originates from PFAS or non-PFAS sources. 

The Commission will review whether to amend or repeal the PFAS restriction under the PPWR by August 2030. 

New Labelling and Marking Requirements

To enhance sorting and recycling, Article 12 mandates: 

• A harmonized label indicating the material composition of packaging will be required by 12 August 2028, or 24 months after the new implementing acts noted above come into force, whichever is the latest, pursuant to Article 12(6) or 12(7). 
• Standardized digital markings for packaging containing Substances of Concern (SoC) 
  • The standardized digital marking format will be defined by the upcoming delegated acts. The marking will include, at a minimum, the name and concentration of any SoC(s) present in each material within a packaging unit. 

Mandatory Recyclability and Reuse Standards

The previous directive promoted recycling but left implementation to national laws. PPWR enforces binding recyclability criteria, requiring electronics manufacturers to: 

• Use packaging with a minimum recycled content. 
• Meet reusability targets for certain packaging types. 

Increased Reporting and Compliance Obligations

Companies selling in the EU market must submit detailed packaging composition reports and demonstrate compliance with recyclability and reuse criteria. Stricter supply chain documentation will impact manufacturers sourcing packaging from multiple suppliers. 

Declaration of Conformity (DoC) Requirements: 

• Per Article 39 & Annex VIII, manufacturers must provide a Declaration of Conformity (DoC) confirming that their packaging complies with the regulation.  
  • This document must include details to ensure traceability, such as packaging identification, manufacturer information, a statement of responsibility, relevant EU legislation and standards applied, and any certifications issued by a notified body (if applicable). 
• If packaging or the packaged product falls under multiple EU regulations requiring a DoC, a single DoC may be prepared to cover all relevant Union acts. Alternatively, individual declarations may be compiled into a compliance dossier. 

PPWR's Impact on Electronics Manufacturers 

The new Packaging and Packaging Waste Regulation (PPWR) imposes additional compliance requirements. For electronics manufacturers, these changes mean: 

• Technical documentation will be required for future SoC restrictions and labeling requirements. 

• Manufacturers must reassess packaging materials for recyclability and compliance beginning in 2030 and beyond. 

• Working closely with suppliers will be essential to obtain verified compliance documentation. 

• Regulatory reporting processes must be updated to align with EU-wide standards. 

GreenSoft Can Help You Comply with the EU Packaging Regulation 

GreenSoft Technology provides supply chain data collection and compliance software to help electronics and component manufacturers navigate evolving environmental regulations like EU 2025/40 (PPWR).  

We offer proactive compliance solutions to: 

✔  Ensure your packaging meets recyclability and substance restrictions. 
✔  Streamline supplier documentation and compliance tracking. 
✔  Mitigate risks of non-compliance through expert regulatory support. 

Stay ahead of regulatory changes—contact us today to ensure compliance with the new EU Packaging Regulation!