EU PPWR Now Applies What Glass Kitchenware Businesses Need to Prepare

One question has come up repeatedly in our conversations with European customers:

“Do you have a PPWR certificate?”

The short answer is that PPWR is not a single certificate that can cover every packaging configuration. In practice, PPWR compliance requires a traceable body of evidence showing which materials are used in each packaging configuration, what the testing covers, and how compliance will be reassessed when a material or structure changes.

• No single PPWR certificate can permanently cover every packaging configuration, version and market.
• Testing must match the specific material and its real use. Cartons, labels, films and adhesives are not interchangeable.
• When a material, structure or supplier changes, the existing evidence may need to be reassessed.

This article focuses on packaging systems for glass kitchenware, including cartons, inserts, films, labels, tapes and cushioning materials. It does not cover the food-contact compliance of the glass product itself.

• 11 February 2025: Regulation (EU) 2025/40 entered into force.
• 12 August 2026: PPWR began to apply. Limits on heavy metals in packaging, PFAS limits for food-contact packaging, and the relevant documentation obligations became applicable.
• From 2028: Harmonised packaging-labelling requirements will be phased in.
• From 2030: Design-for-recycling, recycled-content requirements for plastic packaging, packaging-minimisation and empty-space requirements will begin to apply, with further requirements to follow.

PPWR compliance requires ongoing management. Some details and methods will be further clarified through secondary legislation and guidance.

No. PPWR does not establish one universal certificate that can cover every packaging configuration, market and future requirement. A more accurate approach is to connect the applicable provisions, packaging specifications, material information, supplier declarations, test reports, technical documentation, EU declaration of conformity and change records into a traceable evidence chain.

It includes more than the outer carton. Cartons, inserts, dividers, films, bags, tapes, labels, inks, adhesives and cushioning materials may all need to be identified and managed. The first step is not to ask whether a certificate exists, but to map every component and material in each packaging configuration.

Start by confirming which requirements apply. Article 5(4) of the PPWR states that the combined concentration of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components must not exceed 100 mg/kg. From 12 August 2026, food-contact packaging must also meet the specific PFAS limits in Article 5(5). A glass product being used for food does not automatically make its transport packaging “food-contact packaging”; applicability depends on the packaging component’s actual use and contact conditions. Total-fluorine screening can flag potential risk, but it is not a substitute for targeted PFAS analysis.

Compliance cannot be reduced to using less material. Packaging must still support identification, sorting and recycling, including whether labels, inks, adhesives, coatings and different materials can be separated. For glass kitchenware, too much packaging increases resource use, while too little can lead to more transport damage, returns and product waste. Effective minimisation removes unnecessary material and space without compromising safe delivery.

Not necessarily. A test report supports only the samples, materials and test scope it identifies. Changes to ink, label stock, adhesive, film thickness, packaging structure or supplier may trigger reassessment. Reliable PPWR management defines which changes require document review, additional evidence or retesting.

For customers asking where we are today, IKOO GLASS can provide a clear and verifiable set of testing evidence with a clearly defined scope:

• Materials covered: Reports obtained to date cover selected cartons, paperboard, inserts, dividers, plastic films, bags, tapes, label materials, cushioning materials and printing inks.
• Heavy metals: All tested samples received a Pass conclusion against the combined 100 mg/kg limit for lead, cadmium, mercury and hexavalent chromium.
• Total fluorine screening: No total fluorine was detected in the selected self-adhesive label material at the laboratory’s stated method detection limit of 20 mg/kg.
• Evidence boundary: These results apply only to the tested samples and the tests performed. They do not mean that one certificate covers every SKU or future packaging version. Total fluorine screening is also not a substitute for targeted PFAS analysis.

IKOO GLASS is mapping material information, supplier declarations, test reports, packaging specifications and change records to specific packaging configurations. When customers need confirmation, they can quickly identify the relevant packaging configuration, component and evidence.

Under the PPWR, packaging is no longer just a procurement record. It is product compliance information that must be maintained over time. For customers, the real value is not simply being told that a supplier “has a certificate”. It is knowing that the supplier can explain which materials are used in a specific packaging configuration, which evidence supports them, and how changes are reviewed.

· Regulation (EU) 2025/40 — Official text on EUR-Lex

· European Commission — Guidance document for Regulation (EU) 2025/40 (2026)

· European Commission — New EU packaging rules start to apply

· European Commission — Packaging waste overview

Published by IKOO GLASS  |  Last updated November 2026

Disclaimer: This article is based on publicly available EU information and IKOO GLASS’s current testing evidence as of November 2026. It is intended as a practical industry reference and does not constitute legal advice. Applicability should be confirmed against the specific packaging structure, supply chain and target market.