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Phân tích · 2026-10-03

Packaging rules act somewhere else

Eight articles in, the object of the rules has changed. The first seven asked whether a product is safe and conforming. Packaging asks something else: can it be recycled, how much recycled material is in it, is there too much of it, and who pays for collection.

The rules act somewhere else

Packaging compliance is often treated as an appendix to product compliance: clear the product and the packaging can be whatever. In most markets packaging is a set of requirements of its own, and its aim is recycling and reduction rather than safety.

That produces a practical consequence: a product test report does not cover packaging. Answering a packaging question with a product compliance file answers a different question. Packaging needs three things looked at separately: whether it can be recycled, what it is made of, and who carries the collection cost.

EU: PPWR replaces the old directive, but duties come article by article

The current basis in the EU is the Packaging and Packaging Waste Regulation (EU) 2025/40, usually shortened to PPWR, which replaces the 1994 Packaging and Packaging Waste Directive 94/62/EC. The regulation itself enters into force on the twentieth day after publication, which by the 22 January 2025 publication date works out to 11 February 2025.

What matters is that its duties do not all arrive at once. The text uses two forms: a fixed date, or a number of months after a delegated or implementing act enters into force. So saying PPWR is in force is correct, but it does not mean every packaging requirement is now applicable.

This is the same structure as the battery article, one regulation with a timetable. The difference is that the battery timetable runs by year, while the PPWR timetable hangs more on later acts, which creates windows where the Commission has not yet published the detail.

What the date 12 August 2026 actually holds

The most frequent date in the PPWR text is 12 August 2026, and it is not a general application date. In the text it carries two different kinds of content.

One is a hard duty on businesses: from 12 August 2026, food-contact packaging must not be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS). This one changes material selection directly and is the part an exporter has to handle ahead of time.

The other is a deadline for the European Commission: by that date it must adopt implementing acts establishing harmonised labels, specifications and methodology. Those are not duties on businesses, and reading them as "the day we start filing" is a common mistake.

The distinction is the same discipline as in the battery article, where the Commission's own deadlines are not manufacturer obligations. Reading a European timetable, the first thing to establish is who the subject of that line is.

The EU's second layer: food-contact packaging stacks with food contact law

If the packaging holds food, it must also satisfy the food contact framework, (EC) No 1935/2004 and the material measures underneath it, covered in article 6 of this series. The same carton can therefore be governed by two EU regulations at once: one on how it is recycled, one on whether it transfers substances into food.

The two have different bases, different test items and different forms of evidence. A buyer holding documents for only one of them has checked half the job.

Where the UK and the US land

The UK keeps its own packaging producer responsibility regulations and operates a plastic packaging tax, so the cost side is collected both as tax and as responsibility.

There is no single federal packaging act in the US. Requirements land in two places: producer responsibility legislation in a group of states, with California among those moving on recycled content and collection responsibility; and phytosanitary requirements for wood packaging, which apply to export pallets under international standard ISPM 15. For the US market, packaging compliance looks more like a checklist to be worked through by state and by mode of transport than a single national mark.

China, Japan, Korea, Brazil, Australia-NZ

China has two lines: food-contact packaging goes under the GB 4806 series covered in article 6, and limits on excessive packaging sit in a separate mandatory standard, GB 23350, with parts by product category. Japan has its container and packaging recycling act, imposing collection duties; Korea has packaging material and structure standards under its resource recycling act, including limits on over-packaging; Brazil has reverse logistics arrangements under its national solid waste policy; Australia and New Zealand have national packaging targets with state-level regulation moving forward.

For these markets we currently hold the regime described but no primary text, so the page states the regime and no document numbers.

Ten markets side by side

Two columns, what is constrained and who pays:

Read across, the biggest difference between packaging and the other categories in international trade is this: its cost is not a one-off testing fee but an ongoing producer responsibility. The first is paid once; the second is paid every year.

What to ask before you order

Ask four things about packaging: what material it is and whether it can enter the target market's recycling system, since accepted materials differ and the same composite can be judged non-recyclable in one market and not another; whether it touches food, which brings in a second set of food contact documents from article 6; whether it exceeds the target market's over-packaging limits, since layer counts and void ratios are hard requirements rather than aesthetic ones; and who registers the producer responsibility, because EPR in the EU and several other markets must be filed by a local entity, and this is the step most often left unclaimed.

The last question tends to surface only after the goods have landed. The product is fine, the material is compliant, but nobody completed the EPR registration, so the goods cannot be listed. To work through this in order, start with the free verification checklist. The previous article in this series is cosmetics and personal care, which closes the consumer goods group; the series then moves to industrial products. To see how certifications and compliance documents are recorded, look at a report sample, or get in touch.