The Australasian Institute of Packaging (AIP) hosted a State of Industry webinar on 9 July, where Lina Wimmer, senior consultant at Circular Analytics, and Manfred Tucker, managing director at Circular Analytics, outlined new European Union packaging compliance requirements under the Packaging and Packaging Waste Regulation (PPWR).
The webinar focused on the obligations for companies supplying packaging into the European market, including new requirements for declarations of conformity, technical documentation and substances of concern applying from 12 August.
Wimmer said the PPWR is a harmonised regulation that will apply across all European Union member states from 12 August.
She explained that manufacturers placing packaging on the European market under their own name or trademark are responsible for carrying out conformity assessments, preparing technical documentation and issuing a declaration of conformity. Importers are responsible for reviewing this documentation and ensuring packaging complies with the regulation before it is placed on the market.
A key requirement taking effect from 12 August is Article 5, which introduces limits for substances of concern, including PFAS and heavy metals in packaging.
Wimmer said there would be no transition period for the PFAS requirements.
"All products that are being placed on the market after 12th of August of this year must be compliant with the PFAS requirements and also with the heavy metal requirements," she said.
She said this applies even where packaging was manufactured before 12 August if it is placed on the European market after that date.
The webinar also covered European Commission guidance for PFAS testing, which recommends an initial assessment of total fluorine content before further analysis is undertaken where required.
Tucker said, "A supplier declaration is very important, but alone will not be enough here for the compliance of PFAS."
He outlined a risk-based PFAS assessment methodology that considers material composition, production processes, finishing and packaging structure to classify packaging into four risk categories and identify where additional testing may be required.
Tucker said the methodology creates a documented process that can be incorporated into technical documentation and compliance systems.
"PFAS compliance is not just a testing challenge, it's a supply chain management challenge," he said.
The webinar also covered the declaration of conformity required under the PPWR, which Wimmer described as the legal document confirming packaging complies with Articles 5 to 12 of the regulation.
Each packaging type placed on the European market requires a declaration of conformity supported by technical documentation. The documentation must include packaging specifications, applicable standards, supplier information, risk assessments and relevant test reports where required.
The declaration of conformity must be made available to national authorities on request, with documentation retained for five years for single-use packaging and 10 years for reusable packaging.
Future PPWR requirements will include packaging labelling requirements from 2028, followed by recyclability, recycled content, packaging minimisation and reuse requirements from 2030.
