Sep 2, 2026Material Notes
Impact of the EU PPWR on the Baby & Infant Products Export Sector
Based on PPWR text + European Commission guidance (March / August 2026)
What the regulation is ？
- The PPWR (Regulation (EU) 2025/40) is the EU Packaging and Packaging Waste Regulation. It entered into force in February 2025 and has been fully applicable since 12 August 2026, replacing Directive 94/62/EC.
- It regulates the packaging around a product, not the product itself. We export baby bathtubs, potty trainers and similar items to the EU; our packaging is mainly PE poly bags + outer cartons, so the impact falls entirely on that packaging layer.
What it means for us ？
- PE bags must contain recycled (PCR) content: 35% from 2030, rising to 65% by 2040.
- Keep materials separable: PE bags and cartons must not be laminated or glued together, so each material can be recycled on its own.
- Outer carton void ratio ≤ 50% of box volume — don't use oversized cartons for bulky items like bathtubs.
- Heavy metals ≤ 100 mg/kg total (lead + cadmium + mercury + hexavalent chromium) — applies to the PE film and to the printing inks, coatings and adhesives on it.
Supporting actions: issue a Declaration of Conformity (DoC), register for EPR in each EU member state (there is no single EU-wide registration number), and run third-party testing.
Note: if a PE bag is for food-contact accessories (feeding/oral-use parts), the PCR threshold is lower (10% in 2030 / 25% in 2040) — confirm per product.
