The European Union's Packaging and Packaging Waste Regulation (PPWR) is now in full effect, increasing the compliance burden for domestic exporters. Companies must verify various aspects, from the applicability of the regulations to packaging materials, labeling, and registration under the Extended Producer Responsibility (EPR) system.
According to industry sources, the Korea Trade-Investment Promotion Agency (KOTRA) reported that over 730 people registered for its 'EU PPWR Response Webinar' held on August 20. Actual attendance reached 501, with 210 pre-submitted questions, indicating that the PPWR is transforming product design and supply chain management for EU exporters beyond mere environmental regulation.
The PPWR aims to reduce packaging and packaging waste and enhance recycling for products entering the EU market. Since its implementation on August 12, exporters must assess the materials and composition of their packaging and maintain relevant documentation. Requirements for packaging design that considers recyclability, the use of recycled plastic materials, and minimizing packaging will be phased in.
One of the significant challenges for companies is determining the applicability of the regulations during the export process. KOTRA states that the classification of packaging materials is based on functionality rather than the product's material or industry. Packaging that serves sales, bundling, and transportation functions may be subject to regulation. Packaging used in e-commerce may also fall under transportation packaging, necessitating separate verification.
Companies must also clarify the criteria for handling existing inventory. The determination of market release is based on the date of distribution in the EU, meaning products released before August 12 may be exempt from the regulations. However, products released after this date must comply with PPWR requirements, even if produced before the implementation date.
Pre-approval is not required during customs clearance. However, companies must prepare technical documents and declarations of conformity before product release. Exporters must manage documentation carefully, as buyers or importers may request these materials in advance.
Companies should also verify labeling methods in advance. The regulations do not require identifying information for tracking packaging materials to be directly marked on every individual package. If direct labeling is impractical, accompanying documents may be used.
EPR compliance must be addressed on a country-by-country basis. There is no unified registration system at the EU level; instead, each member state operates separate portals and fee systems. Companies exporting to multiple countries must confirm EPR registration and related procedures for each sales country.
The questions submitted during KOTRA's webinar focused on practical issues faced by exporters, including the preparation of technical documents and declarations of conformity, the scope of packaging, and evidence of heavy metal and PFAS testing. Inquiries also covered existing inventory management, the determination of economic operators' roles, and EPR registration and labeling requirements.
Local EU companies have already begun to respond by expanding the use of recycled materials in packaging design and establishing reuse and recovery systems. However, concerns have been raised about the consistency of enforcement across countries as subordinate regulations are developed.
KOTRA advises exporters to secure information on the materials, weight, and composition of packaging items in advance and to establish relevant documentation systems. The Korea Testing & Research Institute (KTR) and the Korea Construction & Living Environment Testing Institute (KCL) are also providing support for heavy metal and PFAS testing, as well as recyclability assessments and technical document compliance.
Additionally, KOTRA plans to hold another PPWR response webinar on August 25 in collaboration with the National Institute of Technology and Standards and the TBT Comprehensive Support Center. Regulatory interpretations and corporate response materials based on the second FAQ released by the European Commission on August 3 will be provided through KOTRA's overseas market news.
* This article has been translated by AI.
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