What tests are required for a PPWR declaration?

Must every item of packaging be laboratory tested before a PPWR declaration?

PPWR does not impose a general obligation to carry out an identical set of laboratory tests for every type and every batch of packaging.

However, the manufacturer must demonstrate that the packaging complies with the requirements applicable to it.

Depending on the case, evidence may include:

• a laboratory report,
• a technical specification,
• material documentation,
• a calculation result,
• a design assessment,
• a supplier report,
• a document concerning the origin of recycled material,
• an assessment carried out in accordance with the appropriate standard or methodology,
• a combination of several different items of evidence.

Testing becomes particularly important where, without measurement, it is not possible to reliably confirm a property required by PPWR.

Annex VII to PPWR – what role do test results play?

Annex VII lays down the conformity assessment procedure and the requirements for technical documentation.

The documentation must enable an assessment of the packaging’s conformity with the relevant requirements and include technical information and evidence enabling the way in which the assessment was made to be understood.

In practice, it may include, among other things:

• design calculation results,
• results of tests carried out,
• test reports,
• material specifications,
• assessments concerning the relevant PPWR requirements.

The term ‘test reports’ should therefore not be interpreted as requiring arbitrary tests to be carried out without first determining which property they are to confirm.

How do you determine which PPWR tests are needed?

The best starting point is a requirements matrix for the specific type of packaging.

For each requirement, answer the following questions in turn:

1. Does the requirement already apply?
2. Does it concern this type of packaging?
3. Which property must be demonstrated?
4. What data do we already have?
5. Is the supplier document sufficiently precise?
6. Is there an appropriate assessment method or standard?
7. Does significant uncertainty remain without testing?
8. Which sample must be tested for the result to be representative?

Only at the end of this analysis is it worth preparing an order for the laboratory.

What tests may be needed for PPWR – requirements map

This is not a “mandatory testing package”. It is a map showing where measurement or testing may be one way of demonstrating compliance.

Heavy metal testing in packaging – when is it required?

Article 5 of the PPWR maintains restrictions on the total concentration of lead, cadmium, mercury and hexavalent chromium in packaging and its components, taking account of the exemptions provided for.

This does not automatically mean that every delivery of every carton must be sent to a laboratory.

First, it is worth checking:

• the material composition,
• the origin of the raw material,
• inks and pigments,
• coatings,
• supplier documentation,
• previous results for exactly the same specification.

If the documentation is insufficient or the risk is elevated, laboratory testing may be the most reliable way to close the gap.

PFAS testing – particularly important for food contact packaging

From 12 August 2026, Article 5(5) establishes specific PFAS limits for packaging intended to come into contact with food.

The PPWR uses three reference levels:

• 25 ppb for an individual PFAS measured by targeted analysis,
• 250 ppb for the sum of PFAS measured as the sum of targeted PFAS,
• 50 ppm for PFAS, including polymeric PFAS.

With such a requirement, a laboratory report can be highly significant, particularly where the supplier is unable to provide sufficient supporting evidence.

However, you should not simply order a test called:

“PPWR test”.

The laboratory should know which criterion under Article 5(5) is to be assessed and what type of material is being tested.

Is total fluorine testing sufficient for PFAS?

Not always.

Total fluorine determination may be a useful screening tool, but the result alone is not automatically equivalent to PFAS content.

Fluorine may also originate from other sources.

Therefore, when interpreting the result, it is necessary to understand:

• what exactly the method measures,
• what the limit of quantification is,
• whether the result allows assessment against the PPWR thresholds,
• whether further targeted analyses are needed.

A “total fluorine” report without additional interpretation should not automatically be described in the documentation as a full PFAS compliance assessment.

Does the recyclability of packaging need to be tested in a laboratory?

Recyclability under the PPWR is not a simple chemical parameter that can be confirmed by a single measurement.

Article 6 establishes a system based on design for recycling criteria and, subsequently, also recycling at scale.

The following may be relevant:

• the main material,
• material proportions,
• labels,
• adhesives,
• coatings,
• closures,
• colourants,
• the behaviour of components during sorting and recycling.

Certain assessment systems may include laboratory tests or process trials, but the official PPWR assessment must ultimately comply with the criteria and methodologies established for the relevant packaging category.

A private recyclability test may be useful evidence, but it should not automatically be treated as the final PPWR grade independently of the applicable delegated acts.

Does recycled content need to be confirmed by laboratory testing?

In many cases, the key will not be a conventional chemical analysis of the finished packaging, but reliable documentation of the origin and proportion of recycled material.

Article 7 provides for minimum proportions of post-consumer recycled plastic content for certain categories of plastic packaging.

The following may therefore be relevant to demonstrate the proportion:

• raw material manufacturer data,
• plastic specifications,
• chain of custody documentation,
• information on the material batch,
• relevant certificates or verification systems, where used.

The method of demonstration must be adapted to the final rules applicable to Article 7, rather than assuming that a single laboratory test of the finished packaging will always determine the legally required PCR content.

What tests may be needed to demonstrate packaging minimisation?

Article 10 requires the weight and volume of packaging to be limited to the minimum necessary to ensure its functionality.

Here, a test does not usually serve to answer “does the packaging weigh 38 g”, but to demonstrate why it cannot safely be reduced, for example, to 34 g.

Depending on the function, the following may be useful:

• compression tests,
• drop tests,
• puncture tests,
• leak tests,
• barrier property tests,
• transport trials,
• validation on the production line,
• product durability tests.

They are not automatically mandatory for every package. They should correspond to the function that the company identifies as limiting further minimisation.

How should reusable packaging be tested?

For reusable packaging, the ability to complete successive rotations while retaining the properties enabling reuse is relevant.

Depending on the format, the assessment may require tests concerning:

• mechanical strength,
• resistance to repeated cleaning,
• leak tightness,
• material degradation,
• the functioning of closures,
• the safety of successive cycles of use.

The scope should be related to the requirements of Article 11 and to the relevant methods and criteria applicable to the specific format.

Does the PPWR require packaging strength testing?

There is no single rule requiring every package to undergo drop, compression or vibration testing.

However, mechanical testing can be very important evidence where:

• strength limits the possibility of minimisation,
• transport packaging must withstand a specified load,
• the material grammage has been reduced,
• the design has been changed,
• the company wishes to demonstrate that a lighter variant does not fulfil the required function.

In that case, the test report is functional evidence, rather than a ‘PPWR test’ in the sense of a universal legal test.

Food-contact packaging may also require testing under other legislation

The PPWR does not replace the rules on materials and articles intended to come into contact with food.

Therefore, for food packaging, the set of tests may arise simultaneously from:

• the PPWR,
• Regulation (EC) No 1935/2004,
• rules concerning the specific material,
• other relevant EU legal acts.

A migration test carried out for the purposes of food-contact rules is not automatically a test of all PPWR requirements.

Similarly, PFAS testing under Article 5(5) of the PPWR does not automatically confirm the material’s full compliance with FCM rules.

Can a test report received from a supplier be used?

Yes, if you can reliably demonstrate that the report relates to the material or packaging you use.

Before including the report in the documentation, check:

• the product code,
• the material name,
• the version or revision,
• the sample manufacturer,
• the test date,
• the method,
• the scope of the parameters analysed,
• the results and units,
• the limits of quantification,
• whether the material has not been changed since testing.

A report concerning a ‘paper packaging sample’ without a code and version has significantly less evidential value than a report clearly linked to the current specification.

Does every batch of packaging need to be tested?

The PPWR does not establish a general rule requiring laboratory testing of every batch of every package.

However, the manufacturer must ensure that production remains in conformity with the technical documentation and the assessed type.

This means that an appropriate production control system is needed.

The frequency of testing may depend on:

• risk,
• process stability,
• raw material variability,
• a change of supplier,
• the requirements of a specific standard,
• other relevant rules.

If other rules or the method used require testing of every batch, that obligation must of course be taken into account. However, it does not automatically arise from the term ‘PPWR’ itself.

Must every PPWR test be carried out by an accredited laboratory?

The PPWR does not establish one general rule under which every test forming part of the documentation must be carried out by an accredited laboratory.

This does not mean that the laboratory’s status is irrelevant.

When assessing the reliability of evidence, it is worth checking:

• the laboratory’s competence,
• the scope of accreditation, if it is accredited,
• the method used,
• method validation,
• limits of detection and quantification,
• the quality assurance system.

In addition, a specific standard, implementing act or other rules may require a particular way of conducting the test.

Article 35 PPWR – the method must deliver a reliable result

The key point is not the name of the laboratory itself, but the quality of the method used.

Article 35 refers to testing, measurement, calculation and assessment methods used for the purposes of demonstrating conformity.

In practice, the method should be suitable for the parameter being tested and ensure a result that can be reliably used in the conformity assessment.

When selecting a method, check:

• whether it measures the correct parameter,
• whether its range covers the level required by the PPWR,
• whether the result is sufficiently accurate,
• whether the method is repeatable,
• whether it takes account of the state of the art,
• whether it complies with applicable standards or methodology, where established.

How do you commission laboratory testing for PPWR purposes?

Do not send the laboratory a request saying ‘please test for PPWR’.

A good testing request should specify:

1. the type of packaging,
2. the exact material and version,
3. the intended use of the packaging,
4. the specific provision or parameter you want to demonstrate,
5. the required limit value, where one exists,
6. the expected method or standard, where applicable,
7. the required limit of quantification,
8. how the sample is to be identified in the report.

This will help you avoid a report that looks professional but does not answer the question required by the PPWR.

What should a test report used in PPWR documentation contain?

How do you select a sample for PPWR testing?

Testing is not useful if the sample does not represent the material actually used in production.

Before sending the sample, it is worth recording:

• the packaging code,
• the material code,
• the supplier,
• the batch number, where relevant,
• the formulation version,
• the production or sampling date,
• the person responsible for sampling.

For multilayer or multi-component packaging, you must also determine whether the following is tested:

• the finished unit,
• a specific layer,
• the raw material,
• the coating,
• each component separately.

This depends on the requirement to be demonstrated.

Can one report be used for several packaging items?

Sometimes, yes, but representativeness must be justified.

For example, several SKUs may use exactly the same:

• carton,
• material,
• bottle,
• film,
• closure.

If the property tested results from identical material and design, one report may potentially serve as evidence for several applications.

However, the documentation should indicate:

report → material tested → representativeness criterion → packaging types covered by the result.

Similarity of the product’s trade name alone is not sufficient.

When must PPWR testing be repeated?

A laboratory result should not be treated as an indefinite certificate unaffected by changes.

The following may require reassessment:

• change of supplier,
• change of raw material,
• change of formulation,
• change of pigment,
• change of coating,
• change of adhesive,
• change in recycled content,
• change of manufacturing process,
• change of packaging design.

Not every change automatically means repeating every test. It must be assessed whether it may affect the property tested.

The best way to plan testing: requirement → evidence matrix

Instead of creating a list of tests for the entire company, it is worth creating a matrix for each packaging type:

This model reduces both the risk of missing necessary tests and the cost of unnecessarily testing everything “just in case”.

What will a laboratory not confirm with a single “PPWR certificate”?

A laboratory can test specific parameters. It does not replace the manufacturer in the full conformity assessment of packaging.

One report does not automatically confirm:

• all requirements of Articles 5–12,
• the correct role of the economic operator,
• the completeness of the technical documentation,
• proper minimisation, if only the chemical composition was tested,
• recycled content, if the test is not intended for this purpose,
• final recyclability according to future criteria merely because the base material is recyclable,
• the overall conformity of packaging merely because PFAS are below the limit.

Therefore, the statement:

“packaging tested for PPWR”

is too general without indicating the actual scope of testing.

Most common mistakes when commissioning PPWR testing

• purchasing a universal “PPWR package” without analysing the requirements;
• testing every packaging item using exactly the same set of methods;
• commissioning testing with “please check PPWR” without specifying the parameters;
• testing a sample whose code is not subsequently included in the report;
• using a result for a different supplier or a different formulation;
• failing to check the limit of quantification;
• confusing total fluorine with PFAS content;
• regarding a single report as confirmation of the entire PPWR;
• repeating costly tests despite having a reliable, current report for identical material;
• failing to reassess after a material change;
• testing a future requirement using a private method and presenting the result as an official PPWR class;
• failing to link the report to the technical documentation.

Testing for the PPWR declaration – checklist before sending the sample

1. Identify the exact packaging type.
2. Determine its version.
3. Identify the PPWR requirements currently applicable.
4. Check supplier documentation.
5. Identify existing evidence gaps.
6. Carry out a risk analysis of non-compliance.
7. Determine whether the test genuinely closes the gap concerned.
8. Select the appropriate method.
9. Check the required limits of quantification.
10. Select a representative sample.
11. Mark the sample code, version and supplier.
12. Provide the laboratory with a specific testing objective.
13. After receiving the report, check the method and result.
14. Link the report to the PPWR requirement.
15. Link the report to the relevant packaging type.
16. Record the period during which the result is representative of the version used.
17. Determine which changes should trigger reassessment.

How do you manage test reports for hundreds of packaging items?

With a large portfolio, the most costly mistake may be not only failing to test, but also repeatedly commissioning the same test.

One material may be used in several dozen packaging types.

If a report is properly described and its representativeness can be demonstrated, the system should allow one piece of evidence to be used in all relevant assessments.

The following relationship is therefore needed:

report → material → supplier → version → PPWR requirement → packaging types.

Following a material change, the system should identify which assessments rely on the old report and require review.

What testing is needed for the PPWR declaration – key conclusions

There is no universal list of PPWR tests mandatory for every packaging item.

The scope results from the requirements applicable to the specific type, the available data and the risk of non-compliance.

In some cases, laboratory testing is the most reliable evidence – particularly for specific substance limits. In others, the appropriate evidence may be a specification, calculation, material origin documentation, functional test or assessment against a harmonised criterion.

The best process is therefore:

requirement → existing data → risk analysis → gap → appropriate method → result → technical documentation → EU declaration of conformity.

This ensures that the company tests what it genuinely needs to demonstrate, instead of carrying out a random package of tests and still not knowing whether the documentation is complete.

FAQ – packaging testing for the PPWR declaration