Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), entered into force on 11 February 2025 and became fully applicable on 12 August 2026, replacing Directive 94/62/EC. It applies directly in the 27 EU member states: no national transposition step, and no grace period for food-contact packaging placed on the market from that date. For importers of molded fiber tableware, trays and food containers, compliance documentation has moved from an after-sales formality to a purchase condition. This page covers what applies now, where responsibility sits, and how Grandlink Hopes supports buyers in assembling a documentation pack.
What already applies (from 12 August 2026)
- PFAS: food-contact packaging containing PFAS above the PPWR limits may not be placed on the EU market, whether or not the PFAS was intentionally added. Limits recorded in our market research: any single non-polymeric PFAS 25 ug/kg; sum of non-polymeric PFAS 250 ug/kg; total organic fluorine 50 mg/kg.
- Heavy metals: combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium.
- Annex VII technical documentation: must be established and retained for 5 to 10 years.
- EU Declaration of Conformity (DoC, Article 39).
- Design-for-recyclability obligations.
- EPR producer registration (Article 45); producers outside the EU generally need an authorised representative in a member state.
Where responsibility sits for products made outside the EU
The importer placing third-country goods on the EU market carries the compliance obligation, and must be able to produce the Annex VII technical documentation and the DoC and show that PFAS and heavy-metal limits are met for the item and grade actually shipped. A supplier that cannot provide PFAS and heavy-metal test data on those items does not merely slow an order down – it creates market-access risk for the importer.
What comes next (plan beyond this season)
- 1 January 2027: compostability requirements for specified categories.
- Earliest 12 August 2028: harmonised EU labelling.
- 1 January 2030: recycled-content thresholds and recyclability grading.
- EUDR (Regulation (EU) 2025/2650) applies from 30 December 2026 for large and medium operators and traders, with small and micro operators later (30 June 2027). Pulp, paper and paper-based packaging are in scope, so fibre-origin due diligence becomes part of the sourcing file. Source: European Commission access2markets.
What Grandlink Hopes provides
Grandlink Hopes is a trading and supply-chain integrator. We coordinate qualified suppliers and help importers close the documentation gap:
- Supplier screening against the buyer’s specification: process route and item scope, material origin, food-contact documentation, willingness to release test data.
- Documentation support: coordinating PFAS and heavy-metal test reports for the specific items and grades ordered, from qualified third-party laboratories.
- Annex VII technical documentation support and DoC support for the importer’s file.
- EUDR-related fibre-origin information collected from suppliers to feed the importer’s due-diligence record.
- EPR and authorised-representative coordination guidance.
We do not describe products as certified or PPWR-compliant unless a named certificate or test report exists for the specific item and grade and the certificate holder’s terms allow the reference. This page makes no price, MOQ or lead-time commitments.
Importer checklist before ordering
- Confirm item scope and process route of the SKU.
- Request PFAS and heavy-metal test reports stating test method, laboratory, sample date, item reference and reporting limit.
- Confirm the documentation pack: Annex VII technical documentation, DoC, retention period.
- Confirm fibre-origin information for EUDR due diligence, EPR registration status and any in-country representative.
- Keep records for the required retention period.
Note for US-bound shipments
PPWR is an EU regime and does not govern US imports. For US imports of thermoformed molded fiber products, separate AD/CVD orders apply from 27 January 2026; scope is defined by process, and pulp type, coating or finish does not change subject status. Rates are set per company; the Federal Register notice referenced in our market research cites China-wide AD of 477.97 percent and Vietnam-wide AD of 260.56 percent, with company-specific rates. Subject items are therefore outside our US offering. For non-subject molded pulp food packaging, US supply can be discussed subject to HS and origin verification.
Frequently asked questions
Is PPWR already in force?
Yes. It entered into force on 11 February 2025 and has been fully applicable since 12 August 2026, replacing Directive 94/62/EC.
What are the PPWR PFAS limits for food-contact packaging?
As recorded in our market research: 25 ug/kg for any single non-polymeric PFAS, 250 ug/kg for the sum, 50 mg/kg total organic fluorine, whether or not intentionally added.
Who is responsible when the packaging is made outside the EU?
The importer placing the goods on the EU market, who must be able to produce the Annex VII technical documentation and the DoC.
What is Annex VII technical documentation?
The PPWR documentation set supporting conformity of the packaging, to be established and retained for 5 to 10 years.
Can molded fiber packaging still be sold into the EU after August 2026?
Yes, if the item meets the applicable food-contact requirements and the documentation is available. Non-fluorinated fiber tableware is not banned as a category; it must be demonstrably compliant.
Can you provide PFAS test reports?
We coordinate documentation: reports on the specific item and grade from qualified third-party laboratories. Which items currently have reports on file must be verified item by item.
What are the EU labelling and recycled-content deadlines?
Harmonised labelling earliest 12 August 2028; recycled-content thresholds and recyclability grading from 1 January 2030.
Do the US AD/CVD orders apply to bamboo or bagasse tableware?
For thermoformed molded fiber products subject to the 27 January 2026 orders, subject status follows the process, not the pulp; bagasse or bamboo pulp, coatings and finishes do not change it. Check scope and HS classification per item.
Next step
Send your SKU list and destination market, and we will confirm which documentation our screened suppliers can support. Contact us. No pricing, MOQ or lead-time commitments on this page.
Sources
Regulation (EU) 2025/40 (PPWR) and European Commission access2markets guidance; U.S. Federal Register, thermoformed molded fiber orders (27 January 2026); internal market research, September 2026.
Planning your next container?
Send your item specification, destination market and volumes. We screen suppliers against your spec, coordinate the documentation pack for your market, and come back to you with what we can support.