✅ Who must comply

You need this if you place packaged products or packaging on the EU market, including:

• 🏭 Brand owners / fillers / packers (you specify packaging)
• 🧱 Packaging manufacturers & converters (you supply components and specs)
• 🚢 Importers (you introduce packaged goods into the EU)
• 🛒 Retail/private-label owners (you control specs, artwork, and suppliers)

☣️ Restriction 1: Heavy metals limit (Pb + Cd + Hg + Cr(VI))

Requirement

EU rules require that the sum of lead, cadmium, mercury, and hexavalent chromium in packaging or any packaging component stays within the Directive’s heavy-metals limits (including the final 100 ppm threshold used across the EU framework).

What “good compliance” looks like

• 📌 A written specification requiring the heavy-metals sum limit for every packaging component (including inks, coatings, adhesives, labels, closures, films, foils).
• 🧾 Supplier declarations tied to part number + revision + site (not generic statements).
• 🧪 Risk-based testing for high-risk items (inks/pigments, coatings, recycled plastics, metallised layers, legacy stock).

If you use plastic crates/pallets with recycled content

A specific EU Decision sets conditions for a derogation for plastic crates and plastic pallets in relation to the heavy-metals concentration levels. Use it only with documented system controls and evidence.

♻️ Restriction 2: Essential requirements (Annex II)

Annex II sets design and composition requirements that, in practice, must be evidenced across three themes:

• 📉 Prevention/source reduction: packaging volume and weight limited to the minimum adequate to maintain safety, hygiene, and acceptance.
• 🔁 Reusability and/or recoverability: packaging designed to enable reuse or recovery (including recycling).
• ⚠️ Minimisation of hazardous substances: reduce noxious/hazardous substances to limit negative impacts during incineration/landfill (emissions/ash/leachate).

🏷️ Marking & material identification (97/129/EC)

The EU identification system provides numbering and abbreviations for packaging materials. Its use is voluntary for the listed materials (plastics, paper/fibreboard, metals, wood, textiles, glass, composites).

How to apply it correctly

• Decide whether your business will use 97/129 codes as a standard.
• If used, ensure markings are governed by a single rulebook (placement, legibility, durability, artwork approval, version control).

📑 Standards commonly used to demonstrate compliance (EN 13427 series)

The European Commission lists harmonised standards used under the packaging framework, including: EN 13427, EN 13428, EN 13429, EN 13430, EN 13431, EN 13432.

Use these to structure:

• source-reduction decisions,
• reuse suitability,
• recoverability route evidence (recycling / energy recovery / composting).

✅ What a company should do to comply

1) 🧩 Create a complete Packaging BoM (Bill of Materials)

For each packaging format/SKU family, capture:

• structure (primary/secondary/transport),
• every component (incl. inks/coatings/adhesives/labels),
• weights, materials, supplier, manufacturing site, and revision.

2) 📜 Issue controlled packaging specifications (with restrictions)

Include:

• heavy-metals requirement (Pb+Cd+Hg+Cr(VI) sum control),
• restricted substances expectations for inks/coatings and recycled inputs,
• mandatory supplier change notification rules.

3) 🤝 Collect supplier evidence (component-level, versioned)

Require:

• Declaration of compliance per component and revision,
• supporting material disclosure where relevant,
• traceable upstream evidence for inks/coatings/recycled feedstock.

4) 🧪 Verify with a risk-based testing plan

Define when to test:

• new supplier/site,
• formulation changes,
• recycled content source changes,
• higher-risk materials and colours/pigments.

Store test reports against the exact component revision.

5) ♻️ Document Annex II essential requirements (one pack per packaging family)

Maintain short, audit-friendly evidence for:

• prevention/source reduction rationale,
• reuse/recovery design intent,
• hazardous substance minimisation controls.

6) 🏷️ Lock marking governance

• one rulebook for 97/129 code usage (if adopted),
• artwork approval workflow and revision control,
• checks to prevent inconsistent markings across markets and suppliers.

7) 📁 Maintain a packaging technical documentation set

Keep (per packaging family):

• BoM + specs + drawings,
• supplier declarations + change history,
• testing evidence,
• essential-requirements assessment,
• approved artwork/markings.

8) 🔄 Run change management as a compliance trigger

Re-check restrictions whenever you change:

• material, supplier, inks/coatings, recycled feedstock,
• design/weight/dimensions,
• market scope or labeling approach.

🆕 Transition to PPWR (EU) 2025/40: dates to plan for

The EU has adopted the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR), which repeals Directive 94/62/EC.
The Commission timeline notes PPWR entered into force on 11 February 2025 and the general application date is 12 August 2026.

⭐ Why ComplyMarket is the best-ever solution for “Packaging Directive Restrictions” compliance

ComplyMarket is a great and exceptional Material Compliance management and reporting platform that turns packaging restrictions into a controlled, auditable process—across packaging BoMs, supplier evidence, testing, marking governance, and technical documentation.

With ComplyMarket, companies can:

• 📦 build structured Packaging BoMs (materials, weights, suppliers, revisions),
• ☣️ enforce restriction rules with validations and approvals,
• 🤝 automate supplier declarations, evidence collection, and change notifications,
• 🧪 manage testing plans and attach lab results to component revisions,
• 🏷️ control marking and artwork approvals with version history,
• 📁 generate compliance-ready documentation and audit trails fast.

If you want the best practical way to comply with Packaging Directive Restrictions and stay ready for PPWR, ComplyMarket brings everything into one integrated compliance system.