With reference to the implementation timeline of the EU Packaging and Packaging Waste Regulation (the “PPWR”, Regulation (EU) 2025/40), the requirements shown in the chart are reviewed and analysed item by item as follows:

1. Entry into force of the Regulation as a whole and repeal of the old Directive

Requirement: The PPWR entered into force on 11 February 2025. It comprehensively replaces the Packaging and Packaging Waste Directive (94/62/EC), which had been in force for nearly 30 years. Under the PPWR, the old Directive is repealed and ceases to apply 18 months after the entry into force of the new Regulation, i.e. on 12 August 2026.

Chart check: Placing “repeal of 94/62/EC” at 2026/8/12 in the chart is correct. However, it should be noted that 2025/2/11 is merely the date on which the legal text entered into force and the transitional period began to run.

2. Restrictions on hazardous substances (heavy metals and PFAS)

Heavy metals: Article 5 of the PPWR provides that the sum of lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr(VI)) in all packaging shall not exceed 100 mg/kg. This limit effectively applied from the entry into force of the Regulation on 11 February 2025 and remains continuously applicable thereafter. It is therefore reasonable for the chart to list it separately under the 2025/2/11 node.

PFAS: The Regulation introduces strict restrictions on PFAS (per- and polyfluoroalkyl substances) in food-contact packaging — for example, total fluorine content not exceeding 50 ppm. These restrictions are explicitly and fully applicable from 12 August 2026 .

3. Packaging recyclability and eco-design requirements

Recyclability requirement: From 12 August 2026, all packaging placed on the EU market must be recyclable. As for the “recyclability requirement” labelled in the chart at 2028/2/12, and read together with the “recyclability grading requirement” at 2030, it is inferred that the 2028/2/12 date refers to the European Commission’s obligation to adopt, before 12 February 2028, the detailed technical standard for recyclability grading (e.g. the quantitative definitions of Grades A / B / C) .

Compostable packaging requirement: The Regulation requires that, before 12 February 2028, the EU shall establish harmonised technical specifications for compostable packaging, and that such packaging shall be preferentially designed for material recovery rather than mere composting.

Packaging labelling requirement: From 12 August 2028, all packaging must bear a harmonised material-identification label and a sorting pictogram, and the use of digital carriers such as QR codes is encouraged .

Recycled-content requirement: This is a long-term, phased target. From 1 January 2030, plastic packaging must contain a minimum proportion of post-consumer recycled (PCR) material — for example, single-use beverage bottles must contain at least 30% PCR.

Packaging minimisation requirement: From 1 January 2030, manufacturers must ensure that the weight and volume of packaging are minimised for its function — for example, the empty space ratio of transport packaging must not exceed 50% — so as to eliminate excessive packaging .

Given that the current date is August 2026, the EU PPWR is now in full mandatory application. If your company exports goods to the EU — for example the “uncoated kraft paper tape” previously mentioned — immediate action is required. Priority verification should focus on the following points:

• Substance compliance: Ensure the total heavy-metal content of the packaging material does not exceed the limit; where food contact is involved, strictly verify PFAS content.

• EPR registration: Complete Extended Producer Responsibility (EPR) registration in the target Member State(s) and fulfil declaration and fee-payment obligations.

• Declaration of Conformity (DoC): Prepare the technical file and issue the EU Declaration of Conformity.

• Labelling and minimisation: Check that the correct material label is already applied to the packaging, and that the empty space ratio complies with the minimisation requirement.