Information on Scaldia compliance with regulation (EU) 2025/40 on packaging and packaging waste (PPWR)
We would like to inform you about upcoming information requirements related to the EU Packaging and Packaging Waste Regulation (PPWR). At this stage, several elements of the PPWR are still being clarified at EU level, and implementation guidelines continue to evolve. Therefore, the information we provide is based on the best knowledge available as of the date of this information and reflects our current best efforts to support you in preparing for compliance.
Scope
This information is about the most relevant obligations, to be implemented by August 12th 2026.
- PFAS limits (Art. 5) : Limits for food contact packaging
- Heavy metal limits (Art. 5): Limits for all packaging
1. Packaging material
Regarding packaging materials used for shipping products (such as palettes, ream-paper, boxes, stretch foils, etc), Scaldia relies on supplier declarations attesting compliance with applicable regulatory requirements.According to Articles 38 and 39 and 1) Annex VIII, the PPWR primarily requires manufacturers to make the declaration of conformity and keep it together with the technical documentation available to competent authorities upon request. The Regulation does not contain a general obligation to provide the Declaration of Conformity distributors and end-users. Scaldia may track down any delivery upon request from the appropriate authorities in the event of audits at downstream parties in the supply chain.
Conformity assessment procedure declaration of conformity
The manufacturer shall draw up a written Declaration of Conformity for each packaging type and keep it together with the technical documentation at the disposal of the national authorities for 5 years after single-use packaging has been placed on the market, and 10 years after reusable packaging has been placed on the market. The declaration of conformity shall identify the packaging for which it has been drawn up. A copy of the declaration of conformity shall be made available to the relevant authorities upon request.
Based on the information currently provided by our suppliers, Scaldia has no reason to believe that the packaging supplied does not comply with the applicable requirements of the PPWR Regulation. Should further published guidelines be issued by the EU authorities, we will adjust our processes and inform accordingly.
2. Products
This information is not about packaging, but about raw materials suitable to produce packaging material out of it.
Companies producing or converting packaging materials will typically be regarded as manufacturers under the PPWR. Depending on the specific circumstances, the brand owner or end-customer may also assume the role and responsibilities of a manufacturer under the Regulation.
Manufacturers are obliged to draw up a written declaration of conformity, based on the technical documentation they receive from the supplier 2). Scaldia will provide the relevant technical documentation for each product upon request, subject to availability and any applicable confidentiality restrictions.
As of now, we have not yet received these documents from all our suppliers. We continue to collect and review documentation from our suppliers and expect further documentation to become available in the period leading up to the application date of the PPWR.
Please note: This process is necessary only to produce of packaging and packaging components, and not for other printed products. There are still many uncertainties about definition of packaging. For example, uncertainty we see for manuals/instructions (is it part of packaging or part of the product) and if or to what extend envelopes are part of the regulation (eg. not for invoices, but brochures sent with envelopes).
Information obligations of suppliers of packaging or packaging materials
1. Suppliers shall provide the manufacturer with all the information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and the packaging materials with this Regulation, including the technical documentation referred to in Annex VII and required under or pursuant to Articles 5 to 11, in one or more languages which can be easily understood by the manufacturer. That information and documentation shall be provided in either paper or electronic form.