PPWR (EU 2025/40) Compliance Feedback Report

Document Information

Document Name: PPWR Packaging Compliance Feedback Report for EU Export Regulation: Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR) Version: V1.0 Date: 2026-09-09 Applicable Product: Adjustable Dumbbell (Fitness Equipment) Target Market: All EU Member States Mandatory Effective Date: 12 August 2026. All packaging placed on the EU market must comply with this regulation from this date.

1. Brief Introduction to PPWR

PPWR is the new EU packaging regulation replacing the old 94/62/EC Packaging Directive. It applies directly in all EU member states without national transposition. PPWR governs all packaging materials used to contain, protect, transport or present goods, not only the retail colour box. It covers retail boxes, outer shipping cartons, foam inserts, adhesive labels, packing tape, wooden pallets, etc. Any packaging accompanying products entering EU is subject to PPWR requirements, for both B2B and B2C, cross-border online and wholesale shipments.

2. Packaging List of Adjustable Dumbbell Subject to PPWR

3. Mandatory PPWR Compliance Requirements

3.1 Heavy metal limit test (compulsory)

For all homogeneous packaging materials (paper, plastic, printing ink, glue, coating): Sum of four heavy metals: Pb + Cd + Hg + Cr(VI) ≤ 100 mg/kg. A third-party lab test report is required as supporting evidence.

Note: This consumer fitness product is non-food-contact, PFAS testing is not mandatory for this item.

3.2 Packaging design rules

1. No overpackaging; void ratio must meet PPWR waste reduction criteria.
2. Packaging shall be designed for recyclability; prefer single material construction and minimise multi-layer non-separable composite materials.
3. Starting from 2030, packaging must achieve recyclability class C or higher.

3.3 Required documents for customs & market surveillance

1. PPWR Declaration of Conformity (DoC) Issued and signed by brand / manufacturer per PPWR Annex VIII, stating packaging complies with Article 5~12 of Regulation (EU) 2025/40.

Important: DoC is a self-declaration document and must be used together with complete technical file, cannot be used standalone.

2. Technical Documentation (TD) Packaging drawings, BOM of packaging materials, supplier certificates, lab test reports, packaging photos, recyclability assessment and traceability records. Customs may request full technical file for inspection at any time.

3. EPR (Extended Producer Responsibility) Registration Register packaging EPR in each EU country where the goods are sold, to fulfil packaging waste recovery and payment obligations. Separate registration is required country by country.

3.4 Packaging marking (long-term requirement)

Unified EU packaging waste sorting labels will be mandatory printed on packaging from August 2028.

4. Current Status & Action Items (Key Feedback)

Product: Adjustable dumbbell for EU export

✅ Product itself: CE and mechanical safety certification for dumbbell is independent from PPWR. PPWR only regulates PACKAGING, NOT the dumbbell product itself.

⏳ Pending tasks:

• Collect samples of all packaging components (colour box, outer carton, foam, label paper, tape) and submit to third-party laboratory for 4 heavy metal testing to obtain test report.
• Compile full packaging technical documentation (TD).
• Draft and sign PPWR Declaration of Conformity (DoC).
• Complete packaging EPR registration for target EU countries.
• Review packaging construction, assess overpackaging risk and optimise materials for better recyclability.
• Include printing ink on warning / model labels into the scope of lab testing.

⚠️ Risk Warning After 12 August 2026, shipments without full PPWR compliance documents may be detained by EU customs, face heavy fines or product delisting on e-commerce platforms. There is no grandfathering exemption for old stock. All newly placed batches must be compliant.

5. Recommended Timeline

6. Summary

For this batch of adjustable dumbbells exporting to EU, the full set of inner & outer packaging, cushioning materials and printed adhesive labels are all under PPWR control. We must complete heavy metal testing, build technical documentation, issue PPWR DoC and register EPR to achieve market access in EU. PPWR compliance is a separate entry requirement for packaging. It cannot replace the CE product safety certification of dumbbells.