Since August 12, packaging placed on the European Union market requires technical documentation, EU declaration of conformity, and compliance with heavy metal and PFAS limits; a webinar held on September 24 by Think Plastic Brazil and ABIPLAST detailed the role of each link in the export supply chain.
Photo Credits: Envato Elements
Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), has been applicable since August 12, 2026, reaching all packaging placed on the European Union market—whether empty or containing products, manufactured within the bloc or imported. This includes packaging and packaged products exported by the Brazilian industry. The topic brought together over 200 registrants from more than 120 organizations during a webinar hosted on September 24 by Think Plastic Brazil, a portfolio of solutions for the internationalization of the converted plastics sector created through a partnership between ApexBrasil (Brazilian Trade and Investment Promotion Agency) and INP (Brazilian Plastic Institute).
Unlike previous directives, the PPWR applies directly in all European Union Member States without requiring national transposition laws. Published in the Official Journal of the European Union on January 22, 2025, the text repeals the former Directive 94/62/EC and establishes mandatory requirements for technical documentation, official declarations, and strict chemical limits for any packaged product placed on the European market.
New Requirements Raise the Technical Rigor for Packaging
Among the requirements already in effect, strict chemical limits stand out. The total concentration of heavy metals (lead, cadmium, mercury, and hexavalent chromium) cannot exceed 100 mg/kg in packaging or its components.
For food-contact packaging, restrictions on per- and polyfluoroalkyl substances (PFAS) are even stricter, setting limits of 25 ppb for specific analyses and a ceiling of 50 ppm for total PFAS. A crucial warning highlighted by the European Commission’s official guide: there is no grace period or deadline for clearing old inventory.
Manufacturers Take a Central Role in Proving Compliance
The regulation also redefines the roles of economic operators. Under the rule, the manufacturer is defined as the company that fills, seals, and places the final product on the market. Legal responsibility lies with this entity to perform the conformity assessment, draft the Annex VII documentation, and issue the EU declaration of conformity, keeping records stored for up to ten years in the case of reusable items.
“Fast and transparent adaptation is the only way to maintain the competitiveness of Brazilian products in Europe. The new regulation demands technical rigor, but it also opens opportunities for companies that invest in innovation, traceability, and sustainability right now,” highlights Carlos Moreira, Executive Director of INP and CPO at Think Plastic Brazil.
“Legally, the manufacturer is the party responsible for the compliance of this packaging,” summarized panelist Danilo Bordan Istuque from AIMPLAS, a technology center based in Valencia. The assessment follows internal production control, with a declaration made under the manufacturer’s exclusive responsibility. Istuque reported that recommendations in Europe have focused on backing this declaration with heavy metal and total fluorine testing.
In this ecosystem, Brazilian converters act as strategic suppliers, tasked with equipping clients with all necessary technical data. In turn, EU-based importers will be responsible for prior document verification before commercialization.
Targets Advance Through 2040 and Expand Requirements for the Sector
Transformations will continue over the coming years. Starting in August 2028, harmonized material composition labeling becomes mandatory. In 2030, strict weight and volume minimization targets, a 50% empty space limit for grouped packaging, and restrictions on various single-use disposable formats will take effect.
On the same date, design for recycling becomes mandatory: only packaging classified under recyclability grades A, B, or C will be allowed to circulate in the European market, narrowing exclusively to grades A and B by 2038.
Another crucial pillar is the mandatory minimum percentage of post-consumer recycled (PCR) content. For 2030, targets between 10% and 35% are required depending on the plastic application, figures that increase significantly to levels between 25% and 65% by 2040.
Brazil Establishes Mechanisms to Support Exporters
In proactive response to the new requirements, Georgia Albertoni from ABIPLAST highlighted Recircula Brasil—a traceability platform based on electronic invoices and mass balance that digitally certifies recycled content. Concurrently, Leandro Santos Teixeira from the Ministry of Foreign Affairs (Itamaraty) reinforced the government’s commitment to mapping sector costs to inform diplomatic dialogue between Brazil and the European Union.
Full documentation and official application guides for the PPWR are publicly available on the EUR-Lex portal and the official website of the European Commission’s Directorate-General for Environment.
Carlos Moreira
Executive Director of INP and CPO at Think Plastic Brazil
About Think Plastic Brazil
Think Plastic Brazil was created to promote the internationalization of the converted plastics industry. It was created in a partnership between the National Institute of Plastics (INP) and ApexBrasil (Brazilian Trade and Investment Promotion Agency). Think Plastic Brazil started its activities with 38 companies and, over the last 20 years, has expanded its participation to more than 250 companies. During this period, the Portfolio promoted the participation of 4,773 companies in the industry in 240 projects specifically for Trade Promotion, resulting in 64,366 meetings. The economic impact was significant, with more than US$ 1.247 billion in business generated and a total investment of US$ 12.338 million, achieving an impressive ROI of US$ 101.04 for every dollar invested.
For those interested in buying from Brazil and contacting Brazilian companies associated with Think Plastic Brazil directly, please contact richard.assis@thinkplasticbrazil.com via email or visit the website thinkplasticbrazil.com. Think Plastic Brazil is a non-profit, non-commissioned organization that can facilitate your direct contact with Brazilian producers.
About the Brazilian Plastic Institute (INP)
Founded in 1989, the Brazilian Plastic Institute (INP) arose amid the process of globalization and the need to make the plastic market more competitive internationally. Its strength and representativeness are the result of the union of the Synthetic Resin Industries Union in the State of São Paulo (SIRESP) and the Brazilian Processed Plastic and Recycling Industry (ABIPLAST).
As a sectoral technological body, the INP’s goal is to be the focal point for the entire plastics production chain in Brazil. To this end, the body maintains an extensive workforce qualification program, promotes access to the most modern technologies—especially for small and medium-sized companies—and develops Technical Standards so that higher-quality products are manufactured.
About ABIPLAST
The Brazilian Processed Plastic and Recycling Industry (ABIPLAST) has represented the converted plastics and recycling sector in Brazil since 1967, working to expand its competitiveness. The entity promotes new technologies, processes, research, and products focused on sustainability, with the circular economy as a strategic priority. Currently, ABIPLAST represents a universe of over 14.9 thousand plastic converting and recycling companies, which together employ 409.4 thousand professionals across the country.
About ApexBrasil
The Brazilian Trade and Investment Promotion Agency (ApexBrasil) works to promote Brazilian products and services abroad and attract foreign investments to strategic sectors of the Brazilian economy. To achieve its objectives, ApexBrasil carries out diversified trade promotion actions aimed at promoting exports and highlighting the value of Brazilian products and services abroad, such as prospective and trade missions, business roundtables, support for the participation of Brazilian companies in major international trade fairs, and visits by foreign buyers and opinion leaders to learn about the Brazilian productive structure, among other business platforms designed to strengthen the Brazil brand.
The Agency also acts in a coordinated manner with public and private stakeholders to attract foreign direct investment (FDI) to Brazil, focusing on strategic sectors to develop the competitiveness of Brazilian companies and the country.
