The PPWR is now in force. Have you completed your packaging testing compliance?

SHEIN recently released an official announcement: all packaged goods sold to the EU and Northern Ireland require preparation and upload of documents including packaging identification codes, QR codes (or equivalent displays) for packaging manufacturer information, PPWR chemical test reports for packaging, and PPWR Declarations of Conformity (DoC). For sellers, packaging manufacturers and brands, the toppriority issues to resolve are: what tests are required for packaging, according to which specifications samples should be submitted, and how reports can be matched to the packaging actually used.

01. PPWR is in Force – Is Your Packaging Testing Compliance Complete?

The PPWR applies to all packaging and packaging waste regardless of material, origin or application scenario, covering sales packaging, service packaging and transport packaging.

Companies shall first identify all packaging units placed on the market, such as courier bags, ziplock bags, bubble bags, colour boxes, outer hangtag bags, cartons and fillers. Packaging with different materials, dimensions, suppliers or print versions may each constitute separate objects for testing and documentation management.

From NBTS’ compliance perspective, the most frequent issue is not “no testing performed”, but inconsistency between submitted test samples and bulkshipped packaging: submitted samples are plain bags while production uses printed bags; samples are of one dimension but bulk goods use different thickness or material construction; test reports come from an old supplier while procurement has switched to a new one. Even if such reports exist, they cannot effectively support platform reviews or regulatory inspections.

02. SHEIN’s Packaging Control Requirements

SHEIN mandates compliance controls including realworld label photos, test reports and Declarations of Conformity (DoC) for goods sold to the EU and Northern Ireland. Merchants must ensure submitted documents are authentic, complete, valid and correspond exactly to the packaging used for the sold products.

1. Requirements for realworld label photos

• PPWR Packaging Identification Code 

The packaging must bear an identification code for the packaging itself, NOT for the product. Codes may be model numbers, batch numbers or serial numbers. Uniform codes may be used for bags of identical dimensions; differentsized bags shall NOT share the same code. Code format is merchantdefined, consisting of numbers and/or letters only; Chinese characters are not permitted.

• PPWR Packaging Manufacturer Information (QR Code) 

Packaging must display the packaging manufacturer’s name and contact address, which may be achieved by direct printing, adhesive labels or electronic display via QR code.

From February 2027, QRcode display will become mandatory for packaging waste recovery and environmental ERP information. Merchants are advised to design a unified QRcode at the packaging development stage, integrating manufacturer details, contact address and future recoveryrelated environmental information to reduce costs from repeated packaging revisions.

• WPR Registration in each Member State

Under Extended Producer Responsibility (EPR), producers must register in every Member State where packaging is first placed on the market. If the producer has no local establishment in the target Member State, an Authorised Representative (AR) may be required to fulfil EPR obligations.

2. Packaging Report / Certification Requirements

a. PPWR Chemical Test Report for Packaging

Key analytes are four heavy metals: lead, cadmium, mercury and hexavalent chromium, with a total limit of ≤ 100 mg/kg.

Different materials shall be tested separately; sample mixing is strictly prohibited. Carton substrate, printing inks, plastic films, foams and other materials shall be submitted individually according to material type and risk source. For printed, coated, laminated or specialcolour packaging, testing only base materials is not recommended; compliance shall be verified on the final finished packaging.

For foodcontact packaging, PFAS risk assessment is also critical. Without valid test reports, complete technical documentation and a PPWR DoC cannot be established.

Effective 12 August 2026, PFAS in foodcontact packaging shall not exceed the following limits:

· Individual nonpolymeric PFAS ＜ 25 ppb

· Sum of all nonpolymeric PFAS ＜ 250 ppb

· Total polymeric PFAS ＜ 50 ppm; a fluorinecontent test report is mandatory when total fluorine exceeds 50 mg/kg

b. PPWR Packaging DoC

· From 12 August 2026, every packaging type shall be supported by technical documentation plus a DoC.

· Issued by the packaging manufacturer and verified by the importer; supporting documents include packaging descriptions, drawings, material lists, test reports and recyclability assessments.

· DoC shall be updated whenever specifications, materials, suppliers or applicable standards change. Document retention: 5 years for singleuse packaging; 10 years for reusable packaging.

Six key points a valid report must address

1. Tested packaging: name, intended use, material, construction, dimensions, thickness

2. Sample origin: packaging manufacturer, model / batch number

3. Test items: four heavy metals; PFAS (for foodcontact applications)

4. Whether test results meet regulatory limits

5. Associated packaging identification code

6. Consistency between submitted sample and bulkproduction packaging

Management principle: one packaging specification, one complete file

Files shall contain realpackaging photos, material schedules, specification drawings, test reports, supplier information and the PPWR DoC, readily retrievable for platform spotchecks.

NBTS is a recognised testing laboratory for Amazon, SHEIN, TEMU, Alibaba.com, AliExpress, TikTok Shop and other platforms. We provide crossborder sellers with onestop compliance support covering risk assessment, sample testing and document review.

NBTS service scope includes:

· PFAS testing: total fluorine / total organic fluorine results according to EN 14582 or ASTM D73592023; applicable to textiles, footwear materials and coated fabrics.

· Fullscope EU textile chemical testing: REACH SVHC, azo dyes, phthalates, heavy metals, PFAS fractionation and more, allinone.

· DoC template guidance: formatted for SHEIN backend requirements to avoid rejection due to format or missingfield errors.

· Predictable turnaround: draft reports for standard PFAS testing in 57 working days; expedited service available upon request.

· PPWR packaging chemical testing + EPR registration liaison: endtoend EU compliance without engaging multiple vendors.

03. Valid Test Reports Must Match Packaging Specifications OnetoOne

SHEIN requires technical documentation for each packaging specification, with DoC updated upon changes to specifications or standards. For packaging testing, this means reports must clearly answer:

· What packaging was tested: name, intended use, material, construction, dimensions, thickness

· Sample origin: packaging manufacturer, batch or model

· Test scope: four heavy metals plus PFAS where applicable for foodcontact packaging

· Compliance of test results against regulatory limits

· Which packaging identification code the report corresponds to

· Consistency between bulkshipped packaging and submitted test samples

Sellers are recommended to follow the rule: “one packaging specification, one testing file”. Minimum file contents include highresolution photos of physical packaging, material composition sheets, drawings / specifications, test reports, supplier records and the corresponding PPWR DoC.

When platforms request report uploads, label photos or manufacturer information, companies can retrieve records quickly and demonstrate that “this report belongs to this exact bag currently in use”.

04. Common Misconceptions in Packaging Testing

Myth 1: Test plastic pellets only, skip finishedpackaging testing.

Inks, adhesives and laminated layers on finished packaging can affect chemical test outcomes. Testing finished articles better reflects realmarket conditions.

Myth 2: One report covers all specifications.

Different bag styles, dimensions, thicknesses, materials, printing processes or suppliers do not automatically qualify as identical packaging. Valid coverage is determined by material consistency and risk assessment. One NBTS test report can be accepted for audits across multiple ecommerce platforms.

Myth 3: No further management after passing testing.

Packaging is frequentlysourced material. Supplier changes, modified recycledmaterial ratios, print revisions or colour adjustments may require reevaluation of test validity.

Myth 4: Treat test reports and the DoC as separate items.

Test reports supply compliance evidence; the DoC is the manufacturer’s formal declaration of packaging conformity. Reports, DoC, packaging specifications, identification codes and physicalitem photos must crossvalidate each other.

Following PPWR implementation, packaging testing is no longer a lastminute document created just before listing; it forms the foundation of EU packaging compliance. Crossborder sellers should first compile a packaging inventory clarifying material, use case, supplier and specifications for each packaging type. Carry out heavymetal testing, PFAS risk assessment for foodcontact packaging and archive documentation accordingly, to mitigate risks of platform holdups, consumer complaints and regulatory enforcement.

NBTS recommends integrating packaging testing into procurement and design workflows: confirm materials and test requirements before finalising packaging solutions; build your evidence chain prior to mass production. This way, packaging fulfils functional needs AND stands up to PPWR compliance audits.