PPWR Packaging Support for OEM Buyers

Regulation (EU) 2025/40 has applied since 12 August 2026. If you place sporting goods on the EU market, your packaging now needs a technical file, a signed declaration of conformity and a national EPR registration — and most of that file can only be built from data the factory supplies. Rackets, badminton and pickleball, account for most of our OEM packaging work, so that is where the detail on this page sits. This is what we hand over, and where our responsibility stops.

12 Aug 2026PPWR core obligations apply

100 mg/kgPb + Cd + Hg + Cr(VI), sum of four

5 / 10 yrfile retention, single-use / reusable

0notified bodies involved — Module A

What became mandatory on 12 August 2026

Six obligations. Four of them need something from us; all six end with your signature, not ours.

Obligation	Article	What we supply	What you do
Heavy metals — Pb, Cd, Hg, Cr(VI) sum ≤ 100 mg/kg	Art. 5	Per-material test reports from an ISO/IEC 17025 laboratory	Hold the reports in your file
Recyclability — baseline	Art. 6	Material composition and a qualitative design-for-recycling statement	Include in the assessment
Technical documentation	Art. 38 + Annex VII	BOM, component list, drawings, material specs, test reports	Compile per packaging type, retain
Declaration of conformity	Art. 39 + Annex VIII	The evidence the declaration rests on	Sign it as manufacturer
EPR registration	Art. 45(3)	Packaging weights by material, per component per SKU	Register in each member state
Harmonised labelling	Art. 12 — from 12 Aug 2028	Material composition data for the pictogram	Change the artwork

Dates that are still ahead: 12 August 2028 for harmonised material labelling, 1 January 2030 for the recyclability grades (at least C, 70% by weight), minimum recycled content in plastic packaging and the 50% empty-space limit on sales and e-commerce packaging, and 1 January 2038, from which only grades A and B may be placed on the market.

Who counts as the manufacturer — settle this first

Almost every argument about PPWR paperwork is really an argument about this question. The Commission’s guidance presumes that the owner of the trademark on the packaging is the manufacturer. Having a third party produce it does not move the obligation.

Your setup	Manufacturer under PPWR	Signs the DoC	EPR registration
You sell under your brand, we produce	You, the brand owner	You	You, per member state
You buy our stock range under the FANGCAN brand	Fangcan	Fangcan	Fangcan
You are the EU importer, selling under your brand	You	You	You

Practical consequence: our EPR registration cannot be used for your shipments. Registration attaches to a producer, not to a product. If you import under your own brand, you are the producer and the registration has to be in your name, in each member state you sell into. What we can do is shorten the learning curve — see the EPR section below.

Six things you can ask us for

These are issued per packaging type, not per order. Ask once, and they hold until a component changes.

Packaging BOM by homogeneous material

Every component, broken down the way a lab and a register both need it: substrate, coating, ink, adhesive, label, closure, and the weight of each in grams.

Heavy-metal test reports

Pb, Cd, Hg and Cr(VI) per homogeneous material, from an accredited laboratory, with the method and the sample weight on the report.

Recyclability and minimisation statement

Qualitative, written against the Annex II design criteria and the Annex IV minimisation criteria. No grade is claimed, because the grading standards are not published yet.

Packaging weights by material

The figures your national EPR register asks for, per component per SKU. This is the item buyers most often cannot get from a factory.

Design drawings

Components, layers and dimensions — the Annex VII line that says design and manufacturing drawings.

Change notification

We tell you in writing when a substrate, ink, coating or adhesive changes, because that invalidates the file you built on the old one.

What needs a laboratory, and what does not

This is where money gets wasted. Of the six obligations above, exactly one needs a third-party test report at this stage.

Requirement	Third-party test now?	Reason
Heavy metals, Art. 5	Yes	The only PPWR item that needs laboratory evidence from 12 August 2026.
PFAS	No	The limits apply to food-contact packaging. Sporting goods packaging is not food-contact.
Recyclability grade, Art. 6	No, until 2030	Design-for-recycling standards (CEN/TC 261) are due by 2028. Until then a qualitative statement is what can honestly be given. EN 13430 is a self-assessment reference, not proof of conformity.
Recycled content, Art. 7	No, until 2030	Applies from 1 January 2030; verification rules are still in secondary legislation. Plastic components under 5% of pack weight and under 100 g are exempt.
Minimisation, Art. 10	No	Qualitative assessment against Annex IV. Becomes a hard 50% empty-space limit in 2030.
Declaration of conformity, Art. 39	No	Module A internal production control. Self-assessment. No notified body, no CE mark.

If someone quotes you a “PPWR certification package”, ask which article it is issued under. PPWR creates a self-declaration regime. There is no certificate, no notified body and no CE mark for packaging. What a competent supplier hands you is a technical file and a signed declaration — and what an honest one will not do is sell you a badge.

How the heavy-metal test is actually run

Worth knowing, because a report that does not match this shape will not survive a market surveillance check.

1The unit is the homogeneous material, not the pack. Paper, film, ink, adhesive and metal parts are tested separately. A single result for “the carton” is not usable.

2Pb, Cd and Hg by acid digestion (EPA 3050B or 3052) with ICP-OES or ICP-MS.

3Cr(VI) needs its own method — alkaline digestion (EPA 3060A) and spectrophotometric determination. Total chromium cannot be substituted for hexavalent chromium, and reports that do are wrong.

4Sample size is typically 50 g or more per material, taken from production, not from a hand-made sample.

5Turnaround is commonly 5–9 working days; expedited options exist at a premium.

6Cost scales with the number of materials, not with the number of SKUs. A full packaging set usually breaks down into ten to fourteen homogeneous materials — which is also why consolidating materials across a range saves money twice, on testing and on EPR fees.

7Test the risky ones first: PVC, recycled-content board, dark or metallic inks, plated metal parts, and adhesives. Those are where exceedances actually come from.

Racket packaging, component by component

Rackets are where most of our OEM packaging work sits, so this is where the detail belongs. The breakdown below is the structure we work to; the confirmed BOM for your SKU is issued from the actual specification, because a change of liner supplier or ink is enough to change it.

Configuration	Primary packaging	Materials to declare
Racket only, retail	Card header + OPP bag	Paperboard, PP film, ink, adhesive
Racket with cover	Cover or bag + hang tag + OPP bag	Textile or synthetic leather, paperboard, PP film, ink
Racket set	Folding carton + inner bags + insert	Paperboard, PP film, ink, adhesive
Export master carton	Corrugated carton + tape + stretch film + pallet where used	Corrugated board, BOPP tape, PE film, wood

The same structure applies to badminton and pickleball rackets. Pickleball paddles, string packs and overgrip cards are documented on the same basis — ask and we issue those BOMs too. The testing and the EPR figures follow the material, not the product line.

One specification decision is worth taking early: the shrink film, and any PVC component. If the film is specified as PVC it sits on the wrong side of the 2030 recyclability threshold, and changing it after the artwork is approved costs more than changing it now.

EPR and authorised representative are two different things

Providers routinely sell them as one line item. They are separately defined and separately priced, and a quote that blurs them is worth questioning.

Item	Article	What it actually covers
Authorised representative	Art. 17	An EU-established entity that holds your documentation at the disposal of market surveillance authorities and responds within the statutory window. One representative can cover the whole EU. It does not register you as a producer and it does not pay fees.
EPR registration	Art. 45(3)	Registration in each national packaging register, ongoing reporting of volumes by material, and payment into that country’s scheme. This is per member state — Germany, France, Italy and Spain each run their own register.

What we have already done ourselves

For our own-brand shipments we have completed EPR registration in two markets — Germany, through LUCID, the register run by ZSVR, and France, through the ADEME producer register with an eco-organisation mandate through Citeo — and we have appointed an Article 17 authorised representative. That matters for one reason: the sequence below is something we have walked, not something we read.

Be clear about what that does and does not buy you. Those registrations stand in Fangcan’s name, as producer of our own-brand goods. They are not transferable to your shipments and cannot be quoted on your packaging. What they mean is that we can tell you which portal, which document set and which fee category you are about to hit — and introduce you to the representative we use.

1Decide who the producer is, per market. This determines whose name goes on the register.

2Inventory the packaging by material and weight — the register asks for grams, not descriptions.

3Register in each destination country; allow weeks, not days, and expect country-specific portals.

4Appoint an Art. 17 representative where you have no EU establishment.

5Report volumes on the national cycle and pay the eco-modulated fee. Difficult-to-recycle materials cost more.

Where we can carry the work for you

Beyond the data pack, we can assemble the documentation: build the Annex VII file per packaging type from our BOM and test data, draft the declaration of conformity for your signature, coordinate the laboratory, and put you in touch with the authorised representative we use. The signature stays yours — that part cannot be delegated, and any supplier who offers to sign it for you is offering something that does not work in an audit.

What we will not do

Not offered	Why
Sign your declaration of conformity	The declaration is issued under the sole responsibility of the manufacturer. We are not the manufacturer of your branded packaging, so our signature would be void.
Act as your producer for EPR	Registration attaches to a legal person placing packaging on the market under its own responsibility.
State that our packaging is “PPWR compliant” in the abstract	Conformity is assessed per packaging type against the requirements in force on a date. A general claim is both unverifiable and, under Art. 12, a green claim that has to be substantiated.
Certify recyclability	The grading standards are not published. Anyone certifying a grade today is ahead of the law.

How it runs

1Brief. Which member states, which SKUs, which packaging per SKU, and whether artwork or materials are changing in the same cycle.

2BOM. We issue the packaging BOM by homogeneous material, with weights, for the SKUs in scope.

3Testing. We arrange it per material, or accept reports you already hold if the method and the material match. We flag which materials are the likely exceedance risks before anything is sent out.

4Handover. Data pack, test reports, drawings, recyclability and minimisation statements, and a written commitment to notify you before any component change takes effect.

If you already have a compliance provider, we work to their document list instead. Send it — filling a buyer’s template is faster than arguing about formats.

Questions buyers actually ask

Do I need a notified body for PPWR?

No. Article 38 puts conformity assessment under Annex VII, Module A — internal production control. The manufacturer assesses conformity, compiles the technical file and signs the declaration. There is no notified body in the standard case, and Article 39 does not provide for CE marking on packaging; recital 109 says this is deliberate, so a packaging CE mark is not confused with a product CE mark.

Is there such a thing as a PPWR certificate?

No. PPWR is a regulation with self-declaration, not a certification scheme. What exists is a technical file under Annex VII and a signed declaration of conformity under Annex VIII. If a supplier or a lab offers you a “PPWR certificate”, ask which article it is issued under. There isn’t one.

My supplier says their packaging is PPWR compliant. Is that enough?

It is a statement, not evidence. Ask for two things: the Annex VII technical documentation for that packaging type, and the declaration of conformity naming that packaging type. Annex VIII requires each declaration to identify a specific packaging type, so a blanket “all our packaging complies” line does not satisfy it. Also check the date — the file has to be kept current, not issued once.

Which EU member states are you registered in for EPR?

We confirm the current scope per enquiry, because it changes as we add markets, and a page that lists countries goes stale. Ask us in the brief and we will tell you what is live today, in writing.

Will your heavy-metal reports be enough for my declaration of conformity?

They cover the Article 5 evidence for the materials tested. They do not cover your Article 6 recyclability assessment or your Article 10 minimisation assessment, and they do not make you the manufacturer. You still compile the file for your packaging type and sign the declaration; our reports are one input to it.

We changed the artwork on the carton. Do we need to retest?

Depends what changed. A design change that leaves substrates and inks the same does not create a new packaging type and does not normally require retesting. Changing the ink system, the substrate, a coating or an adhesive does — those are the components the Article 5 test covers, and the technical file has to be updated.

Is PVC in the packaging a problem?

It is the first thing we check. PVC scores badly under design-for-recycling criteria, and from 1 January 2030 packaging placed on the EU market has to reach at least grade C — 70% recyclable by weight. From 2038 only grades A and B may be placed on the market. In racket packaging it turns up in two places most often: shrink film, and synthetic-leather covers. If either is specified as PVC, plan the substitution now rather than in 2029.

Start with the packaging you are already buying

Send the SKU list and the destination countries. We will come back with the packaging BOM, the materials that need testing, and a note on anything in the current specification that will not clear 2030.

Send an enquiry

We usually reply within one business day. For a quotation, please include model, quantity and target market.

Regulatory references: Regulation (EU) 2025/40, Arts. 5, 6, 7, 10, 12, 17, 38, 39, 45 and Annexes VII and VIII; Commission guidance published June 2026. This page describes our documentation support. It is not legal advice, and it does not transfer any obligation that rests on the producer or the manufacturer of the packaging.