Packaging and Packaging Waste Regulation (PPWR)

Midas Safety is monitoring all requirements related to the Packaging and Packaging Waste Regulation (EU) 2025/40. As a responsible and forward-looking manufacturer, we are committed to ensuring our operations and those of our partners meet the PPWR requirements. This document provides a structured overview of the PPWR scope, timelines, and practical implementation steps, with a focus on how Midas Safety supports compliance with PPWR.

Understanding the PPWR

The European Union has updated its framework for packaging with Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR). It replaces the previous Packaging and Packaging Waste Directive (PPWD) – Directive (EU) 2018/852 (94/62/EC) and introduces binding, measurable requirements across the full packaging lifecycle, from material composition to end-of-life recyclability.

The regulation applies to any company placing packaging and packaged products on the EU market, regardless of where those products are manufactured. For importers and distributors of protective gloves, this means your product packaging — from polybags to pallet wrap — now falls within the scope.

The regulation is not designed to be disruptive. It is a phased transition with clear milestones, and the core intention is sensible: reduce unnecessary packaging waste, phase out harmful substances, and make recycling genuinely viable across Europe.

The Road to 2040: A phased transition

Rather than a single compliance deadline, the PPWR introduces a structured timeline. This gives supply chains the time to adapt step by step. The milestones below cover the most relevant requirements for glove packaging:

• 12 August 2026
  General Application Gate — chemical safety limits, traceability, Technical Files, and EU Declarations of Conformity become mandatory for all packaging entering the EU market.
• 1 January 2030
  Design for Recycling Gate — all packaging must achieve a recyclability grade of A, B, or C. Grades D and E will be restricted from the market.
• 1 January 2035
  Recyclability at Scale Gate — packaging must be proven to be collected, sorted, and processed within European infrastructure, with a verified 55% net recycling rate.
• 2040
  Ultimate Circularity Target — mandatory 30% overall reduction in packaging mass compared to 2018 baselines, completing the transition to a closed-loop material economy.

The milestones above reflect the primary phase-in dates most relevant to glove packaging. Additional structural requirements apply across the full regulatory roadmap.

 

What Changes on 12th August 2026

The first and most immediate milestone is the General Application Gate on 12 August 2026. From this date, packaging entering the EU market must meet a clear set of validation requirements. Here is what this means in practical terms:

1. Each packaging format has its own compliance profile

Compliance is assessed at the level of individual packaging types, not the finished product SKU. Because transport packaging is fully in scope, a typical shipped glove order will require 3 to 5 separate Declarations of Conformity — covering items such as dispenser boxes, polybags, pallets, stretch wrap, and strapping bands. This is a structural requirement, and Midas Safety’s documentation is already built around this model.

2. Technical Documentation (Annex VII Engineering Dossiers)

Every packaging type requires a comprehensive technical file: a precise Bill of Materials (BOM), substrate material classifications, and component net weights. A signed Declaration of Conformity must be underpinned by this documented evidence. We maintain this data within our ERP systems and it is available on request.

3. Heavy Metals Safety Limits (< 100 ppm)

The cumulative concentration of Lead, Cadmium, Mercury, and Hexavalent Chromium must remain below 100 mg/kg (100 ppm) in every distinct packaging type. We conduct independent laboratory testing for our packaging layers to ensure ongoing compliance.

4. PFAS Restrictions (food-contact packaging only)

PFAS restrictions under Article 5 apply exclusively to food-contact packaging. Protective glove packaging is not food-contact and is therefore outside the scope of this particular requirement.

5. Warehouse stock and “Placing on the Market” timing

The regulation applies at the moment that goods are first “placed on the market” — defined as the first legal transfer of ownership. Practically speaking:

• Packaging already transferred to an owner or distributor before 12 August falls under the previous rules and may continue to be distributed.
• Packaging that remains in the factory’s inventory after 12 August must fully comply with the new rules before it can enter the market.

6. Extended Producer Responsibility (EPR) and legal roles

EPR registration and fee payments are required in every EU Member State where a product is first made available to end-users — not just the country of initial import. The legal responsibilities are defined as follows:

• Legal Manufacturer: Any entity that places its brand or trademark on the packaging or specifies the dimensions of packaging in a design brief, holds the status of Manufacturer and must issue the Declaration of Conformity.
• Importers and Distributors: They do not draft or sign Declarations of Conformity. Their legal responsibility is to verify, request, and securely retain valid documentation from the Manufacturer.
• Producers: Companies that first make a packaged product available on a member state’s national market. They register for EPR in every member state where products are placed and pay financial contributions

7. Data Retention and Retrieval

All compliance assets — technical files, laboratory test reports, and Declarations of Conformity — must be securely archived for a minimum of 5 years (single use packaging). Operators are required to retrieve and deliver complete technical files to European enforcement authorities within 10 working days of an official audit request.

 

How Midas Safety has prepared

Protective glove packaging is inherently multi-layered — polybags, dispenser boxes, cartons, pallets, and ancillary transport materials all fall within the regulation’s scope. Here is what we are doing to meet compliance:

• Full packaging sub-vendor audits. We conduct comprehensive technical evaluations of our packaging suppliers, ensuring all raw material supply chains are aligned with Regulation (EU) 2025/40.
• Independent laboratory testing. We conduct independent absence testing for heavy metals at certified external laboratories, verifying that all distinct packaging layers sit safely below the 100-ppm threshold.
• ERP-level BOM data and Declarations of Conformity. We extract and map precise packaging component breakdowns directly from our ERP systems. This gives customers a clean Bill of Materials data and standard-aligned, and our Declarations of Conformity for further usage.
• EU order prioritization. We are prioritizing orders destined for the EU market ahead of the 12 August compliance gate to ensure no disruption.
• 10-day retrieval readiness. Our data architecture is designed to support the strict 10-working-day retrieval window required during customs checks or enforcement audits.

 

What this means for you:

For most of our customers, the transition will be straightforward. Here is a simple checklist of what you should consider on your side:

• Request your EU Declarations of Conformity from Midas Safety to support your own documentation – we will provide these for all packaging layers associated with your orders.
• Verify that you have a process to store compliance documentation for a minimum of 5 years.
• Ensure that EPR registration is in place in each EU Member State where you first make products available to end-users. This is the legal responsibility of the local EU Operator and we can provide the underlying technical data to support this registration.
• If you apply your own brand or trademark to the packaging, or specify packaging dimensions in your design briefs, you hold the status of Legal Manufacturer and will need to issue your own Declarations of Conformity. We can provide the supporting technical data you need to do this.
• If you have existing warehouse stock being transferred before 12 August 2026, document the date of transfer — this stock can continue to be distributed under the previous rules.

 

Looking ahead

The PPWR is a genuine step forward for European sustainability. The milestones beyond 2026 (recyclability grades in 2030, verified recycling rates in 2035, mass reduction targets in 2040) will require ongoing attention, but they are designed to be achievable with a phased approach.

We will continue to monitor the regulatory landscape and keep our customers informed as guidance evolves, including any delegated acts that clarify specific technical requirements.

 

Questions? We’re here to help.

If you have questions about specific orders, documentation requirements, or how the regulation applies to your particular situation, please reach out to your Midas Safety account manager. We are committed supporting you to make this transition as simple.

 

Disclaimer: This document is provided for informational purposes and reflects Midas Safety’s current understanding of Regulation (EU) 2025/40. It does not constitute legal advice. We recommend consulting a regulatory specialist for guidance specific to your legal situation.