EU PPWR Packaging Regulation Fully Enforced – FarSun Solar Mounting Supplier Is Fully Compliant

Dear European Customers,

On 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) officially entered into full force across all 27 Member States. This regulation completely replaces the nearly 30‑year‑old Packaging Directive (94/62/EC). By upgrading from a “Directive” to a “Regulation”, it has direct legal effect and applies uniformly in all Member States without the need for national transposition – meaning stricter enforcement and harmonised rules.

Most critically: from 12 August 2026 onward, any packaging placed on the EU market without a corresponding Declaration of Conformity (DoC) and technical documentation may be detained by customs. Even if your product itself bears CE marking, non‑compliant packaging will stop your goods at the border.

As your solar mounting supplier, FarSun has completed all preparatory work for PPWR packaging compliance. Below we outline the specific actions we have taken and the complete set of compliance documents you will need for selling in the European market.

1. What is PPWR and Why Should You Care?

PPWR applies to all types of packaging materials (plastic, paper, metal, glass, composites, etc.) and all scenarios (industrial, commercial, consumer, logistics packaging). It sets systematic requirements throughout the packaging lifecycle, including:

• Hazardous substance control – heavy metals and PFAS restrictions

• Recyclability requirements – packaging must be recyclable

• EPR registration – extended producer responsibility

• Technical documentation and Declaration of Conformity – mandatory compliance files

The consequences of non‑compliance are severe: customs detention, platform delisting, product recalls, fines up to 6% of the company’s global annual turnover, and in serious cases, permanent exclusion from the EU market.

2. What We Have Done as Your Solar Mounting Supplier

(1) Hazardous Substance Control – Fully Compliant

PPWR imposes strict limits on hazardous substances in packaging materials:

Heavy metal limits: The total concentration of lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr(VI)) in all packaging components – including outer cartons, inner liners, labels, inks, adhesives, cushioning foam, plastic bags, pallets, etc. – must not exceed 100 mg/kg. This requirement applies without any exemptions and has been in force since 12 August 2026.

Our commitment: We have carried out laboratory heavy metal testing on all packaging materials used for our solar mounting systems (cartons, pallets, stretch film, cushioning materials, labels, tapes, etc.). The test reports show total heavy metal content well below the 100 mg/kg limit.

PFAS control: PPWR sets stringent limits for PFAS (per‑ and polyfluoroalkyl substances) in food‑contact packaging – individual PFAS substance ≤25 ppb, sum of PFAS ≤250 ppb, and total fluorine ≤50 ppm. Although our solar mounting packaging is not food‑contact packaging and is therefore not subject to the mandatory PFAS limits, we have proactively tested our packaging materials for PFAS to ensure forward‑looking compliance.

(2) Recyclability – Achieved

Since 12 August 2026, all packaging placed on the EU market must be recyclable. From 1 January 2030, recyclability performance will need to meet grades A, B, or C (packaging with recyclability below 70% will be considered “technically non‑recyclable” and prohibited).

Pending the issuance of specific technical standards, we have completed our packaging recyclability design assessment by referring to the harmonised standard under the former directive, EN 13430:2004. Our packaging solutions prioritise single‑material designs and avoid non‑separable multi‑layer composites, ensuring that our packaging can be effectively recycled in existing recycling streams.

(3) EPR Registration and Authorised Representative – In Place

Non‑EU companies must complete EPR registration separately in each country of sale, obtain the unique registration number (ERN) for that country, and regularly report packaging volumes and pay environmental fees.

Key requirement: Non‑EU companies do not have an EU legal entity and must appoint an EU‑based authorised representative (AR) in each country of sale to fulfil EPR obligations. One AR cannot cover the entire EU; separate appointments are required for each Member State.

We have completed EPR registration and appointed local authorised representatives in all major EU sales countries (Germany, France, Poland, Belgium, Bulgaria, and others). You do not need to bear any EPR registration obligations for our packaging.

(4) Technical Documentation and Declaration of Conformity (DoC) – Ready

This is the core document for PPWR compliance. Under Article 39 of PPWR, the manufacturer must carry out conformity assessment of the packaging in accordance with the applicable requirements and issue a DoC certifying that the packaging complies with Articles 5 to 12 of PPWR.

Important: The PPWR DoC is not a stand‑alone document; it must be supported by a complete technical documentation file. The DoC is issued solely by the brand manufacturer/compliance responsible party, who bears full legal liability. Generic templates cannot be used arbitrarily.

We have prepared the following complete set of documents for you:

Document retention period: 5 years for single‑use packaging, 10 years for reusable packaging. Market surveillance authorities may request these documents at any time, and companies must respond within 10 working days.

(5) Packaging Labelling – Compliant

Since 12 August 2026, packaging (including transport packaging) must bear manufacturer identification and traceability markings. We have completed all packaging labelling requirements in accordance with PPWR, ensuring full traceability for every shipment.

3. What Do You (the European Customer) Need to Do?

As the entity placing the packaging on the EU market, you are ultimately responsible for compliance. However, we have done all the heavy lifting for you. All you need to do is one thing: request from us and present to EU customs and market surveillance authorities the complete PPWR compliance documentation package, which includes:

1. EU Declaration of Conformity (DoC) – signed per packaging type

2. Complete Technical Documentation – all supporting evidence for the DoC

3. Heavy Metal Test Report – from laboratory testing

4. Material Composition Declaration – full composition and traceability

5. Recyclability Assessment Report – based on EN 13430

6. EPR Registration Certificates – registration numbers and AR details for each sales country

4. Our Advantages

As your solar mounting supplier, we understand that compliance is the foundation of long‑term partnerships. We not only provide high‑quality solar mounting products but also remove all compliance obstacles for you on packaging:

✅ All packaging materials have passed laboratory heavy metal testing
✅ Recyclability design assessment completed
✅ EPR registration completed in multiple EU countries with authorised representatives appointed
✅ DoC and technical documentation ready and available with every shipment

5. Take Action Now

PPWR took full effect on 12 August 2026 with no grace period. Packaging without a supporting DoC and technical documentation may be detained at customs. Compliance is not an option – it is a matter of survival for your EU business.

Contact us today to obtain your exclusive PPWR compliance package for solar mounting packaging. Let us work together to ensure your products enter the EU market smoothly.

If you have any questions regarding PPWR packaging compliance, please feel free to reach out to our compliance team at any time.

FarSun – Your PPWR‑Compliant Partner for Solar Mounting Solutions