Four Things Every EU-Bound Shipment Needs From 12 August 2026

Four Things Every EU-Bound Shipment Needs From 12 August 2026

Substance limits, self-assessment, technical documentation and a signed DoC - the four boxes to tick before the next container leaves.

Four boxes to tick before the next container

From 12 August 2026, packaging placed on the EU market must clear four gates at once: substance limits, a conformity assessment under Module A, a technical documentation file, and a signed Declaration of Conformity with identification marking. Miss any one and the packaging is, in legal terms, not placed on the market at all - even if it is physically there. We have been building this file set for our own shipments, and the honest summary is that it is documentation work, not rocket science, and it is only painful when done late.

Gate 1: Substance limits

The combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg. This limit carried over from the 1994 directive and PPWR keeps it. Separately, from 12 August 2026, food-contact packaging is restricted on PFAS: no more than 25 ppb for any individual PFAS measured by targeted analysis (excluding polymeric PFAS), no more than 250 ppb for the sum of targeted PFAS, and no more than 50 ppm for all PFAS including polymers.

For luggage packaging the practical effect is mild - cardboard and PE film are normally far below the metal limit - but the requirement is proof, not assumption. You need a test report or a supplier declaration that actually names the material. And the food-contact PFAS clause is largely "not applicable" for luggage, but the supplier declaration should say so in writing.

Gate 2: Conformity assessment (Module A)

PPWR's default conformity route is Module A - internal production control under Article 38. The producer assesses conformity itself and keeps the evidence. No notified body, no paid certification, no lab visit required for the assessment itself. That is the good news: for most packaging, the compliance cost is documentation time, not testing fees. The catch is the word "internal": the assessment is only as real as the evidence behind it.

Gate 3: Technical documentation (Annex VII)

Each packaging type needs a technical documentation file covering at least: a general description and intended use, design drawings, material composition, the standards or technical specifications applied, a qualitative recyclability/minimisation/reusability assessment, recycled-content calculations where relevant, and the substance-limit evidence. It must be producible within 10 days of a market surveillance request and kept for five years (single-use) or ten years (reusable). The full contents are unpacked in Article P4.

Gate 4: Declaration of Conformity and marking

The DoC is the signed statement by the producer that the packaging meets the applicable PPWR requirements, per Annex VIII - ten mandatory elements, explained field by field in Article P3. Alongside it, from 12 August 2026 packaging must carry identification information: the producer's or importer's name, trademark and contact details, plus the packaging type, batch or serial number. In practice: add your company name, address and a batch code to the carton print.

What each component needs, and who provides it

About this series

Written by the team behind a luggage factory in Jiangxi, China, for importers, factories and component suppliers who want the same working knowledge. No promotion, just what we'd tell a friend who asked. Author: CLK Luggage Academy —

Packaging component	Evidence needed	Provider
Export/retail carton	Heavy-metal test report, material declaration, weight	Carton factory
Polybag / bubble wrap / foam	Material declaration, heavy-metal test report	Packaging materials supplier
Sealing tape	Material declaration incl. adhesive	Tape maker
Desiccant	Material declaration	Desiccant supplier
Hang tags / labels / manuals	Material declaration incl. inks	Print shop
Wood pallet	ISPM15/IPPC marking, material declaration	Pallet supplier / forwarder

FAQ

Is the 100 mg/kg limit per metal or combined?

Combined. Lead, cadmium, mercury and hexavalent chromium added together must stay at or below 100 mg/kg. A report showing only one metal does not demonstrate the limit.

Can my RoHS report double as packaging evidence?

No. RoHS covers restricted substances in electrical and electronic products; PPWR packaging limits are a different scope with a different calculation. A RoHS report is a useful reference, not a substitute.

Do I really need no third party for Module A?

Correct - Module A is internal production control. But the evidence inside the file (test reports, declarations) should come from accredited sources where risk warrants it. Self-assessment is not the same as self-made evidence.

What exactly goes on the carton print?

Producer or importer name, trademark and contact details, plus the packaging type and a batch or serial number. The harmonised sorting label arrives in 2028; the identification marking is due now.

What if one component is missing evidence?

The technical documentation is incomplete, which makes the DoC invalid for that packaging type. Market surveillance or a diligent importer will find the gap. Collecting the whole table takes weeks, not months - do it once, reuse it for every market.

Who is responsible for assembling all of this?

The factory collects evidence from suppliers and files it; the producer signs the DoC; the EU importer verifies before placing on the market. Three roles, one chain, and the chain starts with the suppliers' documents.