Two big shifts have landed since our late-April D-100 report. On March 30, the European Commission released its formal PPWR guidance document and FAQ, locking in the rule that compliance is simultaneous at the start date rather than phased in casual stages. On April 22, Hansol Paper hosted 60-plus customer executives at a technical seminar where the gap between EU and Korean industry response timelines was on full display in one room. The 102 days remaining are not a long runway by industry standards.
EC Guidance + FAQ Release: The ‘Simultaneous Compliance’ Rule, Codified
On March 30, 2026, the European Commission released its guidance document and a separate FAQ document on PPWR (Regulation (EU) 2025/40). The two documents together aim to drive uniform interpretation and consistent enforcement across member states.
The core message of the guidance is simple. PPWR allows only those packages on the EU market that satisfy every requirement of Articles 5 through 12 simultaneously, beginning August 12. This is not a casual phased framework where some clauses can wait. From day one, five axes operate in parallel.
| Axis | August 12 application |
|---|---|
| Substances of concern (SoC) | Intentional PFAS addition prohibited; food-contact residue limits applied |
| Compliance evidence | Declaration of Conformity (DoC) issued; technical documentation (TD) maintained |
| Packaging minimization | 40% maximum empty space in grouped, transport, and e-commerce packaging |
| Labeling | Standardized material and recyclability labels (subject to implementing acts) |
| Recyclability | 2030 design-grade obligation prepared at the design stage now |
The FAQ addresses the most-asked operational questions: recyclability, recycled content in plastic packaging, packaging minimization, labeling. The Commission notes the document is not legally binding, but it functions as a de facto operational baseline that EU member-state market surveillance authorities will reference for consistent compliance assessment.
EU Industry Clock: ‘Start Date = Market Access Threshold’ Already Locked In
For EU companies, the guidance release was less new information than confirmation of a process already underway. The EU industry treats August 12 not as a legal start date but as the market access threshold: the moment at which packaging must be ready, not at which preparation begins.
The Beyond Meat packaging redesign is a representative case. Beyond Meat is applying recycled plastic, reducing packaging material volume, and shifting to recyclable structures: not as ESG branding but as market access compliance. The work is being treated as pre-launch design change so that product flow into the EU market does not break at the start date.
The shift is enabled by the guidance’s clearer definitions. Recyclable packaging under PPWR is not a marketing claim but a status that must be objectively verified through technical data. After August 12, the market will accept companies that prove sustainability, not those that merely claim it. The verification rests on three tools.
- Declaration of Conformity (DoC): A formal declaration by the packaging manufacturer that all requirements are met
- Technical Documentation (TD): Test data, design drawings, recyclability assessment results that support the DoC
- Conformity assessment: Internal or external assessment performed by category-specific procedures
DoC issuance is required for every packaging category placed on the EU market. Importers and distributors may only place packaging on the market when the DoC and TD are in place. For Korean exporters, missing or insufficient DoCs become a transaction-rejection trigger from EU import partners.
Korean Industry Clock: Hansol Paper’s April Seminar Exposed the Gap
On April 22, Hansol Paper hosted its 2026 Customer Technical Seminar at the Daejeon plant for food, logistics, and packaging customers. CJ Logistics, Lotte Wellfood, GS Retail, Ottogi and 60-plus customer executives attended. Hansol unveiled a packaged set of PPWR-aligned solutions.
Hansol Paper’s PPWR Lineup
- Protego HS (Heat Sealable): Secondary packaging used for chocolate, candy, seaweed, coffee. Five product lines aligned to customer printing methods and physical requirements. Designed to meet the A grade, the highest recyclability rating under PPWR.
- Protego: Barrier flexible packaging.
- Terabath: Water-resistant material for food packaging boxes.
- Eco-friendly paper insulated box: Replacement for expanded polystyrene delivery boxes.
The significance of the seminar lay less in the catalog than in what it implied: demand-side companies were still searching for PPWR-aligned materials at the end of April. Food and packaging companies’ difficulty in sourcing compliant materials was visible in the room. This reflects a perception gap that treats PPWR as a component swap immediately before the deadline rather than as enterprise-level design change.
Two Persistent Misreadings
Two flawed interpretations still circulate in Korean industry conversations.
- “For now, only Article 5 substances of concern need to be addressed.”
- “Recyclability and packaging minimization can wait until 2030.”
The EC guidance dismisses both. PPWR requires simultaneous compliance with Articles 5 through 12. Packaging that fails verification on or after August 12 will be excluded from the EU market. The 2030 clauses represent additional strengthening, not a delay of core compliance.
May to August 12: A 102-Day Practical Checklist
The remaining 102 days are not enough to complete new material development, testing, and certification from scratch. But none of the following can be deferred for time reasons.
| Window | Priority | Action |
|---|---|---|
| May (target D-90) | Immediate | Inventory packaging specifications by EU export SKU; first-pass PFAS screening |
| June (D-60) | High | Standardize internal DoC template; gap analysis on TD components (test reports, design drawings, recyclability assessments) |
| July (D-30) | Required | Decide on phase-out or material substitution for non-conforming SKUs; coordinate DoC handover with EU importers |
| August (D-0) | Deadline | Activate DoC issuance + TD retention; prepare market surveillance authority response playbook |
Small and medium-sized exporters, with limited bargaining power on alternative materials, should confirm by May the PPWR-aligned product lineup and certification documentation of their existing paper and packaging suppliers. Beyond Hansol Paper, Moorim Paper, and Kkeullighan Nara, the certification testing labs designated by EU importers should also be on the verification list.
Frequently Asked Questions
Q: Will all EU exports be blocked after August 12?
Only non-compliant packaging is barred from the market. SKUs with completed DoC issuance and TD retention will continue to flow normally. That said, missing or insufficient DoCs translate directly into transaction rejection, so unprepared SKUs effectively lose EU market access.
Q: Who issues the Declaration of Conformity (DoC)?
The packaging manufacturer (including converters producing private-label packaging) is legally responsible for performing the conformity assessment and issuing the DoC. Importers and distributors are obligated to verify that DoC and TD are in place. For Korean exporters, EU importers will typically request copies of the DoC and TD.
Q: With the 2030 recyclability obligations still ahead, do we really need to act now?
The guidance makes clear that all core requirements apply simultaneously from August 12. The 2030 stage represents additional strengthening such as design-grade obligations: recyclability itself is verifiable starting in August. Without design-stage integration now, market entry in August itself becomes difficult.
About the Author
PackingMaster: Editor at PaperPackLog. Curates market trends, product information, and technical insights for the paper packaging industry.
References
- European Commission, “Commission publishes guidance to support implementation of new packaging rules” (2026.03.30)
- Latham & Watkins, “European Packaging and Packaging Waste Regulation: Summary of Provisions and New Guidance” (2026.04)
- Global Environment, Land & Resources Blog, “European Packaging and Packaging Waste Regulation: Summary of Provisions and New Guidance” (2026.04)
- HeraldK, “Hansol Paper presents response strategy for August EU packaging regulation” (2026.04.22)
- Allpackaging, “Two perspectives on August 12, 2026: PPWR response reality through the Beyond Meat case” (2026.04)
- CIRS Group, “EU Packaging Regulation (PPWR) Countdown: PFAS Restrictions Take Effect in August” (2026.04)