K-food export packaging teams are now looking at two rules at once in Q2 2026. One is the EU PPWR (Packaging and Packaging Waste Regulation) at D-70 from its 2026-08-12 application date. The other is California’s SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act), which just passed its first reporting deadline on 2026-05-31. With the timing concentrated in a single quarter, bundling the two reviews into one checklist is now cheaper than reviewing each rule separately at the SKU level.

This post does not repeat the general explanation of PPWR and SB 54. For the general PPWR explainer, see ‘EU PPWR August 2026 Countdown’; for SB 54, see ‘Looking Back at the US Packaging EPR First Reporting Deadline (2026-05-31)’. This post focuses on how K-food export packaging teams can review both rules using a single checklist.

Why a Single Checklist Now

The two rules start from different premises. PPWR is a product and packaging rule that gates EU market entry, while SB 54 is an EPR (extended producer responsibility) rule that puts costs on producers selling into California. Yet at the level of a single K-food export packaging SKU, the items that need checking overlap.

  • Packaging material and structure — PPWR: recyclability, reusability, design for recycling / SB 54: covered material category and recyclability assessment
  • Labeling — PPWR: separate collection and material codes / SB 54: responsible end market standard
  • Data and documentation — PPWR: technical file and DoC / SB 54: producer reporting data, baseline year data
  • Supply-chain evidence — PPWR: supplier documentation (see ‘EU PPWR Supplier Document Request Package’) / SB 54: SKU-to-category mapping

These four overlapping areas mean that if a K-food export division cleans up its data once for a given SKU, it can use the same dataset on both sides.

Single Checklist for K-Food Export Packaging (Six Areas)

Diagram bundling PPWR and SB 54 review items into a single SKU-level checklist for K-food

The following six areas are the minimum unit for reviewing PPWR and SB 54 together.

Area 1: SKU Mapping Sheet (Common)

  • Internal SKU code / product name / shipping country
  • Packaging structure: primary, secondary, tertiary, separated
  • Material per layer: paper, plastic, composite, coating, adhesive, liner
  • Unit weight (g): including labels and tape
  • PPWR mapping: PPWR annex classification, plus candidate recyclability grade A/B/C/D opinion
  • SB 54 mapping: covered material category (box, tray, wrap, label, etc.), plus candidate recyclable status

This one sheet is the starting point for both rules.

Area 2: Recyclability Evidence (Common)

  • Test reports: recycling-line test results (4evergreen, CEPI standards)
  • Coating and adhesive data: PE, PLA, PVdC, adhesives, printing inks
  • Separability: documentation that multilayer structures can be separated
  • Supplier data: documents from paper, film, and adhesive suppliers (see ‘Supplier Document Request Package’)

Both PPWR and SB 54 are moving toward requiring an “evidence pack” rather than just a “recyclable” label. This is the largest overlap between the two regimes.

Area 3: Label and On-Pack Text

  • PPWR: separate-collection pictogram and material code marks
  • SB 54: responsible labeling for environmental claims (see ‘FTC Green Guides’)
  • Korea: separate-collection labels (see ’environmental claims overview’)
  • Decide at the design stage how multi-market labels will be laid out on the pack itself

Area 4: EPR Registration and Reporting Line

  • By EU member state: an SKU-level table showing where each EPR registration sits
  • California SB 54: producer registration (CAA or independent), registration number, whether the first report (2026-05-31) was filed, and the next deadlines (7/1 source-reduction baseline, 8/1 plan)
  • Internal response script: a ready answer for buyer requests like “share your EPR registration number”

Area 5: Baseline / Reporting Data

  • PPWR: recycled-content baseline and reuse baseline (depending on the PPWR application phase)
  • SB 54: 2023 baseline year shipment data (packaging SKU, weight, category)
  • Common: confirm which standard report in the Korean parent ERP or shipping system produces this data
  • English response sheet for US buyers (SB 54 registration, CAA, responsible end market)
  • English response sheet for EU buyers (PPWR application, DoC, EPR member state)
  • Reference set for Korean parent legal review (EUR-Lex, CalRecycle official guidance)

Three Things That Often Slip Through Dual Review

Items K-food export packaging teams often miss when running PPWR and SB 54 reviews in parallel

1. Reviewing One Rule at a Time, Creating Duplicate Work

When the PPWR owner and the SB 54 owner sit in different departments at headquarters, the same SKU often gets its data cleaned up twice. Sharing a single SKU mapping sheet across both teams cuts the data entry to one pass.

2. Putting Only PPWR Pictograms on Labels, Treating KR and US Labels Separately

If labels get refreshed EU-first because PPWR is imminent, US and Korean label markings tend to drift on their own track. Reviewing EU, US, and KR markings on a single sheet at the label-design stage is the cheaper route.

3. Failing to Define a Single Source for Baseline Data

PPWR (recycled-content baseline) and SB 54 (2023 shipment baseline) use different baseline years and different units, but the underlying internal system is the same. Deciding in advance which standard report the data is pulled from in the ERP or shipping system speeds up reporting on both sides.

What to Actually Do in June through September

A reasonable sequence for a K-food export division between June and September:

  1. June: First pass of the single SKU mapping sheet, starting with the top 20 EU plus US shipping SKUs.
  2. Early July: Prepare data for the next SB 54 deadline (7/1 source-reduction baseline) and review the PPWR DoC draft.
  3. Mid-July: Run an integrated EU/US/KR review of label and on-pack text. Make the call in one meeting with the packaging design team.
  4. Early August: Final check ahead of the SB 54 source-reduction plan filing (8/1) and the PPWR application start (8/12).
  5. September: Post-mortem on operating both regimes. Update internal response scripts and standard sheets.

This schedule assumes a K-food exporter with sizable EU and US share. If the share differs, only the weighting changes.

Conclusion

The combination of EU PPWR’s imminent application date and California SB 54 having just cleared its first deadline is a load on K-food export packaging teams, but it is also a good moment to review both rules together. Wrapping SKU mapping, recyclability evidence, labels, EPR registration, baseline data, and response standards into one six-area checklist cuts the internal cost of dealing with both regimes quickly.

Read this alongside the area-by-area explanations in ‘EU PPWR August 2026 Countdown’ for PPWR and ‘Looking Back at the US Packaging EPR First Reporting Deadline’ for SB 54.

About the Author

PackingMaster: Editor of PaperPackLog. Curates and organizes market trends, product information, and technical insights for the paper-packaging industry.

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