Reports > Infrastructure

Supply Chain Paradigm Shift and Strategic Responses to the Enforcement of EU PPWR

2026.06.10 Jae-ho Jung

Jae-ho Jung

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#logistics #PPWR #trade
In August 2026, the submission of a Declaration of Conformity (DoC) becomes mandatory under the Packaging and Packaging Waste Regulation (PPWR), which applies to all packaging and packaging waste for products introduced into the EU market. This regulation is expected to serve not merely as a waste management rule, but as a new mandatory requirement for accessing the EU market. This report examines the impact of PPWR on domestic industries, summarizes key concerns raised during discussions between the Korean government and industry stakeholders, and presents step-by-step practical action plans for enterprise preparation.
Table of Contents

  • 1. Why Is the PPWR a Supply Chain Rule Rather Than a Mere "Packaging Regulation"?

  • 2. Risk Matrix by Industry

  • 3. Which Suppliers Is the EU Supply Chain Beginning to Select?

  • 4. Realistic Risks Facing Korean Enterprises

  • 5. Five Immediate Action Items for Enterprises

    • [Addendum] Key Q&A from the Joint Government Briefing

Executive Summary

  • ○ The EU's PPWR is not a simple set of environmental standards for packaging, but a new prerequisite for EU market access. Inadequate documentation can lead to buyers withholding order approvals, border customs blocks, and product recalls—shifting the issue from "regulatory compliance" to "qualification to do business."

    • Starting August 12, 2026, requirements for the Declaration of Conformity (DoC), Technical Documentation (TD), and hazardous substance limits (four heavy metals and PFAS) will take effect simultaneously. With no transition period, immediate action by Korean companies is imperative.

  • ○ Industries most heavily impacted rank in the order of Cosmetics (K-Beauty), Food & Beverages, E-Commerce, Industrial Goods & Steel, Packaging Suppliers, and Chemical Material Companies, with the nature and timing of risks varying by sector.

    • For cosmetics and food, the PFAS standard taking effect in August 2026 is the most urgent issue, whereas transport packaging reuse (2030) for industrial goods and the empty space ratio limit under 50% (2030) for e-commerce represent the main long-term hurdles.

  • ○ The EU supply chain is already restructuring to prioritize suppliers capable of offering PFAS-free materials, Class A/B recyclable packaging, EU-certified PCR raw materials, and comprehensive Technical Documentation. Companies failing to meet these criteria face a high likelihood of supply chain exclusion.

    • EU buyers are actively inserting mandatory submission of PPWR compliance documentation into purchasing terms, leaving non-compliant suppliers at risk of losing business continuity.

  • ○ The primary vulnerability for Korean enterprises stems not from a lack of regulatory awareness, but from a "deficiency in response infrastructure."

    • Companies are complexly exposed to infrastructure deficits, including non-standardized Bills of Materials (BOM) and supply chain documentation among small- and medium-sized packaging suppliers, difficulties in sourcing EU-compliant PCR materials, and fragmented operations among procurement, packaging, and logistics departments.

  • ○ Five Immediate Action Items for Enterprises:

    • 1. Build a comprehensive packaging materials inventory;

    • 2. Initiate testing for PFAS and heavy metals;

    • 3. Establish a framework for drafting Technical Documentation (TD) and Declarations of Conformity (DoC);

    • 4. Assess supplier capabilities regarding PPWR compliance;

    • 5. Clarify liability boundaries according to export structures (B2B vs. B2C).

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