The short answer: the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied since 12 August 2026, not January 2027. What 2027 brings is enforcement and the Commission's guidance on single-use packaging formats. For buyers, the question is no longer what the law says-it is whether the supplier can show test data. Here is ours.

What has IPACK actually tested?

Four reports from SGS and CTI, covering our production:

Report	Product	Scope	Result
SHAHL26028396401 (SGS), 8 Sep 2026	Colourful paper cup	PPWR Art. 5(5)(c): total fluorine	Not detected (<20 mg/kg) against a 50 mg/kg limit; PASS
A2260639716101 (CTI), 31 Jul 2026	Printed paper cups and paper lid	PPWR Art. 5(4) heavy metals; Art. 5(5) targeted PFAS	Pb, Cd, Hg and Cr(VI) not detected; targeted PFAS not detected
A2260905599102001 (CTI), 21 Oct 2026	PET cup and PP cup, composite sample	PPWR Art. 5(5): total fluorine and targeted PFAS	Fluorine not detected (<10 mg/kg); targeted PFAS not detected; PASS
A226090559910101 (CTI), 28 Oct 2026	PET cup	EU 1935/2004 and French decree 2007-766 food-contact migration	Bisphenols, overall migration, heavy-metal migration and primary aromatic amines not detected; PASS

What do these numbers actually prove?

On total fluorine, the paper cup returned not detected against a method detection limit of 20 mg/kg, using ASTM D7359-23 with combustion ion chromatography. That is the screening value Article 5(5)(c) sets at 50 mg/kg.
On PFAS, the targeted scan follows EN 17681-1:2025 and returns every listed substance below its detection limit. EN 17681-1:2025 is a published European test method for PFAS analysis in textiles and textile products; we use it as a reference method for targeted PFAS screening. That is the evidence Article 5(5)(a) and (b) ask for-25 ppb for any single PFAS, 250 ppb for the sum, and total fluorine below 50 mg/kg including polymeric PFAS. The report includes a caveat worth repeating: there is no single official PFAS list, so the method and the detection limits are what make the result meaningful.
On heavy metals, Article 5(4) caps lead, cadmium, mercury and hexavalent chromium at 100 mg/kg combined. All four were below detection in the printed paper cup, ink included.

The migration report sits under a different regime-food-contact safety rather than packaging composition-but importers now ask for both in one folder, so we file them together.

Why does the 50 mg/kg total-fluorine figure confuse buyers?

Because total fluorine counts every fluorine atom in the sample, not only PFAS. Article 5(5)(c) sets 50 mg/kg, then does something unusual: where a reading exceeds it, the manufacturer must document how much of that fluorine is PFAS and how much is not. A targeted PFAS scan is how that split is proven.

Two details decide whether a total-fluorine result means anything: the method, and the detection limit. A report reading "not detected" against a 20 mg/kg limit is a different statement from one reading "not detected" against 2 mg/kg.

A supplier who sends only a "PFAS-free" certificate-no method, no detection limit, no report number-has not answered the question. Ask for the report.

What should a buyer check before accepting a PPWR file?

Report number, laboratory and test date, and whether the sample was a single SKU or a composite.
The Article cited for each test, not just "PPWR compliant".
Detection limits, so that "not detected" means something.
Whether the product tested is the product you are buying, in the same material and print.

IPACK answers those four points for paper cups, PET cups and PP cups. Buyers who need the file before a tender can request it with the sample set

FAQ

Q: Is "PFAS-free" the same as passing PPWR?

A: No. Article 5(5) sets three numeric limits. A report with a stated method and detection limits is the evidence; the phrase alone is not.

Q: Does the paper cup test cover the print?

A: Yes. The SGS sample was a colourful printed cup, and the CTI heavy-metal and PFAS tests covered the printed cup and paper lid as submitted, ink included.

Q: When does the rest of PPWR bite?

A: Design-for-recycling criteria are due by 1 January 2028, the harmonised label from 12 August 2028 (or 24 months after the relevant implementing acts enter into force, whichever is later), and recyclability grades plus Annex V restrictions from 1 January 2030. PFAS, heavy metals and total fluorine are already enforceable.

About IPACK

IPACK is a brand of Wuhan Xinyongan Industry and Trade Co., Ltd., manufacturing paper cups, paper bowls, PET and PP cups, beverage packaging, cup holders, straws and bags in Wuhan, China. We serve distributors, coffee chains and foodservice brands across the Middle East, Europe and North America. The company exhibits at Gulf Print & Pack 2027, 12–14 January, Dubai World Trade Centre. Contact our team for test reports, certificates and samples

18oz Plastic Cups with Lids

Integrated cup and lid set, easy to assemble and use.
Lightweight design, convenient to carry around for outdoor activities.
Uniform wall thickness, not easy to bend under normal pressure.
No harmful additives, keeps original taste of beverages.
Classic transparent look, suitable for various beverage stores and chain shops.

News

EU PPWR Compliance: SGS and CTI Test Results for Paper Cups, PET Cups and PP Cups