TEYING BUYER GUIDE · UPDATED OCTOBER 1, 2026

PPWR 2026: How to Package Jewellery Without Breaking EU Rules

Regulation (EU) 2025/40 applies from 12 August 2026 and changes what a jewellery box, card and pouch have to be. This covers the 100 mg/kg heavy metals limit, extended producer responsibility in each member state including the German LUCID rule, packaging minimisation, and the material detail to put in a packaging brief.

By Qiu Qiu, Founder and Design Lead at TEYING · October 1, 2026

The short answer: packaging is now regulated like a product

PPWR (EU) 2025/40 replaces the packaging directive and applies from 12 August 2026 across all 27 member states. The combined lead, cadmium, mercury and hexavalent chromium content of a jewellery box, card, pouch or insert must stay at or below 100 mg/kg. Producers register under extended producer responsibility in each country they sell into, and in Germany a foreign seller must appoint an authorised representative.

The lines below are general guidance, not legal advice. Packaging requirements also interact with national registration systems, so confirm your position with a compliance adviser for the countries you actually sell into. The figures reflect the regulation as of October 2026.

The regulation, and why the form of it matters

Regulation (EU) 2025/40 was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025, and applies generally from 12 August 2026. It replaces Directive 94/62/EC.

The change in legal form is the part brands should notice. A directive is transposed country by country with local variation. A regulation applies directly and identically in all 27 member states. You work from one text, and then from a set of national registers that still differ from each other in fees, reporting cycles and portals.

Obligations arrive in stages rather than all at once.

The two that land on a jewellery brand today are the substance limit and the registration duty.

The heavy metals limit is a combined 100 mg/kg

Article 5 sets one combined limit. Lead, cadmium, mercury and hexavalent chromium together must not exceed 100 mg/kg, which is 100 ppm, by weight, in packaging or in any packaging component. It is a sum, not an allowance per metal.

Component is where brands get caught. The limit covers inks, coatings, adhesives, closures and ribbon, not only the board. A laser-printed kraft box with a coated foil logo and a glued fabric insert is four components before you count the box.

In a typical jewellery pack the limit touches:

• the gift box and lid
• the printed backing card
• the pouch
• the insert
• the adhesive, coating and any laminated layer
• stickers, seals and closures

The limit itself is not new, and it applies to the whole pack rather than to the pieces inside it. What changed is the context around it: the same text now carries the substance-of-concern rules and stronger market surveillance, and the Commission can lower the figure by delegated act.

Practically, the question goes upstream. Board, ink and coating choices sit with the packaging printer, so ask them what values they can support and in what form. Recycled and heavily pigmented materials deserve the closest look, since legacy content can travel with them. Derogations exist for recycled glass and for certain closed-loop plastic crates and pallets, and none of them is a general pass for a jewellery box.

The documentation and the printing on the pack

Two further obligations start on the same date and both need decisions before artwork is finalised.

Conformity documentation. The packaging manufacturer completes a conformity assessment, holds technical documentation, and issues an EU Declaration of Conformity before the packaging is placed on the market. If your factory orders packaging on your behalf, ask who that manufacturer is and who holds the declaration, and get the answer in writing while the design is still open. If the box changes later, the assessment is revisited.

Identification details. Packaging must carry the type, batch or serial reference and the name, registered trade name, postal address and electronic contact of the manufacturer or importer, clearly and legibly. On a 5 cm backing card, that is a layout problem, not a print problem. Solve it at artwork stage rather than at the printer.

EPR: registration happens per country, not once

Under Articles 44 and 45, the producer registers in every member state where it first makes packaging available. Registration is national, so it happens in each country separately: different registers, different fee scales, different reporting. Where a producer is not established in a member state, an authorised representative may be required there.

Who counts as the producer depends on the route to market. A brand selling direct to EU consumers is normally the producer for the packaging it puts on the market. A brand selling wholesale to a retail stockist may sit behind the stockist, depending on the country. That distinction decides whose registration number goes on the file.

Germany is the case to know, because the requirement is explicit and dated. From 12 August 2026, a company established abroad with no German branch that sells packaged goods directly to end users in Germany must appoint an authorised representative, under Article 45(3) PPWR and the German packaging law. The representative takes on the packaging-law duties in its own name, with one exception: registration in the LUCID Packaging Register stays with the seller, because it is treated as a personal obligation. Only one representative may be appointed, and it must be independent of the company.

Three dates sit behind that: 12 November 2026 to add the representative to a LUCID registration made before 12 August 2026, 31 December 2026 for system participation agreements concluded before that date, and 1 January 2027 for the new role split to be fully in place.

Packaging minimisation, before it becomes binding

The binding minimisation rules arrive with the design obligations around 2030. The decisions they constrain are made now, during development, when box size, insert and pack-out are chosen and tooling is paid for.

What a small brand can specify in the brief:

• size the box to the piece plus the insert, not to a generic carton that fits everything
• a paper-based insert instead of foam where the piece does not move
• a kraft or fabric pouch rather than a plastic film sleeve
• one outer carton per order instead of per piece where the retail pack already protects it
• pack-out dimensions and weights stated in the quotation, since they set the freight as well as the volume

Empty space is the easiest waste to see, on a shelf and on an air waybill.

What to put in a packaging brief

The one-line version: ask for the material list, not the adjective. A materials list can be checked against a specification and a test report. An adjective cannot be checked at all, and since 27 September 2026 it also carries consumer law exposure, which is set out in green claims on EU jewellery.

How TEYING states it

The packaging option is described as a materials list rather than a benefit. TEYING can build packaging around reduced-plastic materials: recycled paper boxes and cards, kraft or fabric pouches and paper-based inserts, with material options confirmed per project and destination market, since some regions require specific labelling or materials for retail.

That sentence is the pattern worth copying. It names materials, it does not claim a certification, and it ends by confirming the detail for the destination instead of promising it in advance. The full packaging options sit on the private label jewelry packaging page.

If you are specifying packaging for an EU launch, send the piece dimensions, the target markets and the retail tier through the TEYING quote form. We will quote the options per material and state what documentation can be provided for the order, so your registration and your printer work from the same facts.

FAQ

Is my jewellery box affected by PPWR?

Yes, if it reaches an EU customer as sales packaging. The box, backing card, pouch and insert are all packaging, and the combined lead, cadmium, mercury and hexavalent chromium content must not exceed 100 mg/kg from 12 August 2026. The limit covers components such as inks, coatings and adhesives, not only the main material. The piece itself is not packaging, so its material limits come from chemicals and product law rather than from PPWR.

Do I need to register for EPR in every EU country?

You register where you first make packaging available, which in practice means each member state where you sell. Registers, fees and reporting differ by country. If you are not established in a member state where you sell, an authorised representative may be required there. Which party counts as the producer depends on whether you sell direct or through a stockist.

What is the 100 mg/kg limit, and is it per metal?

It is one combined figure across lead, cadmium, mercury and hexavalent chromium, measured in the packaging and its components. There is no separate allowance for each metal, so a single component with high cadmium content can consume the whole budget. Derogations exist for a few specific material streams, not for jewellery packaging generally. Ask your printer for the value and the test method behind it, in writing, for each component you use.

Who holds the paperwork, my factory or my packaging printer?

The packaging manufacturer completes the conformity assessment and holds the technical documentation and the EU Declaration of Conformity. A factory that sources packaging for you should be able to name that manufacturer and confirm it per project and destination market. Ask before artwork is finalised and keep the answer in the order file.