SWTC SWC · Italy

PPWR Early Diagnosis: One Foam Liner Puts an Entire Shipment at Risk of Non-Compliance

Published in English.

The customer conducts a compliance pre-diagnosis before the 2026 applicable date.

EPS liners are non-recyclable foam material, and the empty space rate of the outer box exceeds the draft requirement; the combination of these two will directly trigger non-compliance.

Inventory all packaging levels: outer box, EPS liner, stretch film, sealing tape, manual bag. Replace EPS with honeycomb paper liner and verify equivalent cushioning performance. Redesign the box type to reduce the empty space rate to within the limit. Complete heavy metal testing and recyclability assessment, and prepare a packaging compliance declaration.

Complete the switch 8 months before the applicable date; packaging costs rise by 6%, avoiding the risk of the entire shipment being rejected.

Packaging compliance must be inventoried by "level"; tape and labels all count as packaging components. Whether composite materials can be separated directly determines the recyclability judgment. Starting 6–12 months in advance is necessary to have time for supplier switching and verification.

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