EU PPWR Compliance Reporting for Hang Tags and Bags
Date：2026-11-11 09:23:37 Classification
：【question】 Visits：
EU PPWR Compliance Testing for Hang Tag Bags
Testing Overview
Hang tag bags—commonly used as accessories for apparel, luggage, and footwear—are typically made of PE or OPP. As packaging components, they fall under the scope of the EU Packaging and Packaging Waste Regulation (PPWR, EU 2025/40). The regulation mandates that each homogeneous material within a piece of packaging must be evaluated individually; testing the item as a whole is not sufficient.
Mandatory testing includes four heavy metals: lead, cadmium, mercury, and hexavalent chromium. The combined total concentration of these four substances must not exceed 100 mg/kg—a compulsory requirement for all types of packaging. If the hang tag bags are used for food-related products or come into direct contact with food, additional testing for PFAS (per- and polyfluoroalkyl substances) is required. For standard apparel hang tag bags, PFAS testing is generally not mandatory but can be performed upon client request.
Important Distinction: A PPWR substance test report is not the same as EPR (Extended Producer Responsibility) packaging registration. Both forms of compliance are required. Test reports are typically used for Amazon compliance audits, client factory inspections, and regulatory checks by customs or market surveillance authorities. Required Documentation
1. Testing Application Form: Specify the material and intended use of the hang-tag bag, whether it comes into contact with food, and whether it features printing, lamination, or adhesive dots.
2. Bill of Materials (BOM): List the base material of the bag, printing inks, sealing adhesives, and the material of any hanging cords or strings.
3. Samples: Provide at least 3 samples for each version (based on material and print design). Different colors or ink versions must be submitted as separate samples.
4. Product Photographs: Include images of the front, back, sealing area, and printed sections.
Process
1. Submit documentation; an engineer will evaluate the material structure, determine the required tests, and provide a quotation.
2. Confirm the engagement, sign an agreement, arrange payment, and send samples to the laboratory.
3. The laboratory registers the samples, breaks them down into homogeneous materials, conducts heavy metal testing, and performs PFAS testing if required.
4. Upon successful testing, a CNAS-accredited PPWR test report (in English) will be issued, accompanied by a Declaration of Conformity (DoC) for the PPWR.
5. Any changes to the base material, inks, adhesives, or printing process of the hang-tag bags will necessitate the submission of new samples for re-testing.
6. The test report applies only to the specific samples submitted; companies must retain a complete set of technical documentation in the event of regulatory audits.
Timeline and Notes
The standard turnaround time is 5–7 business days; expedited service (2–3 business days) is available. As small packaging accessories, hang-tag bags are frequently subject to regulatory spot checks in the EU market. For exports to the EU, in addition to the test report, companies must complete Extended Producer Responsibility (EPR) registration for packaging in the target sales country. EPR registration—which concerns waste recovery reporting—is separate from PPWR substance testing and cannot be substituted for it.
Shen Gongwang Security: 44030602006947