PPWR: Cardboard Packaging Must Prove Compliance

Since August 12, 2026, EU packaging law requires manufacturers to meet requirements concerning certain substances in packaging, including heavy metals and, in specific applications, PFAS. Under the new Packaging and Packaging Waste Regulation (PPWR), manufacturers must be able to demonstrate that their packaging meets the applicable requirements and maintain the necessary supporting documentation.

At Climate King, we follow every regulation that applies to our products, and packaging is no exception. We wrote earlier about the new CO2 tax on F gases, and this time the topic is packaging itself. Every unit we ship, including our AirDeck Pro, leaves our warehouse in cardboard packaging, and we already meet the requirements set out below.

What the PPWR restricts in cardboard packaging

Article 5 of the PPWR, formally Regulation (EU) 2025/40, sets limits on substances of concern in packaging. Two things matter here, and they are not the same.

The first is a heavy metals limit that applies to all packaging, regardless of material. The combined concentration of lead, cadmium, mercury and hexavalent chromium in a packaging unit must not exceed 100 mg per kg. This carries over from the previous Packaging Directive, and it is a limit our packaging has always met.

The second is a set of specific PFAS limits, which apply only to food contact packaging and therefore do not apply to our general cardboard shipping packaging. We do not test our packaging specifically for PFAS, but there is no reason to believe that PFAS is present in our cartons. We maintain high standards for all of our products, and these standards also apply to our packaging.

What our packaging test report actually shows

To verify the materials used in our packaging, Climate King had its packaging materials tested by an independent laboratory The laboratory tested the submitted materials for lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr6+) against the relevant PPWR requirement. All tested materials received a PASS result.

At Climate King, we keep the relevant packaging information and laboratory test results on file. The test report covers the packaging materials submitted for testing, including cardboard, EPS/EPE foam, plastic bags, labels, packing tape and honeycomb cardboard.

Climate King is the manufacturer, and we take that responsibility ourselves

Under the PPWR, the manufacturer is the company that has packaging designed or manufactured and markets it under its own name or trademark. Since our packaging carries the Climate King brand, we are the manufacturer under this regulation, not our packaging suppliers.

We do not pass this obligation on to anyone else. We collect the material composition data we need directly from our packaging suppliers, and we use that data to build our own technical documentation and sign our own declaration of conformity. This is our responsibility, and we have already built it into how we work.

This is already in effect

These requirements are not something coming later. August 12, 2026 has already passed, and our packaging has met these requirements since that date. This is already how we operate, not a future plan.

Our approach

We have our packaging materials tested by an independent laboratory against relevant PPWR requirements.
The laboratory test covers lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr6+).
The tested materials include cardboard, EPS/EPE foam, plastic bags, labels, packing tape and honeycomb cardboard.
All tested materials received a PASS result.
We retain the laboratory test report and relevant packaging documentation for our records
We continue to review our packaging documentation as EU guidance develops

Looking for air conditioning units you can trust, built and packaged to meet every EU requirement? Explore the AirDeck Pro or register as a Climate King partner to get access to our full product line.

Laboratory test results

Our packaging materials were examined in September 2026 by an independent laboratory for the heavy metals restricted by the PPWR. The result is clear: all tested materials meet the requirements.

✓

Test result: PASS
All tested packaging materials stay below the PPWR limit of 100 mg/kg.

Substance tested	PPWR requirement	Result
Lead (Pb)	Combined max. 100 mg/kg	✓ PASS
Cadmium (Cd)		✓ PASS
Mercury (Hg)		✓ PASS
Hexavalent chromium (Cr6+)		✓ PASS

Materials tested

CardboardEPS/EPE foamPlastic bagsLabelsPackaging tapeHoneycomb cardboard

We keep the full laboratory report in our technical file. It is available on request for regulators and business partners.

Frequently asked questions about the PPWR and Climate King packaging

Has Climate King's packaging been tested against PPWR requirements?

Yes. The packaging materials submitted by Climate King were tested by an independent laboratory for lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr6+) against the relevant PPWR requirement. All tested materials received a PASS result.

Does PFAS apply to Climate King's packaging?

The specific PFAS limits in the PPWR apply only to food contact packaging and therefore do not apply to our cardboard shipping packaging. We do not specifically test our packaging for PFAS, but there is no reason to believe that PFAS is present in our cartons. We maintain high standards for our products and packaging.

Is Climate King responsible for its packaging, or its suppliers?

Climate King takes responsibility for the packaging it places on the market under its own brand. We work directly with our packaging suppliers to collect the material information needed to support our packaging documentation and testing.

Is the PPWR already mandatory?

Yes. The relevant obligations under Article 5 have applied since August 12, 2026, and Climate King has met them since that date.

How can I become a Climate King partner?

Sources: Regulation (EU) 2025/40 on packaging and packaging waste, European Commission guidance and FAQ on the PPWR.

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