PPWR: Cardboard Packaging Must Prove Compliance

Since August 12, 2026, EU packaging law requires manufacturers to demonstrate that packaging, including cardboard boxes, complies with restrictions on certain harmful substances such as PFAS and heavy metals. Under the new Packaging and Packaging Waste Regulation, known as the PPWR, this involves a formal declaration of conformity supported by technical documentation and a conformity assessment before packaging can legally be placed on the EU market.

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, and these apply only to food contact packaging, not to general cardboard or carton packaging such as shipping boxes. Our packaging is not food contact packaging, so these specific PFAS thresholds do not apply to it, contrary to what some general summaries of the PPWR suggest. The heavy metals limit above still applies regardless of what the packaging is used for, and we meet it in full.

What a declaration of conformity actually means

A declaration of conformity is a formal, written declaration made by the manufacturer, based on the manufacturer’s own technical documentation and conformity assessment. It is not a certificate. It is not issued by a third party, and there is no notified body involved in the standard process.

At Climate King, this means we assess our own packaging internally, maintain a technical file with supporting evidence such as material composition data, and sign a declaration confirming our packaging meets the requirements. We keep that declaration and its underlying documentation on file, ready for inspection at any time.

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 hold a declaration of conformity for our cardboard packaging
We maintain full technical documentation on the materials we use
We work directly with our packaging suppliers to confirm their composition data
Some of our packaging is also sent to an external lab for testing on hazardous substances, giving us an extra layer of verification alongside our own technical documentation.
We review our documentation as EU guidance continues to develop

The European Commission has already published guidance and an FAQ document on the PPWR, and we monitor these closely. We will update this article if anything materially changes.

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

Frequently asked questions about the PPWR and Climate King packaging

Is Climate King's packaging PPWR compliant?

Yes. Our cardboard packaging meets the heavy metals limit set out in Article 5 of the PPWR, and we hold a declaration of conformity backed by our own technical documentation.

Does PFAS apply to Climate King's packaging?

No. The specific PFAS limits in the PPWR apply only to food contact packaging. Our packaging is not food contact material, so those thresholds do not apply to it.

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

Climate King is the manufacturer under the PPWR, since our packaging carries our own brand. We hold the legal responsibility for the declaration of conformity ourselves, and we work with our suppliers to gather the data we need to support it.

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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