Packaging Hazardous Chemicals Under the PPWR: Dangerous-Goods Exemptions, CLP Labels and the 2026 Chemicals Deal
Does the PPWR Apply to Packaging for Hazardous Chemicals?
Yes. Regulation (EU) 2025/40 applies to all packaging, regardless of material, under Article 2(1), and packaging for hazardous chemicals is no exception. Three provisions exempt packaging used for the transport of dangerous goods in accordance with Directive 2008/68/EC: the recyclability rules of Article 6, the recycled content targets of Article 7 and the re-use targets of Article 29.
A chemicals customer told us on 1 October 2026 that about one product in five in its range is a hazardous chemical, sold in several packaging formats, part of it repackaged. This article is for manufacturers and distributors of chemicals, detergents, paints and adhesives, and for their label printers. The general rules are in our guides to who the manufacturer is and to bulk containers and big bags.
Key Facts
- Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1).
- Under Article 5(4), the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
- Under Article 6(11)(f), Article 6 does not apply to packaging used for the transport of dangerous goods in accordance with Directive 2008/68/EC.
- Articles 7(4)(f) and 29(4)(a) exclude the same packaging from the recycled content targets and from the re-use targets.
- According to the European Parliament, the provisional CLP agreement of June 2026 sets an x-height of at least 1.2 mm for the label text of a substance placed on the market for the public.
- Our dated PPWR referential (baseline reviewed 3 October 2026) confirms the first two lines; the others are read on the linked texts on 8 October 2026.
Which PPWR Obligations Have a Dangerous-Goods Exemption?
Regulation (EU) 2025/40 names dangerous goods in three exemptions only: Article 6(11)(f) for recyclability, Article 7(4)(f) for recycled content and Article 29(4)(a) for re-use. The substance limits of Article 5, the labelling of Article 12, the conformity assessment and producer registration carry no dangerous-goods wording in the Official Journal text.
| Obligation | Dangerous-goods wording in Regulation (EU) 2025/40 | Position for packaging used for the transport of dangerous goods |
|---|---|---|
| Substances, Article 5 | None | The 100 mg/kg heavy-metal limit of Article 5(4) applies |
| Recyclable packaging, Article 6 | Article 6(11)(f) | Article 6 does not apply; the Commission reviews the exceptions by 1 January 2035, under Article 6(12) |
| Recycled content in plastic packaging, Article 7 | Article 7(4)(f) | The targets of Article 7(1) and 7(2) do not apply |
| Labelling, Article 12 | None | Article 12 applies; its harmonised label excludes transport packaging other than e-commerce packaging |
| Re-use targets, Article 29 | Article 29(4)(a) | Paragraphs 1, 2 and 3 do not apply to transport or sales packaging used for transporting dangerous goods |
| Conformity assessment and declaration, Articles 15, 38 and 39 | None | The manufacturer assesses the requirements that still apply and documents them |
| Producer registration and extended producer responsibility, Articles 44 to 46 | None | No exemption is written there |
Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since 12 August 2026, transport packaging included. The Article 6(11)(f) exemption is therefore the main difference for a drum or a jerrican that carries dangerous goods. Under Article 2(2), where the Regulation conflicts with Directive 2008/68/EC, Directive 2008/68/EC prevails.
What Counts as Packaging Used for the Transport of Dangerous Goods?
Regulation (EU) 2025/40 does not define packaging used for the transport of dangerous goods. The three exemptions attach the words in accordance with Directive 2008/68/EC, which covers the inland transport of dangerous goods. In our reading, the exemption follows the transport use of the packaging, not the hazard classification of its content.
Directive 2008/68/EC establishes a common regime for the inland transport of dangerous goods by road, rail and inland waterway, according to EU-OSHA. A hazardous chemical is a substance or mixture classified as hazardous under Regulation (EC) No 1272/2008. A dangerous good is a product regulated for transport under Directive 2008/68/EC. In our reading, the two classifications are separate legal tests, so a CLP classification alone does not place packaging within the exemptions.
Two cases stay open on the text: a consumer bottle of a hazardous detergent that travels in a dangerous-goods consignment before being sold on a shelf, and sales packaging of a hazardous product that travels outside the dangerous-goods rules. Our referential records no Commission reading of either case.
What Do the Exemptions Change for Drums, Canisters and IBCs?
For drums, canisters and intermediate bulk containers used to transport dangerous goods, Regulation (EU) 2025/40 removes the recycled content targets of Article 7 and the re-use targets of Article 29. The same containers used for non-dangerous products of the same range stay within both sets of targets.
Under Article 7(1)(d), plastic packaging other than contact-sensitive packaging and single-use plastic beverage bottles contains at least 35 % post-consumer recycled content by 1 January 2030 or 3 years from the entry into force of the implementing act under Article 7(8), whichever is the latest.
Under Article 29(1), from 1 January 2030, economic operators that use transport packaging in the form of pallets, intermediate bulk containers, pails, drums and canisters within the territory of the Union shall ensure that at least 40 % of such packaging in total is reusable packaging within a re-use system.
In our reading, the exemptions apply packaging by packaging, not to the whole company: the same canister can be exempt when it carries a dangerous good and counted when it carries a non-hazardous cleaner. The importer side of pallets and drums is covered in our article on transport packaging for importers, and the targets in our recycled content guide.
How Does the PPWR Label Sit Next to the CLP Label and Transport Marks?
The PPWR label, the CLP label and transport marks answer three different questions. Under Article 12(1) of Regulation (EU) 2025/40, the harmonised label informs consumer sorting on material composition. A CLP label communicates the hazards of a substance or mixture. Transport marks follow Directive 2008/68/EC.
| Label | Legal basis | What it carries | Where it is required |
|---|---|---|---|
| Harmonised PPWR label | Article 12(1) of Regulation (EU) 2025/40 | Material composition, based on pictograms, to facilitate consumer sorting | Packaging placed on the market, except transport packaging other than e-commerce packaging and packaging in a deposit and return system |
| CLP hazard label | Regulation (EC) No 1272/2008 | Supplier details, nominal quantity for the general public, product identifiers and, where applicable, pictograms, signal words, hazard and precautionary statements, according to ECHA | Hazardous substances and mixtures supplied on the market |
| Transport marks and labels | Directive 2008/68/EC | Not read for this article | Inland transport of dangerous goods |
Under Article 12(1), the harmonised label applies from 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to Article 12(6) or (7), whichever is the latest. The CLP Regulation is cited in recital 24 of Regulation (EU) 2025/40, and in none of its Articles.
Article 12(8) prohibits labels likely to mislead or confuse end users about the sustainability requirements for packaging, without prejudice to requirements concerning other harmonised EU labels. Article 12(5) provides that, where Union law requires information on the packaged product through a data carrier, a single data carrier carries the product and packaging information, both easily distinguishable.
What Did the June 2026 Chemicals Deal Change for CLP Labels?
On 16 June 2026, the European Parliament and the Council reached a provisional agreement on the chemicals simplification package, according to the European Commission. The agreement keeps minimum font sizes for products aimed at the general public and sets only general readability criteria for business-to-business labels, according to the Council.
- Font size for the public. Where a substance is placed on the market for the public, the label text uses an x-height of at least 1.2 mm, and of at least 0.9 mm where the package holds 125 ml or less, according to the Parliament.
- Small containers. For containers of 10 ml or less, some label elements may be provided on a digital label, never the hazard pictograms, according to the Parliament.
- Business-to-business. The Commission states that the agreement removes obligatory font sizes for business-to-business chemicals.
The dates differ between the two institutions. The Parliament recalls that most parts of the revised CLP Regulation were postponed to 1 January 2028. Regulation (EU) 2025/2439 of 26 November 2025 amends the dates of application of Regulation (EU) 2024/2865 and sets 1 January 2028 for part of its provisions. The Council states that the provisional agreement extends the date of application of the revised CLP Regulation to 1 January 2030.
The agreement is not yet law. The Parliament states that the informal agreement must be endorsed by both Parliament and Council, and that it enters into force 20 days after publication in the Official Journal. On 8 October 2026, our searches found no publication of the final act. Brands and label printers can keep artwork able to switch between the current CLP layout and the agreed one until the final text is published.
Who Becomes the Manufacturer When a Chemical Is Repackaged?
Under Article 3(1)(13) of Regulation (EU) 2025/40, the manufacturer is any person that manufactures packaging or a packaged product or, where the packaging or packaged product is designed or manufactured under a person's own name or trademark, that person. In our reading, a company that repackages a chemical into new packaging manufactures a packaged product.
Under Article 21, an importer or a distributor that places packaging on the market under its own name or trademark, or modifies packaging already placed on the market in a way that could affect compliance, is considered a manufacturer and is subject to the obligations of Article 15.
| Situation | Who is the manufacturer under Regulation (EU) 2025/40 |
|---|---|
| A brand fills its own product into drums or bottles under its own name | The brand, under Article 3(1)(13)(a) |
| A distributor buys in bulk and repackages into smaller containers under its own name | The distributor, under Article 3(1)(13) and Article 21 |
| A distributor relabels a supplier's container under its own trademark | The distributor, under Article 21 |
| A toll filler packs a product for a brand under the brand's name | The brand, under Article 3(1)(13)(a), subject to the micro-enterprise rule of point (b) |
Under Article 15(3), the manufacturer keeps the technical documentation and the EU declaration of conformity for 5 years from the date the packaging was placed on the market, or 10 years for reusable packaging. The CLP label names its supplier, according to ECHA; who that supplier is follows the definitions of the CLP Regulation, which this article does not read. Own-brand repackaging is also covered in our guide for private label retailers.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 3 October 2026) confirms three statements here: the scope of Article 2(1), the heavy-metal limit of Article 5(4) and the recyclability obligation of Article 6(1). The points below were read on the Official Journal text or on the linked official pages on 8 October 2026.
- Articles 2(2), 3(1)(13), 3(1)(49), 6(11), 6(12), 7(1), 7(4), 12(1), 12(5), 12(8), 15(3), 21, 29(1) and 29(4), and recital 24, read on the Official Journal text, not recorded in our referential.
- Our readings: no dangerous-goods wording in Articles 5, 12, 15, 38, 39 and 44 to 46; the exemption following transport use, not CLP classification; the split packaging by packaging; the roles table.
- Every statement on the CLP Regulation, Regulation (EU) 2025/2439, Directive 2008/68/EC and the June 2026 agreement, read on official pages. The final text and its dates are not confirmed before publication in the Official Journal.
- Not read: the text of Directive 2008/68/EC and its annexes, and the CLP rules for packaging carrying transport labelling. Nothing here is legal advice.
Frequently Asked Questions
Is dangerous-goods packaging outside extended producer responsibility?
No exemption is written in Articles 44 to 46 of Regulation (EU) 2025/40. The words dangerous goods appear only in Articles 6(11)(f), 7(4)(f) and 29(4)(a); Directive 2008/68/EC is also cited in Articles 2(2) and 3(1)(49).
Does a drum used for dangerous goods still need to meet the heavy-metal limit?
Yes. Article 5 of Regulation (EU) 2025/40 has no dangerous-goods exemption, so the 100 mg/kg limit of Article 5(4) applies to a drum carrying dangerous goods as to any other packaging.
How PPWR Connect Helps
PPWR Connect is software for Regulation (EU) 2025/40: it does not classify chemicals, does not design CLP or transport labels and is not a legal adviser. A packaging item can record its use context and whether it belongs to a reuse system. Substance lines are declared per packaging component as present, absent or not declared, each with its source and supplier evidence. A supplier PDF such as a test report, a certificate or a datasheet is read by the platform and filed as evidence against the SKU for the Declaration of Conformity. To see which of your packaging carries dangerous goods and which counts towards the 2030 targets, start with our PPWR compliance software or the PPWR readiness assessment.
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.