Short answer: PPWR (Regulation (EU) 2025/40) covers packaging placed on the EU market, including shoe-box inserts. Use DMF-free, REACH-documented anti-mold packaging and keep the current SGS file with the shipment pack. This page is not legal advice.
Regulation (EU) 2025/40 (PPWR) is the EU packaging rule that replaces Directive 94/62/EC. Footwear and leather-goods brands placing packaging on the EU market have to treat shoe-box inserts — anti mold chips, anti mold bags, desiccants — as packaging components, not as an unregulated “extra.”
What PPWR Changes for Anti-Mold Packaging
- Substance limits: Article 5 combined limit for lead, cadmium, mercury and hexavalent chromium in packaging or packaging components: sum ≤ 100 mg/kg. DMF remains prohibited. REACH SVHC screening is still the usual brand-audit file.
- Recyclability / design: design-for-recycling duties phase in on a later timetable. Small inserts are still packaging components; do not assume a chip is “out of scope.”
- Documentation: manufacturers keep technical documentation. Importers and brands will ask suppliers for test reports and a clear statement of what was tested.
This page is a buyer checklist, not legal advice. For the Article 5 wording and Bester’s SGS table, use the PPWR test notes. DMF background: DMF-free desiccant and REACH.
Which Anti-Mold Products Create Customs and Audit Risk
- Inserts that still contain DMF — not legal for EU consumer goods; shipment can be stopped.
- Suppliers who cannot produce a third-party report for packaging heavy metals and DMF.
- Suppliers with no REACH SVHC screen (251 substances is the current common ask).
Silica gel packets have the same documentation problem if they are placed on the EU market as packaging. Mold claims after silica gel alone are a different issue — see silica gel packets still moldy.
How Bester Supports PPWR-Related Buyer Files
Bester anti-mold chips and bags are DMF-free vapor-phase inserts. Packaging heavy metals are tested to the Article 5 combined 100 mg/kg limit. REACH SVHC and DMF reports are issued by SGS and provided on request (including report CANAF26001423003 for SVHC). We do not claim a public downloadable “PPWR certificate” that replaces your importer’s technical file.
- A505 anti mold chip — plant-based vapor-phase, DMF-free
- C304 anti mold bag — DMF-free, REACH documented
- Container desiccant poles — CaCl2 hanging poles; moisture layer, not a heavy-metal waiver
What Brands Should Do Now
- List every anti-mold and desiccant SKU in EU-bound shoe boxes.
- Ask each supplier for DMF, REACH SVHC, and packaging heavy-metal (Article 5) reports.
- Keep those files with the article’s technical documentation — do not wait for a 2026 border hold.
- Request Bester samples plus the current SGS pack for A505 / C304.
Limitations: When This Approach Does Not Apply
- This page is a buyer checklist, not legal advice and not a substitute for counsel in the destination market.
- A test report is batch- and date-specific. Ask for the current pack, not a screenshot of an old PDF.
- PPWR wording does not replace box-level humidity and spore control on the packing line.
According to test report No. 2025FM00761R01D from Guangdong Provincial Microbiological Analysis and Testing Center (method DA/T 26-2000, issued 2025-02-26) — Mold Growth Rating: Grade 0, 28-day test, 8 mold species, tested on paper/cloth/leather — all three materials showed zero visible mold growth, A505 anti-mold chips inhibit spore germination throughout the test period. According to SGS REACH SVHC test (report No. CANAF26001423003), 251 SVHC substances plus 4 potential SVHC were not detected (≤ 0.1% w/w). DMF was not detected per SGS report No. CANAF26001423001 (< 0.1 mg/kg).
FAQ
- When does PPWR take effect?
- Regulation (EU) 2025/40 is already adopted. Most provisions apply from 12 August 2026, with further dates into 2027. DMF was already banned earlier. Do not treat “2025” as the date chips become illegal if they were already DMF-free.
- Are anti mold chips affected by PPWR?
- Yes, as packaging components when placed in sales packaging on the EU market. They must meet applicable substance restrictions. Recyclability design rules follow the regulation’s staged timetable.
- How do I verify DMF-free?
- Ask for a third-party (SGS or equivalent) DMF test report on the actual insert, not only a brochure claim. Bester provides SGS files on request.
Get samples and the current test pack
Share destination market (EU) and SKU. We will send A505 / C304 samples and the SGS / REACH / DMF set used in brand audits.
Sources and Further Reading
- Guangdong Provincial Microbiological Analysis and Testing Center (Report No. 2025FM00761R01D, 2025) — Mold Growth Rating Test, Grade 0 (28 days, 8 species, paper/cloth/leather)
- REACH SVHC Compliance Test (SGS report No. CANAF26001423003) — 251 SVHC substances + 4 potential SVHCs, all not detected (≤ 0.1% w/w)
- DMF Content Test (SGS report No. CANAF26001423001) — not detected (< 0.1 mg/kg)
For factories & exporters
Home mold cleaning is not the same as export packing mold control. If you run a shoe factory or brand program, use vapor-phase anti-mold inserts (not silica gel alone) before sealing boxes.
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