Make packaging for both the European Union and China and you run into the same question: can’t one compliance program cover both? The short answer is no. The gap between the two markets is bigger than most suppliers expect, and in a few places it is smaller than they fear.
This guide walks through how the EU’s Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) and China’s Ecological Environment Code plus its related national standards treat the same physical package. The goal is practical. It shows exactly where the two systems diverge, where they quietly converge, and what you should do about it before your next production run.
The takeaway in one paragraph
Compliance for a single batch sold in both markets is not the sum of two checklists. The EU sets a few requirements that China does not match at all, most notably a single, uniform heavy-metal ceiling that applies to every type of packaging. China, in turn, has no equivalent unified numeric limit that covers all packaging materials, so some items that escape mandatory testing at home still have to be re-tested to the EU’s stricter standard for export. On compostability, the two sides sit surprisingly close on technical thresholds, yet their certificates do not recognize each other. In other words, similar science, separate paperwork.
The counter-intuitive trap: “technically equivalent” is not “legally accepted”
A common assumption among material suppliers goes like this: “Our product is certified to GB/T 28206, which is technically identical to ISO 17088, so it should clear the EU without a problem.”
On the technical level, that reasoning mostly holds. China’s GB/T 28206-2011 was adopted as an equivalent of ISO 17088:2012. Its heavy-metal limits and its CO₂ conversion thresholds line up with the EU’s current EN 13432. They belong to the same international family of industrial composting standards.
But the certificate itself is not mutually recognized. A Chinese GB/T certification cannot be presented as proof of EU market access. To sell into the EU, you still have to apply separately for EN 13432 certification through an EU-recognized body such as TÜV Austria or DIN CERTCO, and walk through an independent testing process. Technical closeness is not the same as regulatory recognition. This single distinction trips up more exporters than any other.
How the two systems are built differently
You need to understand the underlying logic before comparing specific limits, because it explains why the checklists don’t line up.
The EU runs one unified regulation with a phased timeline. PPWR (Regulation (EU) 2025/40) applies directly across all 27 member states. Its core obligations (heavy-metal limits, PFAS limits, and declarations of conformity) became applicable on 12 August 2026. The mandatory compostable categories, however, do not take force until 12 February 2028, leaving a buffer of roughly a year and a half. During the transition, member states may decide individually whether to require elements earlier.
China’s framework took effect all at once. The packaging-related provisions of the Ecological Environment Code entered into force directly on 15 August 2026, without the kind of staged, “first enacted then delayed” schedule the EU uses. Just as important, China has no single numeric national standard that caps heavy metals across all packaging materials at once. Instead, heavy-metal control is scattered across product-specific standards divided by use. Food-contact materials (the GB 4806 series), food itself (GB 2762), and similar dedicated rules each carry their own limits, rather than one red line inside a packaging law.
The practical upshot: the EU draws a single horizontal line across the whole packaging universe, while China draws several vertical lines by product category.
Three concrete dimensions where the two sides diverge
1. Heavy-metal limits: one line versus many
The EU is blunt. Article 5(4) of PPWR caps the combined total of lead, cadmium, mercury, and hexavalent chromium at 100 mg/kg, and it applies to all packaging types regardless of whether they touch food.
China has no matching unified numeric standard that covers every packaging material. Limits are distributed by intended use across sector-specific standards. The consequence is awkward: a non-food-contact package that falls outside China’s mandatory testing scope at home still has to be measured again, on the EU’s terms, before it can be exported. Same box, two different measurement regimes.
2. Compostable thresholds: close on paper, separate in practice
Here the two systems look almost like cousins. China’s GB/T 28206 (equivalent to ISO 17088:2012) and the EU’s EN 13432 belong to the same mainstream industrial-composting family. Both reference the ISO 14855 series to measure CO₂ conversion and both demand the internationally recognized high bar.
The catch is that China also maintains other, lower-threshold definitions. GB/T 20197 is a broad “degradable plastics” standard that folds oxo-degradation and thermal-oxidative degradation into the “degradable” label. GB/T 38082, written for shopping bags, sets a biodegradation-rate floor (single component at least 60%) that sits clearly below the industrial-composting benchmark. These three standards are not interchangeable. If you are exporting to the EU, you must aim at the tier that aligns with ISO 17088, not the easier one.
3. Implementation timelines: buffer versus immediate
The EU gives industry room to adjust. Its mandatory compostable categories only become compulsory on 12 February 2028. Those categories include non-permeable tea bags and coffee pods, adhesive labels on fruit and vegetables, and ultra-light plastic bags. The unified sorting label publishes its detailed rules no later than 12 August 2026 and becomes mandatory to affix in August 2028.
China’s restrictions, by contrast, switched on together with the Ecological Environment Code on 15 August 2026, with no comparable graded buffer. A brand that planned around “the EU gives us until 2028” may be surprised to find the China side already live.
Side-by-side comparison
| Dimension | EU: PPWR (Regulation (EU) 2025/40) | China: Ecological Environment Code + related GB standards |
| Heavy-metal limit | Art. 5(4): lead + cadmium + mercury + hexavalent chromium combined at or below 100 mg/kg, covering all packaging types | No unified numeric national standard; limits dispersed by use (food-contact materials, toys, etc.) |
| Compostable standard | EN 13432 (current); a revised version is in preparation | GB/T 28206 (equivalent to ISO 17088:2012), technically very close |
| Mandatory effective rhythm | Core clauses from 12 Aug 2026; compostable categories only from 12 Feb 2028 | Restriction clauses in force at once from 15 Aug 2026 |
| Labeling | Unified sorting label; detailed rules by 12 Aug 2026, mandatory affixing Aug 2028 | “jj” biodegradability mark (GB/T 41010-2021); no unified sorting-label system |
| Certificate recognition | Requires certificates issued by locally recognized bodies (TÜV, DIN CERTCO, etc.) | GB/T certification cannot substitute for EN 13432; the two are not mutually recognized |
What each role should do now
Overseas brands and packaging buyers should run heavy-metal testing to the stricter EU 100 mg/kg standard across the board if the same package will be sold on both sides. One measurement regime beats maintaining two supply chains and two test programs.
Material and additive suppliers holding only a GB/T 28206 or ISO 17088 certificate need to tell customers plainly that it does not replace an EU EN 13432 certificate. Build separate certification time and budget into any export plan.
Compliance and testing leads should track two moving targets: the EU’s detailed rules for the unified sorting label, and the latest status of China’s GB/T 20197 revision. Both directly shape what you can print on a label and say in marketing copy.
Frequently asked questions
Do EU and Chinese compostable certifications recognize each other? No. Even when the underlying technical standards are equivalent (GB/T 28206 and ISO 17088:2012 both align with EN 13432), the certificates are not mutually accepted. EU market access requires a separate EN 13432 certificate from an EU-recognized body.
Which heavy-metal limit applies to all packaging in the EU? Under PPWR Article 5(4), the combined total of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg for every packaging type, food-contact or not.
Does China have one unified heavy-metal limit for all packaging? Not at present. Limits are spread across use-specific standards such as the GB 4806 food-contact series, rather than a single horizontal cap inside the packaging rules.
When do the EU compostable rules become mandatory? The mandatory compostable categories take effect on 12 February 2028, with core PPWR clauses already applicable from 12 August 2026.
When did China’s new packaging restrictions take effect? The relevant provisions of the Ecological Environment Code entered force directly on 15 August 2026.
This article is a framework-level comparison for planning purposes and is not compliance advice. Specific testing and certification requirements should be confirmed with a qualified third-party body and the latest official texts.