Get ready for the EU’s packaging regulation: PPWR Requirements that are effective from August

Vol. 1536 | 06 May 2026

The EU Packaging and Packaging Waste Regulation (PPWR) will apply from August 12, 2026, introducing new requirements on PFAS, heavy metals, declarations of conformity, operator identification, EPR registration, and reusable packaging systems to improve packaging sustainability and traceability.

With the Regulation (EU) 2025/40 — commonly known as the Packaging and Packaging Waste Regulation (PPWR) — set to apply from August 12, 2026, stakeholders have less than four months to align their operations with the new legal framework.

This regulation is a fundamental shift in how packaging is designed, tracked, and managed across the European Union. Here is your roadmap to the five critical compliance pillars that must be ready by August.

PFAS and Heavy Metals Requirements

Safety and sustainability start at the molecular level. From August 12, the EU is enforcing strict limits on PFAS and toxic metals in all packaging placed on the market.

• The PFAS Ban: Per- and polyfluoroalkyl substances (PFAS) are prohibited in food-contact packaging if they exceed specific limits: 25 ppb for individual non-polymeric PFAS; 250 ppb for the sum of non-polymeric PFAS; and 50 ppm for total fluorine (including polymers).
• Heavy Metal Limits: The combined concentration of Lead, Cadmium, Mercury, and Hexavalent Chromium must not exceed 100 mg/kg. While this limit existed under older directives, the PPWR introduces more rigorous market surveillance.

EU Declaration of Conformity (DoC)

By August, every packaging type sold in the EU must be accompanied by a formal EU Declaration of Conformity.

Manufacturers are responsible for drafting and issuing the DoC; importers must ensure compliance by securing and validating these documents for every shipment.

The DoC must be backed by a technical file containing design specifications, test results, and recyclability assessments. This documentation must be kept for 5 years for single-use packaging and 10 years for reusable packaging.

Manufacturer and Importer Identification

To ensure traceability and accountability, the PPWR requires clear identification of the economic operators involved.

Packaging must bear the name, registered trade name or trademark, and a postal address for both the manufacturer and, where applicable, the importer.

 EPR Registration in Every Member State

Under Extended Producer Responsibility (EPR), producers must register in each Member State where you make packaging available for the first time. If the producer is not established in a Member State where you sell, Authorized Representative may be required to handle your EPR obligations.

Reuse Systems

By 12 August 2026, anyone placing reusable packaging on the market must ensure an active system is in place for collection, reconditioning, and redistribution. This includes having clear instructions for consumers, designated drop-off points, and established logistics to ensure the packaging actually returns to the loop.

Summary of the timeline 

August 12, 2026: General Application Date

• PFAS Ban
• Heavy metals restrictions
• Declaration (DoC)
• Extended producer responsibility (EPR)

February 12, 2027: Reuse and Refill Initiatives

• Hotel, Restaurant and Catering (HORECA sector) must offer customers the option to bring their own reusable containers to be filled at no extra charge.

August 12, 2028: Harmonized Labelling

• Packaging placed on the market shall be marked with a harmonised label indicating material composition, reusability (via QR code), and consumer sorting instructions.

January 1, 2030: The Major Sustainability Milestone

• Systemic changes to packaging design and waste reduction become mandatory.
• All packaging placed on the EU market must be recyclable and achieve a Grade A, B, or C recyclability rating.
• Plastic packaging must meet minimum recycled content thresholds.
• -commerce, transport, and grouped packaging must not contain more than 50% empty space.
• Single-Use Bans: Bans take effect for certain single-use plastic formats.
• Reuse Targets: Certain transport and sales packaging must hit minimum reuse thresholds.

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