The EU Packaging and Packaging Waste Regulation began applying on 12 August 2026. The first obligations are narrower than the headlines suggest, but they already reach non-EU packaging manufacturers through documentation their EU customers must now hold.
What Happened
From 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, applies across the European Union. The European Commission's Directorate-General for Environment announced the milestone on 11 August, describing a harmonised framework that replaces fragmented national packaging rules with a common set of EU requirements covering the whole packaging life cycle.
The regulation entered into force in February 2025, and its rules apply in phases. The phase that began in August is not the one most people associate with the PPWR. Recyclability requirements, recycled content targets and reuse obligations come later. What changed first is a set of chemical restrictions and a formal conformity procedure that every manufacturer of packaging placed on the EU market must now follow.
What Took Effect First
PFAS limits in food-contact packaging
The measure the Commission highlighted is a restriction on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. Food-contact packaging containing PFAS above the set limits can no longer be placed on the EU market. The Commission notes that PFAS have commonly been used to repel water or grease in takeaway containers, fast-food wrappers, microwave popcorn bags, bakery paper and pizza boxes.
As summarized in a March 2026 Food Safety Magazine analysis, the limits are 25 parts per billion for any individual PFAS and 250 parts per billion for the sum of PFAS, both measured by targeted analysis and excluding polymeric PFAS, plus 50 parts per million for total fluorine, which includes polymeric PFAS.
According to guidance compiled by the UK Food and Drink Federation (FDF), the Commission has confirmed that these limits apply to the packaging unit as a whole, including inks, coatings and adhesives, and apply whether PFAS are intentionally added or present unintentionally. The FDF also reports that there is no general stock-exhaustion period. Packaging already placed on the market before 12 August may remain, but packaging first placed on the market on or after that date must comply. Because sales packaging is generally placed on the market when it is filled, holding empty packaging made before the deadline does not by itself mean it was already placed on the market.
Heavy metals
The long-standing limit on heavy metals continues under the new regulation. The FDF notes that the combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg.
Conformity assessment and declaration
This is the change with the widest reach. Before packaging is placed on the EU market, the manufacturer must assess its conformity following the procedure in Annex VII of the regulation, prepare technical documentation, and draw up an EU Declaration of Conformity. The FDF explains that, from 12 August 2026, the requirements covered are Article 5(4) on heavy metals, Article 5(5) on PFAS in food-contact packaging and, where applicable, Article 11(1) on reusable packaging. More articles will fall within scope as their provisions start to apply.
The documentation must be kept and made available to authorities on request for at least five years for single-use packaging, with a longer period for reusable packaging. Importers must verify that the manufacturer has completed these steps before placing imported packaging on the EU market.
What Comes Later
The Commission has set out the next phases:
| Timing | What applies |
| 12 August 2026 | General application; PFAS limits in food-contact packaging; conformity assessment and declaration |
| From 2028 | Harmonised EU labelling system for packaging to support waste sorting |
| From 2030 | Limits on empty space, restrictions on certain single-use plastic packaging, reuse targets |
| From 2030 | Mandatory recycled plastic content in new plastic packaging; all packaging required to be recyclable |
The Commission also published implementation guidance in March 2026, including practical information on applying the PFAS restrictions.
What It Means for Suppliers Outside the EU
For packaging makers in Asia and other regions that sell into Europe, the practical effect of the first phase is documentation. An EU brand owner or importer now needs evidence that the packaging it buys meets the PFAS and heavy metal limits, backed by technical documentation and a declaration of conformity. That evidence has to come from the supply chain.
Suppliers should expect three kinds of requests:
- Composition and supplier declarations covering the base material and every component in contact with food, including coatings, inks and adhesives.
- Test reports for PFAS, often starting with total fluorine screening and moving to targeted PFAS analysis where results require it. The FDF notes that UK guidance recommends accredited laboratories, with ISO/IEC 17025 accreditation cited as appropriate.
- Traceability that links a declaration to specific production batches, so a customer can show which lots were placed on the market after 12 August.
Suppliers of grease-resistant paper and board, molded fiber and coated food containers face the most immediate pressure, because PFAS-based treatments were common in those formats. For them, reformulation, test data and clear supplier declarations are now conditions of access to the EU market rather than optional sustainability claims.
FAQ
Does the PPWR ban all PFAS in all packaging?
No. The restriction that applies from August 2026 covers food-contact packaging, and it works through concentration limits rather than a zero threshold. Other packaging is not covered by this specific restriction, although other chemical rules may still apply.
Do non-EU manufacturers need to register or appoint anyone in the EU?
The first-phase obligations centre on conformity assessment and documentation. The EU importer must verify that the manufacturer has completed them. Manufacturers should confirm with their importers or legal advisers how responsibilities are allocated for their specific products and markets.
Can packaging produced before 12 August 2026 still be sold?
Only if it was already placed on the market before that date. Packaging that is placed on the market for the first time on or after 12 August must comply, and the Commission has indicated there is no general stock-exhaustion period for non-compliant food-contact packaging.
Conclusion
The PPWR's first phase is about chemistry and paperwork, not yet about recyclability or reuse. For exporters, the immediate task is to make sure every food-contact packaging item sold into the EU can be backed by test data and a declaration that covers all components. Suppliers who build that documentation now will also be better placed for the 2028 labelling rules and the 2030 recyclability and recycled-content requirements, which will rely on the same supply chain evidence.
The overview above is general market information, not legal advice; companies should check the regulation text and official Commission guidance for their specific products.
