Different types of food packaging materials

PPWR: Packaging and Packaging Waste Regulation – key changes in the EU and the impact on the food industry

31 July 2026 | Lorna Yates, Regulatory Insights and Categories Team Manager

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) entered into force on 11 February 2025 and will apply from 12 August 2026, with phased implementation for many of its requirements. It differs significantly from the Packaging and Packaging Waste Directive (PPWD), which it repeals.

The PPWR applies directly in all EU Member States and in Northern Ireland, but it does not apply in Great Britain. Its overarching objectives are twofold:

to harmonise what had become a fragmented approach to packaging and packaging waste, particularly in relation to recyclability labelling, and;
to strengthen the environmental objectives of the PPWD through ambitious targets and new requirements intended to protect human health and the environment.

PPWR timelines

As the PPWR application date approaches, our regulatory affairs team is receiving an increasing number of enquiries from food businesses seeking to understand how the legislation should be implemented.

One of the key questions is around timing: many provisions will not apply from August 2026, but will instead apply from 2028, 2030 and beyond. In several areas, delegated acts and updated guidance are still awaited, including details on recyclability criteria and EU-harmonised recyclability labelling.

In short, the requirements that apply from 12 August 2026 are those provisions in the Regulation that are not expressly identified as applying from a later date.

Of the core requirements within the PPWR (listed in Articles 5-12) only Article 5 applies in a significant way from 12 August. Article 5 addresses substances of concern within packaging and includes new restrictions for per- and polyfluorinated alkyl substances (PFAS) in food contact packaging. Article 6, which requires all packaging to be recyclable, also applies to an extent. However, although Article 6 technically applies from 12 August 2026, the delegated acts setting out recyclability criteria have not yet been adopted. As a result, manufacturers must comply with the recyclability requirement in accordance with the Packaging and Packaging Waste Directive and the related harmonised standard (EN 13430:2004, Requirements for packaging recoverable by material recycling).

Additional requirements applying from 12 August 2026 include the obligations set out in Articles 15–20 of the PPWR for different economic operators in the supply chain for packaging and packaged goods. Of particular importance are the obligations and responsibilities applying to manufacturers under Article 15 and importers under Article 18.

PFAS limits in the PPWR

From 12 August 2026, food-contact packaging must not be placed on the market if it contains PFAS at or above the following concentrations:

(a) 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification);
(b) 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation;
(c) 50 ppm for PFASs (including polymeric PFAS); if total fluorine exceeds 50 mg/kg the manufacturer, importer or downstream user as defined respectively in Article 3, points (9), (11) and (13) of Regulation (EC) No 1907/2006 shall, upon request, provide to the manufacturer or the importer as defined respectively in Article 3(1), points (13) and (17), of this Regulation proof of the quantity of fluorine measured as content of either PFAS or non-PFAS in order for them to draw up the technical documentation as referred to in Annex VII to this Regulation.

The EU guidance and FAQ documents published on the PPWR provide some insight into this new requirement for food-contact packaging. There is currently no harmonised methodology for PFAS testing, as multiple protocols and methodologies exist. However, the guidance document does provide a stepwise approach to demonstrating compliance.

No implementation period is currently identified for these restrictions, so all food contact packaging placed on the EU market from 12 August 2026 will need to comply. However, packaging placed on the market before that date does not need to be withdrawn from sale.

Roles and responsibilities

Alongside compliance with the new PFAS requirements, businesses should ensure that they understand their wider obligations under the PPWR, which will apply from August 2026. This largely depends on where a business sits within the list of economic operators set out in Article 3 of the Regulation.

For food businesses approaching the PPWR for the first time, we recommend starting by determining and documenting their role under the legislation.

Two key roles to determine for each business, and for each route to the EU market, are those of “manufacturer” and “producer”. The manufacturer is not necessarily the physical manufacturer of the packaging, rather, it is the business who “orders and decides on the design specifications for packaging” and, therefore, is often the brand holder of the packaged product. The manufacturer must ensure conformity of all packaging materials with the Regulation by carrying out a conformity assessment and drawing up a Declaration of Conformity. By contrast, the producer is any manufacturer, importer or distributor who makes packaging or packaged product available for the first time in an EU Member State. Under the Extended Producer Responsibility (EPR) scheme, the producer is responsible for financing waste management in the Member State where the packaging is expected to become waste.

PPWR labelling implications

The PPWR has implications for the labelling of packaged foods placed on the EU market. From 12 August 2026, the indication requirements for manufacturers and importers, listed under Articles 15 and 18 respectively, should be complied with.

The Regulation also lays down a harmonised recyclability labelling scheme intended to replace all individual Member State schemes. The delegated act setting out the details of these labelling requirements is expected to be published by 12 August 2026, with a 24-month implementation period from the date that delegated legislation enters into force.

How we can help

Our valuable, extensive and authoritative information and advisory service helps clients stay up to date with food regulations in more than 80 countries. Whatever the legislative requirements of your target market, our experienced team of regulatory experts can support your understanding and compliance.

We can support businesses with PPWR implementation in several ways:

Our regulatory experts run a scheduled online PPWR training course.
We can support individual or in-depth enquiries into the legislation, as well as bespoke training courses for your business.
Our analytical team can help with PFAS testing.

More broadly, we are here to help with all elements of managing food safety, quality and compliance with confidence – navigating change, controlling risk, and protecting your brand.

From initial supply chain risk assessments through to final product assurance, we provide consultancy and guidance at every step. Our regulatory experts help you meet the legal requirements of your target markets and keep up with changes. And our laboratories are here to help with the design and execution of testing plans to demonstrate compliance.