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PPWR three months in: substances are being checked now, 2030 is the real hurdle
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and applies generally 12 August 2026, when Directive 94/62/EC was repealed after nearly thirty years. It is not a single cut-off: 2026 tests substances and identity, 2030 tests design and waste.
1. Four dates to keep straight
| Date | What applies |
|---|---|
| 12 Aug 2026 | Already in force: heavy-metal limits, PFAS limits for food-contact packaging, design-for-recycling obligation, EPR registration and declaration of conformity; the old Directive is repealed |
| 12 Aug 2028 | Harmonised material sorting labels; tea and coffee bags, fruit stickers and similar must be compostable |
| 1 Jan 2030 | The bulk of the obligations: recyclability grade A/B/C (≥70%), minimum recycled content in plastic packaging, minimisation and empty-space caps, Annex V bans on certain single-use formats |
| 1 Jan 2038 | Only grade A/B (≥80%) may be placed on the market; grade C exits |
The split is simple: 2026 governs chemical safety and identification; 2030 governs recyclability and waste. The two have very different lead times — a test report takes days or weeks, but removing a laminated film, switching materials or changing carton dimensions means tooling, new suppliers and factory audits: typically 12–18 months.
2. Three things that must comply today
- Lead, cadmium, mercury and hexavalent chromium: ≤ 100 mg/kg combined. This covers every packaging component — outer carton, inner box, inks, glues, laminating film, tape, labels, cushioning. Not just the carton, and no derogation.
- PFAS in food-contact packaging, three thresholds: any targeted PFAS ≤ 25 ppb; sum of targeted PFAS ≤ 250 ppb; total fluorine including polymeric PFAS ≤ 50 ppm. The Commission's guidance recommends a stepwise approach: test total fluorine first — below 50 mg/kg compliance can be presumed — then pyrolysis GC/MS if needed to separate organic from inorganic fluorine. No stock transition period: packaging placed on the market after 12 August must comply.
- Design for recycling, EPR and the declaration of conformity: packaging must be recyclable and covered by a DoC; technical documentation must be kept 5 years for single-use and 10 years for reusable packaging. Test reports and self-declarations produced under the old Directive do not replace PPWR conformity documents.
How stock is treated: packaging placed on the market before 12 August 2026 and still in circulation may be sold through without recall. Packaging produced but not yet placed on the market must meet the new rules to be placed — and non-compliant stock may not enter the market. For imports, the reference point is release for free circulation at customs, so "it is still on the water" is not an argument.
3. The 2030 workload: change the structure now
- Recyclability as a market-access grade: Article 6 establishes design for recycling. From 2030 packaging must reach grade A/B/C (recyclability ≥70%) and grade D may not be placed on the market; from 2038 only A/B (≥80%). The calculation method comes through delegated acts; in the meantime EN 13430:2004 can support a self-assessment but is not proof of conformity.
- Minimisation and empty space: only packaging necessary for protection and transport. Article 10 caps empty space at 50% for grouped, transport and e-commerce packaging; the Commission sets the calculation method by 12 February 2027, with EN 13428:2004 valid until the end of 2029. Marketing no longer justifies extra volume.
- Recycled content in plastics: by 2030, 30% for contact-sensitive PET, 30% for single-use beverage bottles and 35% for other plastic packaging, rising to 50%/65%/65% by 2040. Plastic components under 5% of packaging weight and below 100 g absolute may be exempt.
- Annex V banned formats: single-portion sachets for condiments, sauces, creamers, sugar in food service; single-use plastic sales packaging for less than 1.5 kg of unprocessed fresh fruit and vegetables; very lightweight plastic carrier bags. Food service also has two dates: customers must be allowed to bring their own containers from 2027, and a reusable option must be offered from 2028.
4. Reading risk by material beats reading it by article
| Material | Today | Assessment |
|---|---|---|
| Plastic-laminated folding carton | Allowed | The biggest 2030 penalty: film and board are permanently bonded, inseparable in paper recycling, which drags the DfR grade down. Move to uncoated board, water-based varnish or mono-material |
| EPS foam inserts | Allowed | PPWR does not ban EPS outright (the widely shared claim is inaccurate), but collection is thin, the grade is low and some Member States restrict it. Switch to moulded pulp or honeycomb paper |
| Carton tape / self-adhesive labels | Allowed | Prefer kraft paper tape and paper labels with water-based adhesive to keep the carton co-recyclable; follow the harmonised sorting labels from 2028 |
| Bubble wrap / PE bags | Allowed | Counts toward recycled-content statistics; replace with paper where technically possible to cut the plastic share |
| PP/PET strapping | Allowed | Avoid PVC; being separable by hand is the baseline, paper strapping is the safer option |
| Corrugated cartons, moulded pulp | Preferred | Mono-material and easily recycled — the direction 2030 grading and minimisation both reward |
5. The document pack to have ready
- Packaging BOM: layer by layer — carton, inner box, tape, labels, cushioning, strapping — with material, grammage and supplier.
- Heavy-metal test reports covering all components including inks, adhesives and laminating film; testing only the carton is the most common gap.
- PFAS test reports where food-contact packaging is involved, following total fluorine → organic fluorine → specific PFAS.
- Declaration of conformity and technical documentation, including the minimisation and design-for-recycling rationale; retained 5 years (single-use) or 10 years (reusable).
- EPR registration in each country of sale; non-EU producers generally need an authorised representative (the Commission's December 2025 Environmental Omnibus proposed suspending that obligation for producers selling directly to consumers — still under examination, so current rules apply until adopted).
6. What to do in 90 days
- Days 0–30: take stock and send samples. Complete the packaging BOM for your main SKUs, run heavy metals across all components and total-fluorine screening on food-contact items — clear the 2026 gate first.
- Days 30–60: launch the redesign. Priority order: remove lamination → paper instead of plastic → pulp instead of EPS → optimise carton size to cut empty space. Start with the three highest-volume SKUs.
- Days 60–90: build the register. File DoCs, technical documentation, test reports and recycled-content data so they survive a customer audit or a customs check; complete the main-SKU switch before 2027.
One more thing to watch: the Commission published implementation guidance in March 2026 and a second FAQ edition in August 2026, and is consulting on a candidate list of roughly 700 substances of concern — bisphenol A and PFAS among them — expected by the end of 2026. The list of substances will keep growing; testing is not a one-off.