What’s new?
On the 30th of March 2026, the European Commission approved the official guidance document for the PPWR (Regulation (EU) 2025/40 on packaging and packaging waste) alongside a complementary document with a set of questions. The two documents were issued in response to significant stakeholder questions following the Regulation’s entry into force in February 2025. The guidance does not create new obligations — it interprets selected provisions to support uniform application across Member States and may be updated as implementation progresses.
Key provisions:
PFAS in food-contact packaging (Article 5(5))
- From 12 August 2026: limits of 25 ppb (single PFAS), 250 ppb (sum of PFAS), and 50 ppm (total fluorine including polymeric PFAS).
- No transition period: packaging placed on the market from 12 August 2026 must comply regardless of production date.
Manufacturer vs. producer
- The manufacturer is the brand owner who has packaging produced under their name or trademark — not the contract manufacturer or converter. Conformity assessment and technical documentation obligations fall on the brand.
- The producer responsible for EPR fees is determined market by market. Companies selling across multiple Member States must establish their producer status in each one separately.
Recyclability (Article 6)
- General recyclability obligation from 12 August 2026, assessed against existing standard EN 13430:2004 until further delegated acts apply.
- Detailed design-for-recycling requirements from 1 January 2030 or 24 months after the relevant delegated act, whichever is later.
Packaging minimisation (Article 10)
- From 1 January 2030: packaging weight and volume must be reduced to the minimum necessary for functionality. Marketing and consumer acceptance are no longer valid justifications for excess volume.
- Exemption available for packaging shapes protected by design rights or trademarks registered before 11 February 2025, provided compliance would alter the packaging’s novelty, individual character, or distinctiveness.
Harmonised labelling (Article 12)
- Mandatory waste-sorting labels from 12 August 2028.
- Mandatory reusable packaging labels, including QR code or digital data carrier, from 12 February 2029.
- Existing national sorting labels cannot coexist with EU harmonised labels after 12 August 2028.
What now?
- 12 August 2026: PPWR applies. PFAS limits and general recyclability obligation take effect.
- 12 August 2028: Mandatory waste-sorting labels on consumer-facing packaging. National sorting labels phased out.
- 12 February 2029: Mandatory reusable packaging labels with digital data carrier.
- 1 January 2030: Packaging minimisation, 50% empty space ratio, re-use targets, and single-use plastic packaging bans take effect.
