PPWR: What packaging obligations will come into effect on August 12, 2026?

The most important part of identifying the requirements that apply to your business is determining your role regarding the packaging and the type of packaging present in your supply chain. Below is a summary of the requirements from three articles of the PPWR Regulation that take effect today.

Art. 5: Requirements for substances present in packaging - Limits for PFAS and heavy metals

Eco-design is not just about facilitating recycling and reuse, but also—and from a health perspective, primarily—about eliminating harmful substances from packaging composition, such as heavy metals.

• Heavy metals: The sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium resulting from the presence of constituent substances in packaging or packaging components must not exceed 100 mg/kg.
• ‍Per- and polyfluoroalkyl substances (PFAS): The PPWR does not introduce a total ban on the use of PFAS, but as of August 12, 2026, it drastically limits their concentration (maximum limits) in packaging intended for direct contact with food. These limits apply to the packaging as a unit, including all components such as inks, adhesives, varnishes, or labels.

There are three thresholds for permissible PFAS concentrations:

• 25 ppb for all PFAS measured using targeted analysis of PFAS (polymeric PFAS excluded from quantification);
• 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where appropriate with prior degradation of precursors (polymeric PFAS excluded from quantification);
• 50 ppm for PFAS (including polymeric PFAS); if the total fluorine content exceeds 50 mg/kg, the manufacturer, importer, or downstream user as defined in Article 3(9), (11), and (13) of Regulation (EC) No 1907/2006, respectively, shall provide the manufacturer or importer as defined in Article 3(1)(13) and (17) of this Regulation, upon their request, with evidence regarding the amount of fluorine measured as PFAS content or non-PFAS substances for the purpose of preparing the technical documentation referred to in Annex VII to this Regulation.