PPWR 2026: A Complete Guide to the New European Packaging Regulation
PPWR 2026: A Complete Guide to the New European Packaging Regulation
From 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR) will become fully applicable across the European Union. For companies operating in the food industry that manufacture, purchase or use packaging, this is far more than a regulatory update. It represents a fundamental transformation affecting packaging design, material selection, regulatory compliance and end-of-life packaging management.
Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), introduces new requirements that directly impact food contact packaging. These range from PFAS restrictions and the EU Declaration of Conformity to recyclability requirements and minimum recycled content targets, with obligations extending through to 2040.
As a result, many businesses are already reviewing their packaging portfolios to ensure compliance with the new legislation. Cartonpack Group is addressing this transition through its PPWR Ready approach, developing innovative multi-material packaging solutions designed to meet the requirements of the new European Packaging Regulation.
What is the PPWR and Why Is It Reshaping the Packaging Industry?
The Packaging and Packaging Waste Regulation (PPWR) represents the most significant overhaul of European packaging legislation in decades.
The Regulation aims to accelerate the transition towards a circular economy by reducing packaging waste and increasing the recyclability of the materials used across the European market.
From Directive to Regulation: What Changes in Practice?
The previous Directive 94/62/EC required each Member State to transpose its provisions into national law, resulting in different interpretations and varying implementation across European markets.
The PPWR, by contrast, is a directly applicable Regulation in all 27 European Union Member States. This establishes a harmonised legal framework with uniform rules, shared requirements and greater market consistency. Its provisions also apply to packaging imported from countries outside the European Union.
The restriction on PFAS is the first major operational requirement that food businesses must address, with compliance becoming mandatory from 12 August 2026.
What Are PFAS and Why Does the PPWR Restrict Them?
PFAS (Per- and Polyfluoroalkyl Substances) are a group of synthetic chemicals widely used across numerous industrial applications due to their water-, grease- and stain-resistant properties.
In the food packaging sector, they may be present in:
• Baking paper
• Fast-food containers
• Popcorn bags
• Barrier films and other food contact materials
The PPWR significantly restricts the use of PFAS because these substances are highly persistent in the environment and have the potential to bioaccumulate, meaning they build up in the tissues of living organisms faster than they can be broken down or eliminated.
The Regulation establishes the following maximum limits:
• 25 ppb for any individual PFAS substance;
• 250 ppb for the total concentration of PFAS;
• 50 mg/kg for total fluorine content.
To demonstrate compliance, companies must implement appropriate analytical testing procedures and obtain up-to-date technical documentation and certified declarations from their suppliers.
The technical verification process includes the following analytical stages:
• Total Organic Fluorine (AOF) Screening
A preliminary screening test used to identify potential exceedances of the regulatory thresholds. Positive results trigger further analytical investigations.
• Liquid Chromatography–Mass Spectrometry (LC-MS/MS or UHPLC-Q-TOF)
The reference analytical technique for the identification and accurate quantification of individual PFAS compounds, such as PFOA and PFOS, within packaging materials.
• Migration Testing
A testing procedure designed to simulate real food-contact conditions in order to assess the potential migration of chemical substances from the packaging material into the food product.
A Five-Step Action Plan to Achieve PPWR Compliance
Companies using food packaging should begin implementing a structured action plan without delay to ensure compliance with the new regulatory requirements.
1. Map Your Entire Packaging Portfolio
Identify all packaging materials and formats used across the business, with particular attention to those at higher risk of containing PFAS. Create a centralised inventory of all food contact packaging materials to establish a clear compliance baseline.
2. Audit Your Supply Chain and Improve Supplier Transparency
PFAS are often introduced through non-visible layers or during manufacturing processes carried out by upstream suppliers. Generic self-declarations are not legally sufficient. Companies should formally request updated Declarations of Conformity (DoCs) and analytical test reports from their suppliers, while establishing clear contractual responsibilities throughout the supply chain.
3. Implement an Analytical Testing Programme
Verify the actual compliance of packaging materials through accredited laboratory testing. Testing should confirm compliance with all three regulatory thresholds established under the PPWR.
4. Redesign Packaging Solutions and Evaluate Alternative Materials
Replace non-compliant materials and fluorinated chemical treatments with safer alternatives, such as natural biopolymers, mechanically treated paper, algae-based coatings or microfibrillated cellulose. New PFAS-free packaging solutions should undergo stability and shelf-life testing to ensure they continue to deliver the required grease-resistant performance and product protection.
5. Strengthen Documentation and Data Governance
Collect, centralise and maintain all analytical data to support regulatory audits and inspections by health and customs authorities. Analytical test results and supplier certifications should be incorporated into the technical documentation for each product, ensuring that the company's Food Contact Materials (FCM) Declaration of Conformity remains accurate, complete and up to date.
The Objectives: Less Waste, Greater Circularity
According to the European Commission, each EU citizen generated an average of 178 kg of packaging waste in 2023.
The PPWR aims to reverse this trend by introducing ambitious targets designed to promote a more circular packaging economy:
• A 5% reduction in packaging waste by 2030;
• A 10% reduction by 2035;
• A 15% reduction by 2040;
• 100% recyclability of all packaging placed on the EU market by 2030;
• Increased use of recycled plastic in packaging applications;
• The progressive phase-out of hazardous substances, including PFAS.
Key Deadlines Under Regulation (EU) 2025/40
Understanding the PPWR implementation timeline is essential for planning investments and ensuring packaging compliance with the new regulatory requirements.
12 August 2026: The First Major Compliance Deadline
From 12 August 2026, the first operational obligations under the PPWR will come into force:
• PFAS restrictions for food contact packaging exceeding the permitted thresholds;
• Mandatory registration with Extended Producer Responsibility (EPR) schemes;
• Issuance of an EU Declaration of Conformity for each packaging type;
• Compliance with the general recyclability requirements set out in Article 6 of the Regulation.
No transitional period is provided for newly placed products. Any packaging placed on the market from this date onwards must fully comply with the new regulatory requirements.
Retail and Takeaway Requirements (2027–2029)
• 2027: Bars, cafés and restaurants will be required to allow customers to use their own reusable containers for takeaway food at no additional cost.
• 2028: The introduction of harmonised packaging labelling will become mandatory, helping consumers correctly sort packaging waste and improving recycling across the European Union.
• 2029: Member States will be required to implement Deposit Return Schemes (DRS) for single-use plastic beverage bottles and aluminium cans.
2030: A Turning Point for Packaging Design and Recycling
From 2030 onwards, the PPWR introduces a new set of mandatory design requirements:
• Mandatory recyclability: all packaging placed on the EU market must be designed for recycling (Design for Recycling).
• Minimum recycled content: mandatory minimum levels of post-consumer recycled plastic must be incorporated into new plastic packaging.
• Single-use packaging restrictions: selected single-use packaging formats will be banned, including packaging for fresh fruit and vegetables (under 1.5 kg), single-portion packaging used in hotels and restaurants (such as sauce sachets and miniature toiletry bottles), and plastic luggage wrapping at airports.
• Reuse targets: large retailers will be required to dedicate at least 10% of their retail space to refill and reusable packaging systems.
Long-Term Targets (2035–2040)
• 2035: Packaging with low recyclability performance (Performance Grade C) will no longer be permitted on the EU market. Only packaging achieving Performance Grades A or B will be allowed.
• 2040 – The Final Milestone: The Regulation sets a mandatory 15% per capita reduction in packaging waste compared with 2018 levels. Reuse targets for transport packaging and beverage packaging will also increase significantly, reaching up to 70% for certain packaging categories.
Minimum Recycled Plastic Content
The PPWR establishes minimum recycled content targets for plastic packaging, introducing progressively higher requirements over time.
For the food packaging sector, compliance is particularly challenging, as recycled plastics intended for food contact applications must also comply with Regulation (EU) 2022/1616 on recycled plastic materials and articles intended to come into contact with food.
Under the PPWR, all plastic packaging will be required to meet mandatory minimum levels of post-consumer recycled content.
Cartonpack Group has already developed a range of rPET thermoformed packaging solutions containing more than 90% recycled material, while maintaining the highest standards of food safety and industrial performance.
EU Declaration of Conformity and Documentation Requirements
The PPWR establishes a comprehensive regulatory framework that redefines the responsibilities of every stakeholder involved in the packaging lifecycle.
The Regulation clearly distinguishes the roles and obligations of each economic operator, creating a structured compliance system in which responsibilities depend not only on the activities performed, but also on the geographical market in which the operator places packaging on the market.
Who Is the Manufacturer Under the PPWR?
The cornerstone of the PPWR framework is the definition of the Manufacturer. This role applies to any company that manufactures a packaged product, commissions its production by a third party on its behalf, or packages—or has a product packaged—and places it on the market under its own brand.
Unlike other economic operators, the Regulation establishes that each individual packaging item can have only one Manufacturer, ensuring a single, clearly identifiable entity responsible for product compliance and traceability throughout its lifecycle.
Supporting the Manufacturer is the Supplier, a term that covers any business providing packaging components or manufacturing packaging on behalf of third parties.
The regulatory framework further distinguishes between the roles of Producer and Distributor.
The Producer is the economic operator that first places packaging or a packaged product on the market within a specific EU Member State. As a result, the same packaged product may have different Producers if it is introduced into multiple EU countries.
The Distributor, by contrast, is responsible solely for making the product available on the market or transferring it within the supply chain, without modifying its characteristics or compliance status.
The complexity of the PPWR lies in the fact that these roles may overlap depending on the market in which a company operates. For example, a business selling products within its domestic market may act as the Producer, while the same company exporting those products to another EU Member State may assume the role of Distributor.
This flexible allocation of responsibilities requires companies to carefully assess their operations, as the PPWR assigns specific legal obligations to each economic operator. Correctly identifying each role is therefore a fundamental prerequisite for achieving compliance with the new European packaging legislation.
Within this framework, documentation and regulatory compliance become one of the most critical aspects of the new Regulation.
Documents to Prepare by August 2026
Manufacturers placing packaged products on the market under their own name or brand will be required to prepare the following documentation:
• The EU Declaration of Conformity in accordance with Regulation (EU) 2025/40 (PPWR);
• Supporting technical documentation provided by the relevant Supplier(s);
• Registration with the applicable Extended Producer Responsibility (EPR) schemes;
• Certifications relating to PFAS, heavy metals, and Substances of Very High Concern (SVHCs).
Cartonpack Group supports its customers by providing the technical documentation and material certifications required to complete the Manufacturer's EU Declaration of Conformity, helping businesses meet the documentation requirements of the PPWR.
Is Your Packaging PPWR Ready?
Want to find out whether your packaging already complies with the new PPWR requirements? Contact our team for a tailored compliance assessment.
Harmonised Packaging Labelling: What Changes from 2028?
The PPWR introduces harmonised packaging labels featuring standardised pictograms that identify packaging materials and provide clear disposal instructions. The aim is to improve waste sorting, enhance consumer understanding and ensure that labelling is accessible, including for people with disabilities.
Once the harmonised labelling system becomes mandatory, national labelling schemes will no longer be permitted alongside the EU harmonised label. In addition, environmental claims will only be allowed where they refer to environmental performance that goes beyond the minimum legal requirements established by the Regulation.
The PPWR also establishes a clear implementation timeline. The adoption of the necessary implementing acts is scheduled by 12 August 2026, while the harmonised labelling requirements will become fully applicable from 12 August 2028, exactly 24 months after the implementing legislation enters into force.
How to Prepare: The PPWR Ready Approach
Companies looking to stay ahead of upcoming regulatory deadlines should begin implementing a structured compliance strategy without delay.
Through a comprehensive multi-material approach that includes thermoformed plastics, flexible films, paper, cardboard and moulded fibre packaging, Cartonpack Group helps food manufacturers, agri-food businesses and large-scale retailers transition to packaging solutions that comply with the PPWR.
Our packaging portfolio is built around four key pillars:
• Mono-material design for improved recyclability;
• Increased use of recycled materials;
• Innovative paper-plastic hybrid solutions;
• Moulded fibre packaging designed for circularity.
This offering is further strengthened by the innovation developed by Smilesys, whose flexible films made with ISCC PLUS® certified materials help significantly reduce environmental impact while maintaining high performance standards.
Cartonpack Group Is PPWR Ready
Discover our innovative multi-material packaging solutions and prepare your business to confidently meet the challenges of the new European Packaging and Packaging Waste Regulation.