PPWR: The EU's New Packaging Regulation Officially Takes Effect

From 12 August 2026, the EU's Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) officially applies across the EU, directly affecting any company exporting packaged goods to Europe, particularly in the food, beverage, cosmetics, and consumer goods sectors. 

Overview of PPWR 

PPWR establishes a unified legal framework for packaging and packaging waste across the European Union, replacing the fragmented rules previously set by individual member states. The regulation has been legally in force since February 2025, but its specific provisions apply on a phased timeline starting from 12 August 2026. 

The regulation was introduced against a backdrop where packaging waste in the EU is projected to grow by 19% by 2030 without intervention, with plastic packaging waste alone potentially increasing by up to 46%. 

PFAS Restrictions in Food-Contact Packaging 

The most notable provision as PPWR begins applying from 12 August 2026 is the restriction on PFAS (per- and polyfluoroalkyl substances, commonly known as "forever chemicals") in packaging that comes into direct contact with food. These are highly persistent chemicals that tend to accumulate in the environment and the human body, commonly used for their water- and grease-resistant properties in packaging such as takeaway food containers, fast-food wrapping paper, microwave popcorn bags, baking paper, and pizza boxes. 

Under Article 5(5) of PPWR, from 12 August 2026, food-contact packaging cannot be placed on the EU market if it contains PFAS at or above: 

• 25 parts per billion (ppb) for any individual PFAS substance (targeted analysis, excluding polymeric PFAS) 

• 250 ppb for the sum of PFAS substances (targeted analysis, excluding polymeric PFAS) 

• 50 parts per million (ppm) for total PFAS, including polymeric PFAS 

The European Commission's recommended testing approach follows a stepwise process: first, measure total fluorine content. If it falls below 50 mg/kg, the packaging is considered compliant with no further testing required. If it exceeds this threshold, companies need to determine whether the fluorine originates from PFAS using more detailed methods such as pyrolysis-GC/MS. 

One important point to note: this regulation includes no transition period for existing inventory. Packaging manufactured before 12 August 2026 that exceeds the PFAS limits is still restricted from being placed on the market from that date onward, regardless of when it was produced. 

Beyond PFAS, PPWR also maintains the pre-existing heavy metals limit (lead, cadmium, mercury, and hexavalent chromium combined must not exceed 100 mg/kg), applying to all packaging types from 12 August 2026, not just food packaging. 

Upcoming Milestones 

PPWR follows a phased implementation timeline, with companies needing to plan for the following milestones: 

• From 2028: a unified EU-wide packaging labelling system will apply, improving waste sorting efficiency and expected to save the packaging industry billions of Euros over the long term. 

• From 2030: specific measures to reduce packaging waste generation take effect, including limits on empty space within packaging, restrictions on certain single-use plastic packaging, reuse targets, mandatory recycled plastic content in new plastic packaging, and a requirement that all packaging be recyclable. 

Why Non-EU Companies Are Also in Scope 

PPWR is not limited to companies headquartered in the EU. Any company selling packaged goods directly to EU consumers, whether through its own website, an e-commerce marketplace, or an EU-based distributor, falls within scope. The regulation also requires non-EU manufacturers selling directly to EU consumers to appoint an Extended Producer Responsibility (EPR) Authorized Representative in each member state where the packaging is first placed on the market. 

For companies in Vietnam, Singapore, or Malaysia exporting packaged food, beverages, or consumer goods to the EU, whether directly or through distributors, this is a regulation to review immediately, particularly where packaging uses coated paper, grease-resistant paper containers, or plastic film that may contain PFAS. 

What Should Exporters Do Now? 

• Immediately review the food-contact packaging portfolio being exported to the EU, particularly coated paper packaging and grease-resistant containers that may contain PFAS. 

• Request test documentation from packaging suppliers (Certificates of Analysis from accredited laboratories), since supplier self-declarations alone are not sufficient proof of compliance. 

• Check existing inventory, as there is no grace period for packaging manufactured before the effective date. 

• Monitor the 2028 (labelling) and 2030 (recycling, reuse) milestones to prepare early for upcoming requirements and avoid compressing compliance costs into the final stretch. 

• If selling directly to EU consumers, verify whether an EPR Authorized Representative has been appointed in the relevant member states. 

  

PPWR is a clear illustration of the EU tightening technical barriers across multiple fronts simultaneously, extending beyond carbon emissions (CBAM) or deforestation-free supply chains (EUDR) into packaging materials as well. Companies exporting to the EU should treat this as part of a broader compliance landscape, rather than addressing each regulation in isolation.