EU PPWR: what's actually binding from 12 August 2026
PPWR's general application date has passed. Regulation (EU) 2025/40 entered into force on 11 February 2025 and applied generally from 12 August 2026, the same date it repealed the Packaging and Packaging Waste Directive (94/62/EC) that had governed EU packaging rules since 1994. That headline fact obscures the more useful operational question: what, specifically, changed for an exporter's packaging on 12 August, versus what is still years away.
Key facts
- Scope: All packaging placed on the EU market, any material, B2B and B2C — food-contact packaging specifically for the PFAS limit; produce, seafood and meat export packaging into the EU is squarely in scope.
- Regulation (EU) 2025/40 (PPWR) applied generally from 12 August 2026, the same day it repealed the 1994 Packaging and Packaging Waste Directive (94/62/EC).
- The one major new, quantified obligation that binds immediately: food-contact packaging must sit under PFAS concentration limits — 25 µg/kg for any single substance, 250 µg/kg summed, 50 mg/kg total, regardless of whether the PFAS was intentionally added.
- Most of PPWR's headline requirements — recyclability grading, reuse targets, recycled-content mandates — do not apply yet; they phase in on a schedule running from early 2027 (HORECA refill) through 2040, with most (recyclability, reuse, recycled content) not starting until 2030.
What actually binds today
The major new obligation that took effect on 12 August 2026 is a substance restriction, not a design or labelling requirement: Article 5(5) caps per- and polyfluoroalkyl substances (PFAS) in food-contact packaging at 25 µg/kg for any individual PFAS by targeted analysis, 250 µg/kg for the sum of targeted PFAS, and 50 mg/kg for total PFAS including polymeric forms. The restriction applies to the packaging's actual PFAS content regardless of whether it was intentionally added — a coating, adhesive or ink that introduces PFAS as a byproduct is caught the same as deliberate use. Manufacturers must keep technical documentation proving compliance for five years on single-use packaging and ten years on reusable packaging (Article 15(3)). Two older restrictions carried over from the repealed Directive also apply from the same date without a deferred schedule — a heavy-metals cap (lead, cadmium, mercury, hexavalent chromium combined) and a ban on packaging designed only to appear larger than its contents (Article 10(2)) — but neither is new; PFAS is the only genuinely new, quantified requirement live today.
Everything else most coverage associates with PPWR — recyclability performance grading (A/B/C), reuse targets for transport and beverage packaging, recycled-content minimums in plastic packaging, deposit-return systems, and QR-code-based extended producer responsibility labelling — is not binding yet. Those obligations phase in on a schedule running from early 2027 (HORECA refill systems) through 2040, with most of the headline requirements — recyclability grading, reuse targets, recycled-content minimums — not starting until 1 January 2030, and the Commission is still finalising implementing detail on several of them. Treat any claim that your packaging must already meet a specific recyclability grade or reuse target as premature.
What to do
- 1.If you ship food-contact packaging into the EU, confirm your packaging's PFAS content sits under Article 5(5)'s thresholds — this is the one major new, quantified obligation that binds today, not on a future phase-in date.
- 2.Retain technical documentation demonstrating PFAS compliance: 5 years for single-use packaging, 10 years for reusable packaging, per Article 15(3) (mirrored for importers and distributors).
- 3.Do not assume the 1994 Packaging Directive still governs your packaging design — it was repealed on 12 August 2026, though some of its provisions continue to apply during the transition.
- 4.Treat 2027-2030 requirements (EPR digital labelling, HORECA refill systems, compostable-packaging standards, recycled-content mandates, recyclability grading) as planning targets, not immediate obligations — verify each date against the specific article that sets it (Article 6 recyclability, Article 7 recycled content, Article 9 compostable, Article 12 labelling, Article 32 refill) rather than assuming a single consolidated schedule, since PPWR's implementing detail is still being finalised by the Commission.