PPWR for food packaging: what the EU Packaging and Packaging Waste Regulation means for your business

The PPWR is an EU Regulation. It entered into force on 11 February 2025 and generally applies from 12 August 2026; some obligations have later application dates.

Its objectives include reducing packaging waste and supporting circular packaging systems. The applicable obligations depend on the packaging type, the economic operator's role and the relevant date.

Who places a packaging unit on the market, and when, depends on the packaging type and supply-chain facts. The Commission FAQ addresses different situations involving packaging format, final form and supply arrangements. Where that determination affects compliance, obtain case-specific legal advice.

Packaging must not exceed a combined total concentration of 100 mg/kg of lead, cadmium, mercury and hexavalent chromium.

Article 5(5) sets maximum PFAS concentration limits for food-contact packaging:

• 25 ppb for any individual PFAS, measured using targeted PFAS analysis.
• 250 ppb for the sum of PFAS, measured using targeted analysis.
• 50 mg/kg for total PFAS, including polymeric PFAS.

The Commission FAQ states that these limits apply to the packaging unit as a whole, including associated inks, varnishes, glues and adhesives placed on the market by the manufacturer, and do not distinguish between intentionally added and unintentionally present PFAS. Packaging at or above an applicable limit must not be placed on the EU market from 12 August 2026.

The manufacturer must carry out the applicable conformity assessment under Article 38 and prepare the EU declaration of conformity under Article 39. Annex VII sets the technical-documentation requirements. The applicable retention period is generally five years for single-use packaging and ten years for reusable packaging.

The manufacturer remains responsible for the packaging it places on the market. For imported packaging, Article 18 requires the importer to verify, among other things, that the non-EU manufacturer carried out the conformity assessment and drew up the EU declaration of conformity.

Further requirements have separate application dates, including:

• Recyclability (Article 6): requirements start from 2030, subject to the Regulation's terms and exceptions.
• Minimum recycled content (Article 7): requirements for plastic packaging components start on the dates specified in the Regulation.
• Packaging minimisation (Articles 10 and 24): obligations apply from 2030.
• Reuse, refill and labelling: these requirements are phased in under the relevant Articles.
• Restrictions on certain formats (Article 25): specified restrictions begin from 2030.

Check the operative provision and date for each packaging format rather than treating the PPWR as one single deadline.

For food businesses, useful diligence questions include:

• What is the packaging structure and intended use?
• What supplier evidence supports compliance with the applicable Article 5 requirements?
• Have associated coatings, inks, varnishes, glues and adhesives been included in the manufacturer’s assessment?
• Which operator is the manufacturer, and is an importer involved?
• What documentation is available for review?

Evidence should be kept current when the packaging, materials, formulation or supply chain changes.

As a food-service packaging procurement coordinator working with multiple manufacturers, TakeawayPack can help buyers request, organise and compare packaging information. TakeawayPack works across cups, bowls, boxes, containers, trays, lids, bags and cutlery.

TakeawayPack can help with material, structure and coating information; requests for manufacturer documentation and test reports; and coordination of samples, drawings and records. It cannot certify compliance or issue an EU declaration of conformity on a manufacturer’s behalf.