EU PPWR REGULATORY UPDATE | ARTICLE 5 SUBSTANCES OF CONCERN
In July 2026, the PPWR team at the European Chemicals Agency (ECHA) circulated a draft working list of approximately 700 substances of concern (SoCs) identified in packaging or packaging waste. Stakeholders were invited to confirm how these substances are used in packaging and to submit feedback by 24 August 2026.
The central point for companies is that inclusion in this research list does not, by itself, create a new restriction, testing requirement or remediation deadline. However, the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, generally applies from 12 August 2026, and the existing requirements under Article 5 remain applicable. Businesses should therefore distinguish the draft research exercise from the obligations that already apply to their packaging.
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How Was the Draft PPWR SoC List Developed?
According to ECHA's stakeholder communication, the study initially collected information on approximately 6,000 substances associated with packaging or packaging waste. Sources included REACH registration data, existing regulatory and industry lists, scientific literature, research projects, reports and information provided by stakeholders.
After validating the available evidence, around 2,500 substances were considered to have packaging-use information supported by multiple data points or sources. These substances were then screened against the definition of a substance of concern in the Ecodesign for Sustainable Products Regulation (ESPR), which is also used by the PPWR.
The screening considered two broad dimensions:
Chemical safety: whether a substance meets relevant criteria, including Substances of Very High Concern (SVHC) status, certain harmonised classifications for chronic effects or listing under the EU Persistent Organic Pollutants Regulation.
Re-use and recycling: whether a substance may negatively affect the re-use or recycling of packaging materials.
This process resulted in the draft identification of around 700 SoCs, which remains a research-stage working list intended to support data validation and the preparation of the European Commission's report.
Does the Draft List Create 700 New Restrictions or Testing Requirements?
No. The draft list is not a PPWR prohibited-substance list, a final restriction list or a standard panel of approximately 700 tests.
ECHA's communication states that identifying a substance as an SoC for this study does not automatically create a regulatory obligation. Even if a substance is considered during preliminary screening for possible future risk-management measures, that does not mean the EU has decided to restrict it.
Any future restriction or other measure would require further assessment of the relevant hazard, exposure, emissions and risk. Potential follow-up routes could include a restriction under EU REACH for substances that primarily affect human health or the environment, or consideration under PPWR design-for-recycling criteria where a substance negatively affects re-use or recycling.
At the same time, companies should not interpret the absence of new obligations from this draft as an exemption from current PPWR requirements. Article 5(1) requires packaging placed on the EU market to be manufactured so that the presence and concentration of SoCs in packaging materials and components are minimised. Existing requirements concerning heavy metals and, where applicable, PFAS in food-contact packaging should also be assessed separately.
What Information Is ECHA Seeking from Industry?
The present exercise is primarily intended to confirm whether the available packaging-use information is accurate. ECHA is seeking feedback on whether a substance is currently used in packaging; whether it is intentionally added or occurs as a non-intentionally added substance (NIAS); what material, type or format in which it is used in; and what technical function it performs.
The underlying information covers a broad range of packaging materials, including plastics, paper and board, metals, glass and wood. The scope also extends beyond the main packaging substrate to inks, printing compounds, adhesives, coatings, plasticisers, antioxidants and other additives.
What Does the 24 August 2026 Deadline Mean for Companies?
The 24 August 2026 deadline marked the end of ECHA's stakeholder-feedback period for validating the draft data. Its passing does not create a new compliance deadline or require companies to complete a full screening of approximately 700 substances.
For companies placing packaged products on the EU market, the focus should now be on understanding whether the substances and uses identified in the draft list are relevant to their own packaging portfolio. The draft list alone should not be used to justify blanket testing across approximately 700 substances. Any testing or documentation strategy should instead be based on the applicable legal requirements, packaging material, intended use, available supplier evidence and identified risk.
What Should Companies Do Now?
Build or update the packaging inventory: Identify packaging components, materials, suppliers, EU markets, intended uses and food-contact status.
Review supplier-data availability: Determine whether material specifications, substance declarations, composition information and existing test reports can be obtained for relevant packaging components.
Separate binding requirements from research-stage developments: Continue addressing applicable PPWR, REACH, POPs and food-contact requirements while monitoring how the SoC study may influence future measures.
Use a risk-based evidence strategy: Do not treat the draft list as a universal testing panel. Prioritise evidence according to material type, substance function, regulatory status and gaps in the supply chain.
Monitor the next regulatory steps: Track ECHA's study report and any subsequent Commission proposals, guidance, restrictions or design-for-recycling measures.
What Happens Next?
ECHA has indicated that it plans to submit its study report to the European Commission by 21 September 2026. Separately, Article 5(2) of the PPWR requires the Commission, assisted by ECHA, to prepare its report on SoCs in packaging and packaging components by 31 December 2026.
The Commission report may list SoCs present in packaging and indicate the extent to which they could negatively affect re-use or recycling or present an unacceptable risk to human health or the environment. The substances ultimately prioritised, the regulatory route selected and the corresponding obligations will depend on subsequent assessments and formal EU measures.
How REACH24H Can Support PPWR Compliance
REACH24H supports manufacturers, brand owners, importers and packaging suppliers with EU PPWR packaging compliance, including:
Applicability and responsibility assessment;
Packaging and supplier data-gap review;
Testing strategy and technical documentation support; and
Ongoing regulatory tracking.
Companies preparing for PPWR should focus on a proportionate compliance pathway built around their actual packaging portfolio, supply-chain role and available evidence. REACH24H can help identify priority data gaps and translate evolving PPWR requirements into a practical preparation plan.
Not sure which PPWR obligations apply to your packaging portfolio or whether your current supplier evidence is sufficient?
REACH24H can help assess applicable responsibilities, identify evidence gaps and develop a proportionate testing and documentation strategy based on your packaging materials, intended uses and EU market routes.
Recommended Reading
EU PPWR Guidance 2026: Key Compliance Requirements and Timelines
PPWR Traceability and Enforcement: What the August 2026 FAQ Means for Packaging Operators
EU PPWR Now Applies: How to Handle Existing Stock, Goods in Transit and Pre-Produced Packaging
