EU PPWR REGULATORY GUIDANCE
On June 5, 2026, the European Commission published its final guidance on Regulation (EU) 2025/40. Together with the Commission's PPWR FAQs, the guidance clarifies packaging scope, economic-operator roles, PFAS restrictions for food-contact packaging, recyclability, recycled-content exemptions, minimisation and implementation timelines. Companies preparing for the Regulation's general application on August 12, 2026 can use these clarifications to prioritise their EU PPWR packaging compliance work.
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EU PPWR Guidance at a Glance
| Issue | Commission Clarification | Business Priority |
|---|---|---|
| Guidance status | The final Commission Notice was published on June 5, 2026. It interprets selected PPWR provisions but does not replace or amend the Regulation. | Read the guidance together with Regulation (EU) 2025/40 and subsequent implementing measures. |
| General application | August 12, 2026, unless a provision specifies another date. | Map packaging, market routes and economic-operator roles before the application date. |
| Food-contact PFAS | PFAS limits apply from August 12, 2026, with no stock-exhaustion transition for packaging placed on the market after that date. | Prioritise high-risk food-contact packaging, testing strategy and supplier evidence. |
| Recyclability | All packaging placed on the market must be recyclable from August 12, 2026; harmonised design-for-recycling criteria apply later. | Review current compliance and create a redesign roadmap for the 2030 framework. |
| Recycled content | Specified exemptions apply directly, but manufacturers must substantiate them in the technical documentation. | Document material shares, polymers, intended use and the basis for any exemption. |
| Minimisation & empty space | Marketing alone will not justify extra packaging. A 50% empty-space cap applies to grouped, transport and e-commerce packaging from the applicable Article 24 date. | Collect design evidence and monitor the calculation methodology due before February 12, 2028. |
What Is the Status of the EU PPWR Guidance and FAQs?
The European Commission approved a draft Commission Notice and released its PPWR Frequently Asked Questions on March 30, 2026. The final Commission guidance document, C(2026) 3702, followed on June 5, 2026. The PPWR replaces the 30-year-old Packaging and Packaging Waste Directive and creates a more harmonised framework for packaging and packaging waste across the EU.
The guidance does not replace, add to or amend the PPWR. Regulation (EU) 2025/40 remains the legal basis, and the binding interpretation of EU law remains within the competence of the Court of Justice of the European Union. The Commission may update the guidance and FAQs as implementation experience develops.
How the EU PPWR Guidance Clarifies Packaging Scope and Operator Roles
What counts as packaging?
Whether an item is packaging must be assessed against the definition in Article 3(1) of the Packaging and Packaging Waste Regulation. The item must be used by an economic operator to contain, protect, handle, deliver or present a product without being an integral part of that product, or must be an integrated component or ancillary element that performs a packaging function.
Not packaging: IV bags and syringes that function as integral delivery devices; empty beverage cups sold to consumers for private use; garbage bags and dog-waste bags.
Packaging: beverage cups filled at the point of sale; textile dust bags used for the transport or presentation of shoes or garments; flower and plant pots used only for sale and transport.
Context-dependent: flowerpots and seed trays used throughout a nursery production cycle are generally not packaging, while the final pot intended for sale or transport may be.
Manufacturer, producer and importer are different PPWR roles
| Role | How the Guidance Interprets the Role | Main Compliance Focus |
|---|---|---|
| Manufacturer | A natural or legal person that manufactures packaging or a packaged product. This is not necessarily the entity that physically produces the empty packaging. Branding, control over design specifications and final processing may determine the role. There is only one manufacturer in the supply chain for PPWR purposes. | Sustainability and labelling requirements, conformity assessment, technical documentation and the EU Declaration of Conformity. A limited micro-enterprise rule may shift the role to the packaging supplier in the same Member State. |
| Producer | The manufacturer, importer or distributor that first makes packaging or packaged products available in a Member State, or supplies them directly to end users in another Member State. The producer may differ from one Member State to another. | Extended Producer Responsibility, registration, reporting, waste-management financing and related fees. |
| Importer | A natural or legal person established in the EU that places packaging from a third country on the market. A branch without separate legal personality cannot qualify as the importer. | Non-EU companies should confirm whether an EU subsidiary, an EU importer or an authorised representative for EPR purposes is needed, depending on the supply chain and Member State rules. |
Role mapping should be completed before preparing a packaging technical file or Declaration of Compliance, because the responsible entity and the applicable EPR obligations depend on the actual market route.
PFAS Restrictions for Food-Contact Packaging from August 2026
From August 12, 2026, food-contact packaging may not be placed on the EU market if it contains PFAS at or above the PPWR limit values, unless another EU legal act already prohibits the relevant concentration. The restriction covers packaging intended to come into contact with food or already in contact with food for that purpose.
| PPWR Limit | Measurement Basis | Polymeric PFAS |
|---|---|---|
| 25 ppb (25 µg/kg) | Any individual PFAS measured using targeted PFAS analysis | Excluded from quantification |
| 250 ppb (250 µg/kg) | Sum of PFAS measured using targeted analysis, with prior degradation of precursors where applicable | Excluded from quantification |
| 50 ppm (50 mg/kg) | PFAS, including polymeric PFAS | Included |
Commission-recommended stepwise testing approach
Total fluorine screening: if total fluorine is below 50 mg/kg, the sample could be considered compliant.
Organic versus inorganic fluorine: if total fluorine exceeds 50 mg/kg, a method such as pyrolysis-GC/MS can help determine whether the fluorine is organic or inorganic. If organic fluorine is below 50 mg/kg, the sample could be considered compliant.
Targeted and precursor analysis: direct total oxidisable precursor analysis is recommended to check compliance with the 25 µg/kg and 250 µg/kg limits.
There is no transition period for exhausting non-compliant stock. Packaging placed on the market before August 12, 2026 may remain on the market, but food-contact packaging placed on the market from that date must comply. The guidance also confirms that packaging containing recycled material does not receive a PFAS exemption.
When Do PPWR Recyclability and Design-for-Recycling Rules Apply?
Article 6(1), requiring all packaging placed on the market to be recyclable, applies from August 12, 2026. The detailed design-for-recycling assessment under Article 6(2)(a) applies from January 1, 2030 or 24 months after the relevant delegated act enters into force, whichever is later.
Until the detailed criteria apply: manufacturers must comply with the recyclability requirement in accordance with the former Packaging and Packaging Waste Directive framework and harmonised standard EN 13430:2004.
Delegated act: the Commission is expected to adopt the act establishing harmonised design-for-recycling criteria and methodology by January 1, 2028.
Conformity assessment timing: manufacturers do not need to perform the Article 38 and Annex VII conformity assessment for recyclability until the relevant Article 6(4) delegated act enters into force.
Later milestone: the recycled-at-scale requirement applies from 2035 or five years after the relevant implementing acts enter into force, whichever is later.
Stricter 2038 threshold: from January 1, 2038, packaging must meet recyclability performance grade A or B; grade C will no longer be sufficient for placing packaging on the market.
Companies should therefore distinguish the August 2026 baseline recyclability obligation from the later harmonised design-for-recycling performance grades and recycled-at-scale assessment.
Recycled Content, Packaging Minimisation and Empty-Space Rules
Recycled-content exemptions require evidence
The guidance confirms direct exemptions from the plastic-packaging recycled-content obligations for:
plastic packaging intended to contact food where the recycled content would threaten human health and result in non-compliance with Regulation (EC) No 1935/2004; and
any plastic part representing less than 5% of the total weight of the whole packaging unit.
These exemptions do not require individual approval, but they must be substantiated in the technical documentation. For the food-contact exemption, the manufacturer should document the relevant polymer, intended use and lack of a suitable authorised and industrially available recycling technology. By January 1, 2028, the Commission will assess whether further exemptions or revisions are needed.
Packaging minimisation and the 50% empty-space cap
Existing packaging-minimisation requirements and EN 13428:2004 remain relevant through the end of 2029. From January 1, 2030, manufacturers and importers must ensure that packaging weight and volume are reduced to the minimum necessary for functionality. Marketing and consumer acceptance alone will no longer justify additional packaging weight or volume.
For sales packaging, there is no fixed empty-space percentage; the assessment follows the applicable minimisation methodology, and manufacturers should retain supporting technical documentation. For grouped, transport and e-commerce packaging, the maximum empty-space ratio is 50% from January 1, 2030 or three years after the relevant implementing acts enter into force, whichever is later. The Commission is to adopt the calculation methodology before February 12, 2028.
Other PPWR Guidance Points Companies Should Track
Compostability: Member States may decide by August 12, 2026 whether specified additional packaging formats must be industrially compostable on their territory. Permeable tea and coffee bags and soft after-use beverage-system units must be designed for composting by February 12, 2028.
Annex V packaging bans: composite packaging, including paper-based packaging containing 5% or more plastic, falls within the relevant bans, while packaging containing not more than 5% plastic is outside those bans.
Reusable packaging: reusable packaging placed on the market before February 11, 2025 does not need to be brought into compliance retroactively. Packaging placed on the market after that date must meet the applicable criteria, with enforcement under the PPWR available after August 12, 2026.
Harmonised labelling: material-composition labels generally apply from August 12, 2028 or 24 months after the relevant implementing acts enter into force, whichever is later. National sorting labels cannot continue alongside the harmonised EU system after the applicable transition.
Deposit and return systems: Member States must work toward the 90% separate-collection target for specified single-use plastic beverage bottles and metal beverage containers by January 1, 2029, subject to the PPWR exemption route.
Practical PPWR Compliance Actions Before August 12, 2026
Build a packaging inventory: list sales, grouped, transport, service and e-commerce packaging by material, component, supplier, weight and intended use.
Map market routes and roles: identify the manufacturer, importer and producer for each route and Member State instead of assuming one entity holds every responsibility.
Prioritise food-contact PFAS: review coatings, inks, adhesives, moulded fibre, grease-resistant papers and other higher-risk formats; then define testing and supplier-data needs.
Check stock timing: distinguish packaging already placed on the market from inventory that will be placed on the market on or after August 12, 2026.
Prepare documentation: collect specifications, supplier declarations, test reports, exemption evidence, conformity-assessment records and draft EU Declarations of Conformity where required.
Plan for later milestones: create a roadmap for design for recycling, recycled content, minimisation, labelling, re-use and EPR while monitoring delegated acts, implementing acts, standards and FAQ updates.
How REACH24H Can Support EU PPWR Compliance
REACH24H's EU PPWR Packaging Compliance Services help manufacturers, brand owners, importers, packaging suppliers and e-commerce sellers move from regulatory interpretation to packaging-specific implementation.
Scope and role assessment: classify packaging and map manufacturer, importer, producer and EPR responsibilities.
Data-gap and testing strategy: review material composition, supplier evidence, PFAS and heavy-metal risks, and testing needs.
Recyclability and packaging-design review: assess material combinations, coatings, labels, adhesives, inks, colours and future redesign priorities.
Technical documentation and EU DoC: support document compilation, conformity evidence and declaration preparation.
EPR coordination and regulatory monitoring: align Member State obligations and track secondary legislation, standards and official guidance.
EU PPWR Guidance FAQ
Need to assess your packaging before the PPWR application date?
Submit your packaging list for an initial review of scope, operator roles, PFAS and testing needs, recyclability, supplier-data gaps, technical documentation and EPR priorities.
Recommended Reading
Northern Ireland to Apply EU PPWR: What Businesses Need to Know
Understanding the EU Declaration of Compliance for Food Contact Materials
EU Proposes Amendments to Regulation (EU) 2022/1616 on Recycled Plastic Food Contact Materials
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