Introdcution
On February 10, 2026, the UK government issued guidance reminding businesses to pay close attention to the applicability of the PPWR in Northern Ireland. Companies placing products on the EU and Northern Ireland markets should understand the core technical requirements of the PPWR.
What Is the EU Packaging and Packaging Waste Regulation (EU PPWR)?
In recent years, the European Union has strengthened its regulatory framework on packaging and packaging waste to promote the circular economy and improve resource efficiency. On January 22, 2025, the European Union officially adopted the Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40). The Regulation entered into force on February 11, 2025, and will apply from August 12, 2026 (with certain provisions subject to specific timelines). It repeals and fully replaces the existing Packaging and Packaging Waste Directive (94/62/EC), becoming the core legislative framework for packaging and packaging waste management in the EU.
Following Brexit, the UK operates a “dual-track” regulatory system for packaging:
Northern Ireland (NI): Under the Windsor Framework, Northern Ireland continues to align with certain EU Single Market rules for goods. Therefore, with the transition from the PPWD to the PPWR, the new Regulation will also apply in Northern Ireland.
Great Britain (GB): England, Scotland, and Wales follow domestic UK packaging regulations, including existing The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 and the evolving Extended Producer Responsibility (EPR) system.
Key Technical Requirements under the PPWR (Regulation (EU) 2025/40)
The PPWR introduces more comprehensive and stringent requirements on packaging, covering hazardous substances, material use, recyclability, and design. Key aspects include:
Substances of Concern: Restrictions on Heavy Metals and PFAS
Heavy metals: Consistent with the requirements of Directive 94/62/EC, this provision entered into force on February 11, 2025. The sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg. In addition, products within the scope of the Regulation must continue to comply with the requirements set out in Annex XVII to Regulation (EC) No. 1907/2006 (REACH) or Regulation (EC) No. 1935/2004 on food-contact materials and articles (FCM).
New restrictions on PFAS in food-contact packaging: The use of per- and polyfluorinated alkyl substances (PFAS) in food-contact packaging is restricted. From August 12, 2026, the following limits apply:
1. Individual PFAS: < 25 ppb
2. Total PFAS (excluding polymeric PFAS): < 250 ppb
3. Total PFAS (including polymeric PFAS): < 50 ppm
If total fluorine exceeds 50 ppm, additional evidence must be provided to demonstrate whether PFAS are present.
Recyclability Requirements
The PPWR establishes the principle of “Design for Recycling” and introduces phased recyclability targets:
From January 1, 2030: only packaging with recyclability performance grade C or higher may be placed on the market;
From January 1, 2038: the requirement will increase to grade B or higher.
The European Commission is expected to adopt delegated acts by January 1, 2028, to define recycling criteria and recyclability performance grading methodologies.
Recycled Content Requirements for Plastic Packaging
By January 1, 2030, any plastic part of packaging placed on the market shall contain recycled content recovered from post-consumer plastic waste (PCR). Specific targets will vary by packaging type and are expected to increase over time.
The European Commission will adopt implementing acts establishing the methodology for the calculation and verification of the percentage of recycled content recovered from post-consumer plastic wasted recycled by December 31, 2026.
Packaging Reduction and Reuse Requirements
The PPWR emphasizes minimizing unnecessary packaging. Companies are required to avoid over-packaging through optimized design and material use. In addition, reuse systems for certain product categories will be progressively promoted to reduce packaging waste.
Labelling and Information Requirements
To improve waste sorting and recycling efficiency, the PPWR plans to introduce a harmonized labelling system. Packaging may be required to provide clear information on material composition and recycling instructions, facilitating consumer participation and improving cross-border consistency in recycling systems.
Compliance Recommendations from REACH24H
As the PPWR enters into force, the EU packaging regulatory framework will become more stringent and harmonized. Given that Northern Ireland continues to align with certain EU Single Market rules for goods under the Windsor Framework, the PPWR will also apply to that market.
REACH24H Consulting Group recommends that companies exporting consumer goods and packaging to the EU and Northern Ireland take early compliance actions, including:
Preparing relevant test reports (e.g., heavy metals content testing);
Conducting PFAS and total fluorine (F) testing, where applicable;
Preparing a Declaration of Conformity (DoC) and complete technical documentation;
Registering in the national registers of EU Member States where products are placed on the market (where registration systems are available).
REACH24H will continue to monitor developments in PPWR implementing measures and supporting legislation in the EU and Northern Ireland, and provide professional regulatory interpretation and compliance support to businesses.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
