PPWR Compliance: What Food & Beverage Brands Must Do Before August 2026
The EU's Packaging and Packaging Waste Regulation introduces binding requirements for every brand selling packaged products in Europe. Some apply from 12 August 2026 — less than four months away.
Deadline: 12 August 2026. Packaging placed on the EU market after this date must comply with PFAS restrictions and be accompanied by a Declaration of Conformity — even if manufactured before that date.
What is the PPWR?
The Packaging and Packaging Waste Regulation — formally Regulation (EU) 2025/40 — entered into force in February 2025. It replaces the previous EU Packaging Directive and sets legally binding rules on packaging design, composition, labelling, and end-of-life management.
Unlike a directive, the PPWR applies directly across all EU member states without transposition into national law. The same requirements apply simultaneously in Germany, France, Italy, Spain, and every other EU market.
For food and beverage brands, the regulation affects every SKU sold in EU markets — from primary food-contact packaging to outer cartons and transport packaging.
What applies from 12 August 2026
Three sets of requirements take effect on the PPWR's initial application date. All packaging placed on the EU market must comply from this date — including packaging manufactured before 12 August 2026.
PFAS restrictions on food-contact packaging
All food-contact packaging placed on the EU market after 12 August 2026 must comply with PFAS concentration limits under Article 5. This effectively bans PFAS-based coatings — widely used in greaseproof paper, pizza boxes, baking trays, microwave packaging, and food wrappers.
PFAS concentration limits (Article 5):
| PFAS measure | Maximum limit |
|---|---|
| Any individual PFAS (targeted analysis) | ≤ 25 ppb |
| Sum of all targeted PFAS | ≤ 250 ppb |
| Total PFAS including polymeric PFAS | ≤ 50 ppm |
Compliance requires testing and documented evidence from packaging suppliers. If current packaging uses PFAS-based grease barriers or non-stick coatings, reformulation or supplier switching may be needed before August.
EU Declaration of Conformity
From 12 August 2026, every type of packaging on the EU market must be accompanied by a legally binding Declaration of Conformity confirming compliance with PPWR Articles 5–12. The obligation sits with whoever places the branded packaging on the market. Technical documentation must be retained for 5 years (single-use) or 10 years (reusable).
Heavy metal concentration limits
The existing restrictions on lead, cadmium, mercury, and hexavalent chromium in packaging are maintained, with a combined ceiling of 100 mg/kg across all four metals in any packaging component.
Beyond August 2026: the full compliance roadmap
PPWR compliance is a multi-year programme. The August 2026 requirements are the first wave — further obligations follow through 2030 and beyond.
| Deadline | Requirement |
|---|---|
| August 2026 | PFAS ban in food-contact packaging; Declaration of Conformity required; heavy metal limits maintained |
| January 2028 | EPR delegated act adopted — framework for recyclability-based fee modulation established |
| July 2029 | EPR fees modulated by recyclability grade; producers must register and report packaging volumes in each EU market |
| January 2030 | All packaging must meet Grade C recyclability minimum (≥70%); minimum recycled plastic content thresholds apply |
| January 2038 | Only Grade A (≥95%) or Grade B (≥80%) recyclability permitted on the EU market |
Recyclability grading under Annex II:
From January 2030, packaging below Grade C cannot be sold in the EU. From 2038, only Grade A and B is permitted.
Why PPWR compliance is harder than it looks
For most food and beverage companies, PPWR compliance is not a single decision — it is a portfolio-wide exercise. A typical brand selling across EU markets needs to:
- ✓Audit the packaging composition of every product line for PFAS and heavy metal compliance
- ✓Verify supplier documentation and PFAS testing results for all food-contact materials
- ✓Prepare and sign Declarations of Conformity for each packaging type across each market
- ✓Register with EPR schemes in every EU member state where products are sold — ahead of the 2029 fee modulation deadline
- ✓Monitor ongoing delegated acts, guidance documents, and national implementations as PPWR continues to roll out
Most regulatory affairs teams are already stretched across multiple compliance programmes simultaneously — FIC labelling, novel foods, contaminant limits, nutrition and health claims. Adding PPWR through manual processes — spreadsheet trackers, supplier email chains, PDF libraries — is unsustainable at scale.
The brands that manage this effectively are those that automate the information-gathering and gap-analysis layer, and reserve human expertise for decisions that actually require it.
Automate your PPWR compliance assessment
Prodeen is an AI-powered compliance operating system built for food and beverage regulatory teams. The PPWR Assessment playbook guides you through the requirements applicable to your packaging, identifies compliance gaps, and generates a structured output your team can act on immediately.
PFAS status check
Assesses your food-contact packaging materials against the Article 5 PFAS thresholds and flags materials requiring reformulation or a supplier switch before the August deadline.
Declaration of Conformity requirements
Identifies which packaging types require a DoC, what technical documentation you need to prepare, and who holds the compliance obligation in your supply chain.
Recyclability grade assessment
Evaluates your current packaging against the Annex II grading criteria and flags gaps against the 2030 and 2038 thresholds — so you can plan material transitions now.
EPR registration mapping
Identifies which EU member states require EPR registration for your product portfolio and the applicable timelines — before the 2029 fee modulation deadline.
Ongoing regulatory monitoring
Tracks PPWR delegated acts, guidance updates, and member state implementation — so you are never blindsided by changes after August 2026.
Start your PPWR compliance review today
With the August 2026 deadline approaching, now is the time to understand where your packaging portfolio stands.
Run a PPWR Assessment
Submit your packaging details and receive a structured compliance output covering PFAS, Declaration of Conformity, recyclability, and EPR. No demo call needed.
Try the PPWR Playbook →For large portfolio teams
Managing multiple SKUs across EU markets? Speak to our team about enterprise-scale PPWR programmes — from initial assessment through to ongoing monitoring.
Get in Touch →Sources: EU PPWR Regulation (EU) 2025/40 · Declaration of Conformity — Packaging Europe · FDF PPWR Business Guidance · EU PFAS packaging ban — Certivo