PPWR in short
- The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the new European packaging law and has applied directly in Belgium, the Netherlands and France since 12 August 2026.
- Three obligations are already in force: the EU declaration of conformity per packaging type, limits on PFAS and heavy metals for food contact, and identification of the manufacturer on the packaging.
- Packaging placed on the market before 12 August 2026 may still be sold and used. New packaging must comply.
- Recyclability and recycled content follow later, with 2030 as the major deadline.
The PPWR — the Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40 — became a good deal more concrete today. Since 12 August 2026, the first obligations under this European packaging regulation apply. And one signal came through clearly in the press: many small businesses and SMEs are not sure what has actually changed. That is understandable, because the packaging legislation is extensive and is being phased in until 2030.
Below we set out what counts right now, what is still coming, and what this means when you buy packaging film or bags for your food business.
What exactly is the PPWR?
The PPWR replaces the old 1994 European packaging directive with a regulation. That distinction matters: a regulation applies directly in every member state, without being transposed into Belgian, Dutch or French law. The same packaging rules, everywhere in the EU, at the same moment. You can find the full text on EUR-Lex.
It has three aims: less packaging waste, safer packaging materials, and full traceability of what is placed on the market. The major material deadlines — recyclability and recycled content — follow later; you will find more on our approach to those on our sustainability page.
What has changed since 12 August 2026?
Three PPWR obligations are in force from this date.
1. EU declaration of conformity required
Packaging may only be placed on the European market if a valid EU declaration of conformity exists for each packaging type, supported by a technical file. That file is not a formality: it sets out the material composition, the tests carried out and the reasoning behind why the packaging meets the requirements. No external certification body is involved — the assessment is done through internal production control, on your own responsibility. Anyone unable to produce it during an inspection risks penalties.
2. Limits on PFAS and heavy metals
Article 5 of the PPWR sets a maximum of 100 ppm for heavy metals (lead, cadmium, mercury and hexavalent chromium combined) in packaging. For food-contact packaging, strict limits also apply to PFAS: 25 ppb per individual PFAS substance, 250 ppb for the sum of PFAS, and 50 ppm total fluorine. Those values apply even where PFAS is unintentionally present.
This directly affects the films and bags food products are packed in — from thermoforming film and topseal film to flowpack film, vacuum bags and bags. Grease- and water-repellent coatings were a classic use of PFAS in food contact materials for years; that route is now closed.
3. Mandatory identification on the packaging
A type, batch or serial number, together with the name, postal address and an electronic means of contact for the manufacturer or importer, must appear on the packaging — or behind a QR code on the packaging. Every pack can then be traced back to whoever placed it on the market.
Worth knowing: stock already placed on the market before 12 August 2026 may still be sold and used. The obligations apply to new packaging entering circulation from now on. So there is no need to empty your warehouse — but your next order does need to be in order.
Does the PPWR apply to my business?
Almost certainly yes. The packaging regulation covers the whole chain: packaging producers, businesses having packaging made under their own brand, importers, distributors, online shops, retailers and certain logistics providers. If you pack food and place that product on the market, then in PPWR terms you are an economic operator with obligations of your own.
Exactly where you stand depends on your role. If you buy film or bags from a supplier, the declaration of conformity for that packaging sits with the party placing it on the market — but you need that documentation yourself to complete your own file. Your supplier is obliged to provide you with all the information you need to demonstrate conformity.
PPWR timeline: 2027, 2028 and 2030
The PPWR is being phased in. The main steps after today:
- 2027 — additional classification rules, including for coffee capsules.
- 2028 — harmonised labelling: an EU label indicating what the packaging is made of and which waste stream it belongs in. Registration with an approved extended producer responsibility organisation — Fost Plus in Belgium, Verpact in the Netherlands — also falls within this phase.
- 2030 — minimum recycled content in plastic packaging, the recyclability requirement for all packaging, and a maximum empty space of 50% in shipping boxes.
On top of that, some thirty additional guidance documents are expected from the European Commission by 2029, filling in the detail. In other words: this file is not closed, and it pays to have a packaging supplier who follows it.
Checklist: is your packaging PPWR-compliant?
If you work in food and buy packaging — directly from a manufacturer abroad or through a local distributor — you are responsible for what enters your factory or warehouse. From today, there are three questions you should be able to answer about every pack you use:
- Can my supplier produce a valid EU declaration of conformity? On paper, per packaging type, and on simple request.
- Is there a technical file behind it? Or is the declaration a blank promise with nothing to support it?
- Does the packaging meet the PFAS and heavy metal limits that apply to food contact?
If you cannot get a clear answer to any one of those three, that in itself tells you something.
Why a local packaging supplier is worth more today
For small and medium-sized food businesses, this is exactly where it pinches: you rarely have the time or the team to audit foreign manufacturers for compliance yourself. A local distributor with its own stock and quality control takes that work off your hands — and is reachable in your own language, within your own time zone.
At AB Flexibles we follow this packaging legislation closely for the films and bags we import and distribute in Belgium, the Netherlands and France. Documentation, material data and declarations of conformity are part of what we supply, so you do not have to worry about it. Read more about our approach on our sustainability page, or in our frequently asked questions.
Frequently asked questions about the PPWR
What is the PPWR?
The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the European packaging regulation replacing the 1994 packaging directive. It aims for less packaging waste, safer materials and full traceability, and applies directly in all EU member states without national transposition.
When does the PPWR come into effect?
The regulation entered into force in early 2025 and has applied since 12 August 2026. From that date the EU declaration of conformity, the limits on hazardous substances and the identification requirement apply. Other obligations follow in phases in 2027, 2028 and 2030.
What is an EU declaration of conformity for packaging?
It is a written declaration that a pack meets the PPWR requirements, drawn up per packaging type by the party placing the packaging on the market. It rests on a technical file covering material composition, tests and supporting reasoning. No external certification body is needed: the assessment is done through internal production control.
Which PFAS limits apply to food packaging?
For food-contact packaging, a maximum of 25 ppb per individual PFAS substance, 250 ppb for the sum of PFAS and 50 ppm total fluorine has applied since 12 August 2026. In addition, a maximum of 100 ppm applies to lead, cadmium, mercury and hexavalent chromium combined in all packaging.
Can I still use my existing packaging stock?
Yes. Packaging already placed on the market before 12 August 2026 may still be sold and used. The new obligations apply to packaging entering circulation from that date onwards — so to your next orders.
Does the PPWR apply to small businesses too?
Yes. The regulation provides exemptions from certain obligations for micro-enterprises, but the basic rules apply to everyone placing packaging on the European market — from producer and importer to online shop and retailer. The size of your business does not release you from the compliance obligation.
Who is responsible: me or my supplier?
The declaration of conformity is drawn up by whoever places the packaging on the market. If you buy film or bags, you need that documentation for your own file; your supplier is obliged to provide you with all the information needed to demonstrate conformity. So ask for it, and keep it.
Questions about your packaging?
Not sure whether your current packaging complies with the new packaging rules, or looking for a supplier who keeps track of this for you? Get in touch — we are happy to think along with you, even if you are not buying anything today.
This article is for information purposes and does not constitute legal advice. If in doubt, consult the official PPWR text or a specialised adviser.