The EU Packaging and Packaging Waste Regulation will generally apply from 12 August 2026.
Regulation (EU) 2025/40, commonly known as the PPWR, introduces a harmonised framework covering packaging placed on the European Union market and the management of packaging waste.
The regulation covers packaging regardless of its material or origin and introduces requirements relating to packaging composition, manufacturing, recyclability, reuse, waste prevention and producer responsibilities.
For cosmetics, food, supplements, healthcare products and imported consumer goods, the PPWR is not only an environmental reporting issue. It affects product development, packaging selection, supplier qualification and technical documentation.
Does every PPWR obligation start on 12 August 2026?
No.
The regulation generally applies from 12 August 2026, but individual requirements, delegated acts, implementing measures and transition periods follow different timelines.
Companies should avoid two opposite mistakes:
- assuming that every PPWR obligation starts immediately
- assuming that no action is required until later deadlines
The correct approach is to create a product-specific implementation roadmap.
One immediate priority: PFAS in food-contact packaging
From 12 August 2026, food-contact packaging must not be placed on the EU market when it contains PFAS at or above the PPWR limit values.
The regulation establishes limits including:
- 25 ppb for any individual PFAS measured by targeted analysis
- 250 ppb for the sum of PFAS measured through targeted analysis
- 50 ppm for PFAS, including polymeric PFAS
Additional evidence may be required where total fluorine exceeds 50 mg/kg.
The European Commission has clarified that the PPWR does not provide a general stock-exhaustion transition for PFAS-containing food-contact packaging produced before 12 August 2026.
Packaging placed on the market after that date must comply. Packaging already placed on the market before the date may remain available and does not automatically need to be withdrawn.
This makes the timing of “placing on the market” operationally important.
Which companies are affected?
The PPWR is relevant to businesses including:
- packaging manufacturers
- food and beverage companies
- supplement brands
- cosmetics companies
- private-label manufacturers
- importers
- distributors
- e-commerce businesses
- companies selling packaged products under their own brand
- suppliers of packaging materials and components
International companies entering the EU should not assume that packaging accepted in the United States, United Kingdom or Asia automatically complies with the PPWR.
What should companies do first?
1. Map the packaging portfolio
Document packaging by:
- product
- material
- component
- supplier
- intended use
- food-contact status
- country of origin
- date of first placement on the EU market
Primary, secondary, grouped, transport and service packaging may be subject to different practical considerations.
2. Clarify economic-operator roles
Companies should determine who acts as:
- manufacturer
- producer
- importer
- distributor
- authorised representative
- fulfilment service provider
The applicable responsibility cannot be determined solely from who physically manufactures the packaging.
Brand ownership, commissioning arrangements and market-placement activities may affect the legal role.
3. Update supplier questionnaires
Suppliers should provide information relevant to:
- material composition
- substances of concern
- PFAS
- heavy metals
- recycled content
- recyclability
- conformity documentation
- production changes
Generic sustainability statements are not substitutes for technical evidence.
4. Prioritise food-contact packaging
Food-contact packaging requires immediate attention because the PFAS limits apply from the general application date.
Companies should identify high-risk materials such as:
- grease-resistant papers
- coated paper and board
- moulded fibre
- barrier coatings
- takeaway packaging
- flexible laminates
- specialised seals and liners
The material type alone does not prove the presence or absence of PFAS.
5. Define a testing strategy
Testing should answer a defined compliance question.
Depending on the material and supplier evidence, this may include:
- targeted PFAS analysis
- total fluorine screening
- migration testing
- material characterisation
- heavy-metal analysis
- assessment of coatings and multilayer structures
Not every packaging component requires the same test programme.
6. Build technical documentation
Companies should retain evidence showing how compliance was assessed.
Documentation may include:
- material specifications
- supplier declarations
- analytical reports
- risk assessments
- design information
- compliance decisions
- change-control procedures
Why waiting is risky
Packaging projects often involve long lead times.
Artwork changes, supplier qualification, material substitutions, tooling, production trials and stability testing cannot always be completed shortly before a regulatory deadline.
A late compliance review may reveal that the packaging needs to be changed after the product formula, shelf-life study or launch schedule has already been finalised.
How Makrolife can support PPWR readiness
Makrolife can support companies with:
- packaging portfolio reviews
- supplier-document gap assessments
- PFAS and chemical-testing strategies
- food-contact material testing
- packaging risk assessments
- coordination of specialised laboratory analyses
- interpretation of results
- preparation of a practical compliance action plan
The objective is to determine what needs to be tested, which documents are missing and what must change before the packaging is placed on the EU market.
Prepare before 12 August 2026
The PPWR should be treated as a cross-functional project involving regulatory affairs, packaging development, quality management, procurement and suppliers.
Request a PPWR Packaging Readiness Check from Makrolife.
