PPWR
AUGUST 2026
PPWR arrives in August.
Here's what it means for your business.
Still figuring out what PPWR actually requires from your team? You’re not alone. Here are the three things QA, Sustainability, and Packaging teams in F&B should know:
Your role determines your obligations. Whether you're a producer, an importer, or a distributor, PPWR assigns different compliance duties to each. Most F&B companies hold more than one role.
Three major requirements kick in from August. PFAS and heavy-metal limits on food-contact packaging, a signed Declaration of Conformity per packaging type, and EPR registration in every Member State where you sell.
Evidence collection takes 2–3 months. Gathering lab data, supplier documentation, and registering across Member States is not a week's work. Companies that start in April can realistically be ready by August.
Most F&B businesses hold more than one role across their product range. A food brand that sells products under its own name is a producer for those SKUs. If it also sources packaged goods from outside the EU, it is an importer for those lines. If it resells a third-party branded product without modification, it acts as a distributor for that product. Your role is determined product by product — not once for the whole business. Mapping your role per SKU is the first step in any PPWR compliance process.
Producer
You are a producer if your name or trademark appears on the packaging, or if you have commissioned packaging to be designed or manufactured on your behalf. The role is determined by the brand on the pack, not by who physically made it.
Your obligations from Aug 2026
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Issue a Declaration of Conformity per packaging type, signed by you
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Obtain lab verified PFAS and heavy-metal data for every food-contact pack
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Retain the technical file for 10 years, producible within 10 days on request
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Register in national EPR schemes in every Member State where you place packaging on the marke
Importer
You are an importer if you are established in the EU and you bring packaging or packaged products from outside the EU into the EU market for the first time. The role is triggered by the act of first placing non-EU packaging on the EU market — regardless of whether you own the brand.
Your obligations from Aug 2026
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Carry the same substance compliance obligations as a producer — a non-EU supplier's word alone is not sufficient
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Verify that packaging meets PFAS, heavy-metal, and labelling requirements before placing it on the market
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Hold a copy of the Declaration of Conformity and produce it within 10 days if requested
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Register in national EPR schemes in every Member State where you sell
Distributor
You are a distributor if you make packaging or packaged products available on the EU market and you are not the producer or importer of those products. The role applies to any step in the supply chain that moves compliant goods onwards — without taking on responsibility for the underlying documentation.
Your obligations from Aug 2026
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Verify that the producer or importer has met their PPWR obligations before you sell — and keep records that show you did
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Check that packaging is correctly labelled and shows no obvious signs of non-compliance
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Maintain traceability so you can identify who supplied what, at any time
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Never relabel or repackage without taking on the full obligations of a producer
— Does this apply to you?
Recognise your position.
Understand your obligation.
The PPWR assigns obligations by role, not by company type. The regulation defines three roles: producer, importer, and distributor. Most food and beverage businesses hold more than one role depending on the product.
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Effective Aug 2026 · Food-contact packaging
What does this mean in practice:
A ready-to-eat salad bowl or sandwich wrap cannot be placed on the EU market from August 2026 if the packaging contains PFAS above legal limits. Moulded fibre bowls and paper-based wraps commonly use PFAS coatings to prevent grease and moisture from leaking through. Every packaging component requires laboratory testing, not just supplier statements.
PFAS limits in food-contact packaging
Maximum thresholds: 25 ppb per individual non-polymeric PFAS, 250 ppb for the total sum, and 50 ppm total fluorine. Covers any packaging in direct or indirect contact with food, including paper, board, and flexible laminates. "Non-intentionally added" is not a valid defence.
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Effective Aug 2026 · All packaging types
What this means in practice?
A brightly printed outer carton or foil lidding with metallic inks could exceed thresholds even if the food-contact inner is clean. Every layer of a multilayer pack needs checking, not just the innermost surface.
Heavy-metal limits across all packaging
Combined concentration of lead, cadmium, mercury and hexavalent chromium must stay under 100 mg/kg for every packaging type, not just food-contact. Applies to inks, pigments, coatings and adhesives used in production.
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Effective Aug 2026 · Producer obligation
What does this mean in practice?
A dairy brand with 80 SKUs across 12 different packaging types needs 12 DoCs, each supported by supplier data and lab evidence. Any material change, such as switching cardboard suppliers or coating specifications, triggers a DoC update. Outsourcing production does not transfer this obligation.
Declaration of Conformity per packaging type
The producer must issue, sign and retain a DoC for each unique packaging type. It must reference the specific PPWR requirements met, include material composition data, and be updated whenever the packaging changes.
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Effective Aug 2026 → Feb 2027
What this means in practice?
For a co-packer producing F&B packaging under a retailer's label, the retailer's name and address must appear, not the co-packer's. Packaging ordered now without this field will need artwork and plate changes before the deadline.
Labelling & digital identifiers on-pack
From August 2026, packaging must display the manufacturer's name and address, or provide a QR code linking to it. From February 2027, digital identifiers must also carry material composition and recyclability information, replacing the Green Dot.
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Criteria being finalised · Effective 2030
What this means in practice?
Black trays with carbon-black pigment, common in ready-meal packaging, are likely to grade D or E due to optical sorting limitations. F&B packaging engineers should model recyclability grades now to avoid costly reformulation under time pressure.
Recyclability grades A–E from 2030
All packaging will receive a recyclability grade against Design for Recycling criteria currently being finalised through EU implementing acts. From 2030, packaging graded D or below will be banned from the EU market. From 2038, only grades A and B will remain permitted. Design decisions made today determine readiness in 2029.
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Effective Aug 2026 · Per member state
What this means in practice?
A Dutch F&B brand selling via Amazon Germany that hasn't registered in Germany's LUCID system is already non-compliant. Under PPWR: fines up to €200,000 and marketplace sales restrictions, with no grace period from August 2026.
EPR registration and fee payment
Producers must register in national EPR schemes in every Member State where they first place packaged goods on the market. Fee levels differ per country and material type. Missing or incorrect registration is an offence in its own right, with direct sales bans as a consequence.
— What changes — specifically for F&B
Six major requirements with real consequences for food and beverage operations.
What each PPWR obligation actually means for your QA, sustainability, and packaging teams. With concrete examples from food and beverage operations.
— your ppwr readiness journey
Evidence collection takes 2–3 months. The window is now.
Working backwards from August 12: operational systems must be live by Q2 2026. Below is the readiness journey before the deadline, and the longer programme that follows it.
3 steps to PPWR Compliance
1. Compliance evidence & technical file readiness:
Supplier documentation, data verification, and audit-ready file maintenance.
2. Packaging redesign
Material selection, design modification, and structural changes to meet customer and regulatory requirements.
3. Reporting & fees
Identify roles and responsibilities and calculate fees
Compliance evidence
For many companies, the largest workload PPWR requires is managing compliance evidence. PPWR requires managing data and evidence across many suppliers, packaging formats and SKUs.
PPWR introduces a shift in sustainability regulation with obligations distributed across quality, procurement, packaging & sustainability teams
Before August 12, 2026 - Start now
Start now
Define which PPWR roles you hold per product line.
Pakcaging baseline
Map components,suppliers, and initial structure
Evidence collection
Gather specs,declarations of conformity,and lab evidence
Compliance verification
Validate PFAS and heavy metals compliance
Compliance required
Prove complinace on authority request
After August 2026 - Long-term Obligations
August 2026
Substances of concern limits
General application- EPR requirements
Febuary 2027
Green dot moves to
QR code
2029
Deposit return schemes must collect 90% of in-scope containers
2030
Recyclability standards & targets are in place
Prohibited packaging types introduced
2035 & beyond
Recycled at scale requirement in effect
Higher recyclability standards, recycled content & reuse targets
Does PPWR apply to packaging made outside the EU?
Yes. PPWR applies to all packaging placed on the EU market regardless of where it was produced. Importers carry the same obligations as EU manufacturers — including verifying supplier compliance and retaining the technical file.
Is "non-intentionally added PFAS" still acceptable?
No. The thresholds apply regardless of intent. Recycled paper and board commonly contain PFAS from previous use cycles — "non-intentionally added" is not a valid defence. Actual measurement or verified third-party analytical data is required.
Who must issue the Declaration of Conformity?
The producer — the entity placing packaging on the EU market under its own name or trademark. If your brand name is on the pack, the DoC obligation is yours, even if a contract manufacturer produced it.
Can a packaging supplier refuse to share composition data?
Not lawfully. Article 16 of Regulation (EU) 2025/40 obliges suppliers to provide complete compliance information to downstream customers. A supplier who refuses is in breach of their own obligations.
In practice: if you cannot obtain the data needed to issue a DoC, you cannot lawfully place that packaging on the EU market.
What about packaging stock produced before August 2026?
Packaging already placed on the EU market before August 12, 2026 does not need to meet the new requirements. The cut-off is the date of placing on the market — not date of manufacture or sale. Managing stock and transition timing carefully is advisable for high-volume SKUs.
Who enforces PPWR and what are the real penalties?
Each Member State designates its own market surveillance authority. In the Netherlands it's the NVWA (typically €5,000–€50,000/week). In Germany, LUCID registration violations reach up to €200,000. Across all Member States, authorities can impose direct sales bans — including via marketplace platforms.
Whitepaper download
18 pages
Unpacking the PPWR: The complete F&B guide
Everything QA, packaging and sustainability teams need in one document: every role, every deadline, every requirement — with a practical preparation checklist.
PFAs & heavy-metal requirements explained
Declaration of Conformity walkthrough
EPR registration by Member State
Step-by-step preparation checklist
F&B-specific examples throughout
