The European Commission has recently published its Guidance document and accompanying FAQ on the Packaging and Packaging Waste Regulation (PPWR). These non-binding guidelines are intended to support economic operators and Member States in implementing the regulation and to contribute to a more uniform application within the European internal market.
Compared to earlier drafts, the text has been further refined, without significant substantive changes. The Guidance will still be translated into all official EU languages before being formally adopted.
A central point of attention is the obligation to minimise substances of concern (SoCs) in packaging. Although there is no general list or threshold values, companies must be able to demonstrate that they have reduced these substances as much as possible.
For PFAS in food packaging, concrete limits will apply from 12 August 2026:
• 25 ppb (individual PFAS)
• 250 ppb (sum of PFAS)
• 50 ppm (total PFAS)
In its Guidance, the Commission proposes a stepwise testing approach. Notably, there is no sell-through period: non-compliant packaging may no longer be placed on the market from the date of application. The rules apply to the entire packaging, including inks and coatings, and also to recycled materials.
In addition, the importance of compliance is emphasised. Manufacturers must carry out a conformity assessment and draw up an EU declaration of conformity, supported by technical documentation. The Guidance also clarifies the division of roles in the chain and confirms that only one party can be considered the manufacturer.
Future obligations are also addressed, such as those relating to recyclability, recycled content and labelling. For example, packaging containing at least 5% plastic may in certain cases be considered single-use plastic, with consequences for future bans.
The publications provide companies with additional guidance, but at the same time underline the need to prepare in a timely manner for the application in August 2026. These clarifications reflect the current interpretation of the European Commission and may evolve as implementation progresses.
Want to know more about PFAS?
Would you like to prepare in time for the new PFAS obligations under the PPWR? IBE-BVI is organising a practice-oriented seminar on PFAS in packaging on 16 June 2026.
During this training, you will receive a clear overview of the properties, applications and risks of PFAS, as well as the applicable regulations and analytical methods. Exposure, migration and possible alternatives will also be discussed.
An ideal opportunity to update your knowledge and to get started with the upcoming obligations in practice.
More information and registration via HERE.
For IBE-BVI members, the Guidance and FAQ are available upon simple request HERE.
