The PPWR is coming

In short, the PPWR sets new requirements for all packaging within the EU.

It pertains to:

• Stricter requirements for recyclability
• The use of recycled material 
• Limiting unnecessary packaging 
• And above all: drawing up and substantiating a declaration of conformity for all packaging placed on the market 

From 12 August 2026, this will become the new reality — and therefore a condition for being allowed to place products on the market. 

Many organisations are grappling with the same questions:

• What role do I play in the chain, and for which packaging data am I responsible?
• Where do I get that information from, and how do I know it's correct?
• How do I record this conveniently? And when do I really need to be ready for this? 

New requirements around PFAS and heavy metals 

The PPWR does not focus solely on sustainability and recyclability. The regulation also sets explicit requirements for the chemical safety of packaging. For the first time, binding limits for PFAS in food contact packaging will be introduced within the EU. In addition, the existing restrictions on heavy metals remain in force, such as for: 

• Lead (Pb) 
• Cadmium (Cd) 
• Mercury (Hg) 
• Chromium (Cr)  

This means organisations not only need to know which materials their packaging is made of, but must also be able to substantiate this technically. 

Which analyses are needed? 

For PFAS, a phased analysis method is currently being used based on the provisional European guidance: 

1. Total Fluorine (TF) 
2. Total Organic Fluorine (TOF) 
3. Specific PFAS analysis 

Depending on the results, further investigation may be needed (steps 2 and 3), for example into organic fluorine (TOP) and specific PFAS components. In addition, we can examine packaging for heavy metals in accordance with European requirements. 

Making PPWR compliance demonstrable 

An important point the PPWR is that compliance must be demonstrable. Organisations must be able to build up and substantiate technical documentation and declarations of conformity. 

This requires:

• Interpretation of results 
• Correct recording of packaging data 
• Embedding within existing quality processes 
• Coordination with suppliers and chain partners 

At Eurofins Food Safety Solutions, we support organisations with both analyses and the interpretation and substantiation required for PPWR compliance. 

Start on time

Because there is no transition period and compliance must be demonstrable from 12 August 2026, it is wise to gain timely insight into potential risks within your packaging portfolio. 

Analysing early helps to identify risks, build technical documentation, and prevent disruptions in the supply chain.