On August 12, 2026, multiple provisions of the European Union’s Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) came into effect.
Concentration limits
For food packaging, some of the largest changes are the concentration limits for per- and polyfluoroalkyl substances (PFAS). Beginning August 12, food packaging cannot be placed on the EU market if it contains PFAS at or above:
- 25 parts per billion (ppb) for any individual PFAS measured using targeted analysis, excluding polymeric PFAS;
- 250 ppb for the sum of PFAS measured using targeted analysis, excluding polymeric PFAS; or
- 50 parts per million (ppm) for total PFAS, including polymeric PFAS
The restriction applies to intentionally and non-intentionally added PFAS, focusing on the concentration of PFAS in the packaging rather than the level migrating out of the packaging and ultimately present in the food.
When total fluorine exceeds 50 mg/kg packaging, chemical manufacturers, importers, or downstream users may need to show evidence of how much comes from PFAS.
A stepwise testing approach
The Commission noted in their guidance published on June 5, 2026, that “[s]everal protocols and methodologies to test the presence of PFAS in different matrices exist, but there is no harmonised methodology for PFAS in food contact packaging at EU level.” For enforcement from August 12, it recommends a stepwise approach.
First, consider the quantity of total fluorine. A sample with less than 50 mg total fluorine/kg packaging could be considered compliant. When total fluorine exceeds 50 mg/kg, stakeholders can use methods such as pyrolysis-GC/MS to determine whether the fluorine is organic or inorganic. A sample with less than 50 mg organic fluorine /kg could be considered compliant. Finally, “[d]irect TOP (total oxidizable precursors) analysis is recommended to check compliance with the 25 μg/kg and 250 μg/kg concentration limit in step 3.”
No transitional sale period
The Commission also clarified that the PPWR does not provide a transitional period for selling packaging containing PFAS. Packaging manufactured before August 12, 2026, but first placed on the EU market after that date, must comply with the new limits. Packaging already placed on the market before August 12 may remain.
PPWR provisions coming into force later
Detailed design-for-recycling criteria and recyclability grades will not restrict market access until 2030 or 24 months after the relevant delegated acts enter into force, whichever is later (FPF reported). The recycled-at-scale requirement follows from 2035 or later.
Other measures scheduled for later dates include requirements for takeaway businesses to accept consumers’ own containers from February 2027, compostability requirements for selected packaging from February 2028, harmonized sorting labels from August 2028 or later, and packaging minimization, recycled content, reuse target, and certain packaging-format restrictions from 2030.
References
European Parliament and Council (December 19, 2024). “Regulation (EU) 2025/40 on packaging and packaging waste.” Official Journal of the European Union.
European Commission (June 5, 2026). “Commission Notice: Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste.”
