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Discover the EU Packaging and Packaging Waste Regulation (PPWR), its requirements, timelines, and impact on food & dietary supplement packaging compliance.
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Discover the EU Packaging and Packaging Waste Regulation (PPWR), its requirements, timelines, and impact on food & dietary supplement packaging compliance.
What is PPWR? EU Packaging Regulation & Compliance Guide
The EU's Packaging and Packaging Waste Regulation (PPWR): What Businesses Need to Know
The Packaging and Packaging Waste Regulation (PPWR) is one of the most far-reaching sustainability laws to come out of the European Union in recent years. It sets out to change how packaging is designed, produced, used, and disposed of across every stage of its life. Formally known as Regulation (EU) 2025/40, PPWR replaces the older Packaging and Packaging Waste Directive that had governed the sector since 1994, and it puts a single, harmonized framework in place across all EU member states.
The shift from a directive to a regulation matters more than it might seem. Under the old directive, each member state had room to interpret and apply the rules in its own way, leading to a patchwork of national requirements. PPWR closes that gap: because it is directly applicable law, any business selling into or exporting to the EU now faces the same packaging rules no matter which member state it operates in.
For sectors that depend heavily on packaging — food and dietary supplements chief among them — this is a substantial shift. Companies will need to reconsider packaging design, material choices, labeling practices, and their broader sustainability roadmaps.
Why the EU Created PPWR
Packaging waste has been growing faster than almost any other waste stream in Europe, straining waste management systems and driving continued reliance on virgin materials. The previous regulatory patchwork also left recycling rates inconsistent and did little to curb the environmental toll of single-use packaging.
PPWR is the EU's answer: a push toward a circular economy in which packaging materials stay in circulation longer through reuse, recycling, and better recovery systems.
Specifically, the regulation is meant to tackle:
Rapidly growing packaging waste volumes
Continued dependence on virgin and non-renewable raw materials
Weak reuse and recycling performance
Environmental pollution linked to single-use packaging
Europe's broader climate and sustainability commitments
By tightening packaging standards, the EU is betting it can cut environmental impact while pushing industries toward more sustainable innovation.
What PPWR Is Trying to Achieve
The regulation lays out several long-term goals that will reshape packaging practices across Europe:
Recyclable-by-design packaging by 2030. All packaging entering the EU market must be designed to be recyclable and to work within existing recycling infrastructure.
Higher recycled content requirements. Plastic packaging producers will need to meet minimum recycled-content thresholds, which vary by packaging type, cutting demand for virgin plastic.
Less packaging overall. Companies must strip out unnecessary layers, cut down on wasted space, and streamline designs so less material is used in the first place.
More reuse and refill options. The regulation pushes reusable packaging and refill systems into more product categories to reduce single-use reliance.
Tighter limits on hazardous substances. Chemicals like PFAS (per- and polyfluoroalkyl substances), often found in food-contact packaging, will be restricted once they cross certain thresholds.
A genuinely circular system. The end goal is a packaging economy where materials are recovered and reused continuously rather than thrown away after one use.
How PPWR Will Roll Out
The EU has mapped out a phased timeline for compliance:
Date
Milestone
January 2025
PPWR formally adopted and published
February 2025
Regulation enters into force across the EU
August 2026
Most operational compliance obligations begin applying
2030 and beyond
Core targets — recyclability, recycled content — become fully enforceable
Some obligations won't kick in until as late as 2040, but given the scale of change involved, businesses are being encouraged to start planning now rather than waiting for deadlines to approach.
What Companies Will Need to Do
Any business placing packaging on the EU market will need to address several requirements:
Design for recyclability. Packaging has to be built so it can be efficiently collected, sorted, and recycled within current waste systems.
Meet recycled-content thresholds. Rather than a simple recyclable/non-recyclable label, PPWR introduces graded recyclability classes starting in 2030, with tougher rules following in 2038.
Cut down on excess packaging. This applies especially to e-commerce and consumer goods, where oversized packaging and wasted space are common.
Introduce reuse or refill systems in certain product categories.
Standardize labeling so material composition, recyclability, and disposal instructions are clear to consumers.
Take on extended producer responsibility (EPR), meaning manufacturers become accountable for the full lifecycle of their packaging, including collection and recycling costs.
Complete conformity assessments and issue an EU Declaration of Conformity. Importers, meanwhile, must confirm these steps have been completed and keep records for the required retention period.
What This Means for Food and Dietary Supplement Companies
Few sectors will feel PPWR's impact as strongly as food and supplements, given how much these industries rely on specialized packaging to protect product safety, stability, and shelf life.
Packaging materials will need to change. Formats that fall short of the new recyclability standards may need to be redesigned — a particular concern for multilayer materials. That could affect bottles, containers, sachets, pouches, blister packs, flexible packaging, and even transport and secondary packaging.
Food-contact compliance gets stricter. New restrictions on substances like PFAS may force companies to reformulate packaging materials and run additional safety testing, all while still meeting food safety rules.
Redesign becomes unavoidable. Manufacturers will likely need to cut material use, boost recyclability, update labeling, and align with the new sustainability expectations — or risk losing market access for non-compliant packaging.
Costs will rise, at least initially. Expect higher spending on packaging redesign, testing and certification, supply chain adjustments, sustainability reporting, and regulatory documentation. Companies that invest early, though, may come out ahead in the long run.
Compliance becomes a market-access issue. Meeting PPWR's requirements won't just be a box to check — it will determine whether a company can keep selling into the EU at all. Early movers stand to gain a real edge in brand reputation and competitiveness.
Where Packaging Is Headed
PPWR isn't just another environmental rule — it marks a broader shift in how packaging will be approached globally. For food and supplement companies, that likely means:
Sustainable packaging becoming the industry norm rather than the exception
More transparency around what packaging is made of and how to dispose of it
Heavier investment in recyclable and reusable materials
Stronger accountability across supply chains
Rising consumer expectations for environmentally responsible products
Businesses that get ahead of these shifts now will be in a much stronger position as the regulatory landscape continues to evolve.
The Bottom Line
The Packaging and Packaging Waste Regulation (PPWR) is one of the EU's most consequential sustainability regulations to date, resetting expectations for how packaging is designed, produced, recycled, and reused. Its impact will be felt most by industries — like food and dietary supplements — that depend heavily on packaging for product protection and shelf life.
This is no longer just a compliance checkbox; it's a strategic shift. Companies that invest in sustainable packaging now will be better positioned to compete as the regulatory bar continues to rise.
Learn what a Declaration of Conformity (DoC) is under PPWR and why supporting technical documentation is critical for EU packaging compliance.
Declaration of Conformity (DoC)in PPWR: Requirements & Guide
The PPWR Declaration of Conformity: Why the Document Is Only Half the Story
As the EU Packaging and Packaging Waste Regulation (PPWR) draws closer to full implementation, packaging manufacturers, importers, and brand owners are going to run into one term constantly: the Declaration of Conformity (DoC). Getting a real handle on this document is essential to navigating the wider set of EU packaging rules now reshaping the industry.
On the surface, a DoC looks straightforward — a handful of compliance statements, a signature, a date. But treating it as a routine formality is exactly what puts companies at risk. A signed statement with nothing behind it isn't compliance; it's a liability waiting to be discovered.
The real value of a Declaration of Conformity isn't the paperwork itself — it's the body of evidence that stands behind it.
What Exactly Is a Declaration of Conformity?
A DoC is the formal document in which an economic operator states that a packaging product meets the applicable requirements of the PPWR. Think of it as the final checkpoint before a product goes to market — the point at which someone is formally vouching that the packaging has already been evaluated and satisfies the relevant obligations.
It gives regulators, customers, and supply chain partners an official assurance that the assessment work has happened. What it is not is a stand-in for that work. A DoC declares that compliance has been demonstrated — it doesn't create the compliance itself.
Why It Matters More Than It Looks
Under the PPWR, market surveillance authorities can ask a company to justify why its packaging was declared compliant in the first place. When that request comes in, a signed DoC on its own usually won't satisfy them. Companies need to produce the underlying documentation, on a set timeline, and walk through exactly how conformity was established.
This is precisely where a lot of organizations run into trouble — because a Declaration of Conformity is only as credible as the technical file backing it up.
What Should Sit Behind the Declaration
A well-supported DoC rests on a technical file that typically includes:
Clear identification of the packaging and its intended use
Details of packaging components and materials
Supplier declarations and related documentation
Food contact compliance information, where relevant
Data on PFAS and other regulated substances
Recyclability assessments
Packaging minimization evaluations
Applicable standards, specifications, and test reports
Version control and document management records
Documented conformity assessment procedures
Taken together, this is the evidence that turns a Declaration of Conformity from a signature into an actual, defensible claim of EU packaging compliance.
The Three Pillars of PPWR Compliance
It helps to think of PPWR compliance as resting on three legs:
1. The Declaration of Conformity — the formal statement that compliance has been achieved.
2. Technical Documentation — the evidence trail showing how that compliance was actually reached.
3. The Evidence Register — the traceable record of assessments, supplier data, and compliance activity underpinning it all.
Strip out the second and third pillars, and the first one is just a piece of paper.
The Misconception Companies Keep Making
Most organizations put their energy into producing the Declaration of Conformity itself — which, frankly, is the easy part. The harder and more valuable work is building the compliance infrastructure underneath it: packaging data management, supplier evidence collection, technical assessments, and a documented decision-making trail.
The Bottom Line
There's nothing inherently wrong with a one-page Declaration of Conformity. A one-page DoC with no supporting evidence behind it, on the other hand, is a real compliance exposure.
Genuine packaging compliance starts well before a DoC ever gets signed. It begins with mapping your packaging portfolio, understanding your regulatory obligations, collecting supplier information, and maintaining a solid technical dossier.
Do that groundwork first, and a Declaration of Conformity becomes what it's supposed to be: credible proof that your packaging actually meets PPWR requirements — not just a signature on paper.
Need help preparing PPWR-compliant Declarations of Conformity and the technical documentation behind them? Freyr's experts can support you in building an audit-ready packaging compliance framework.
Explore the EU PPWR roadmap with key packaging compliance milestones, timelines, and documentation requirements for successful EU market access.
Discover the August 2026 PPWR changes for substances of concern, PFAS, heavy metals, and supplier compliance requirements for packaging.
PPWR Substances of Concern: What Changes in August 2026?
EU Clarifies Substances of Concern Rules Under PPWR Ahead of August 2026 Deadline
The European Commission has published an FAQ on Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), shedding light on how substances of concern (SoC) in packaging will be treated once the regulation's main provisions take effect on 12 August 2026. The guidance is meant to help businesses move from chemical-restriction thinking toward a broader compliance approach that also covers recyclability and circularity.
Defining a Substance of Concern
Rather than creating a new standalone definition, the PPWR borrows its SoC criteria from the Ecodesign for Sustainable Products Regulation (ESPR). Per the Commission's FAQ, a substance only needs to satisfy one of several conditions to be classified as a SoC — the criteria are alternatives, not a checklist that must all be met. These conditions include:
A substance can qualify because it appears on the REACH Article 57 list of substances of very high concern, falls under specific CLP hazard classifications, is regulated under the EU's Persistent Organic Pollutants rules (Regulation 2019/1021), interferes with the reuse or recycling of packaging materials, or meets other criteria set out in the ESPR's SoC framework. Because any single condition is sufficient, the practical scope of what counts as a SoC is considerably wider than under prior packaging rules, pushing manufacturers to think about recyclability alongside traditional toxicity concerns.
What Changes on 12 August 2026
Several core PPWR obligations become enforceable on this date:
Packaging will need to be designed and manufactured to minimize both the presence and concentration of substances of concern. The existing heavy-metal limits — covering lead, cadmium, mercury, and hexavalent chromium — remain in force. And food-contact packaging will be subject to PFAS limits, with the Commission's FAQ confirming this restriction applies regardless of whether the PFAS was deliberately added or ended up in the packaging unintentionally, for instance through recycled inputs, inks, adhesives, or coatings. That nuance matters most for companies relying on recycled content or multi-material packaging, where contamination is harder to control.
No Single Threshold for Every Substance
One point the FAQ makes explicit: there's no uniform concentration limit that applies across all substances of concern. PFAS and the four heavy metals have their own specific thresholds, while other substances are governed by general minimization and conformity obligations rather than a numeric cap. This means businesses can't comply by checking against one master limit; instead, compliance requires substance-by-substance tracking, solid supplier data, and documentation that can demonstrate conformity across different regulatory pathways.
Supply Chain Responsibilities
Article 16 of the PPWR puts the burden of information-sharing on suppliers, who must give manufacturers what they need to assess and demonstrate conformity. Manufacturers, in turn, are responsible for using that information to identify relevant substances of concern, evaluate compliance, and prepare the required EU PPWR Declaration of Conformity. This makes supplier coordination and traceable documentation a central part of meeting the regulation's requirements, not a secondary administrative task.
EN 13428:2004 Loses Its Presumption-of-Conformity Status
The FAQ also clarifies that Annex C of the older EN 13428:2004 standard will no longer be sufficient to presume conformity once the PPWR applies, since it doesn't reflect the regulation's expanded SoC scope. Companies that have relied on this standard for compliance will likely need to revisit their conformity assessment procedures.
Getting Ready Before the Deadline
With less than two months until the 12 August 2026 deadline, businesses should be reviewing their packaging portfolios for SoC exposure, evaluating PFAS risk across their supply chains, tightening up supplier documentation processes, improving visibility into packaging-related data, and updating their conformity assessment procedures accordingly.
The Commission's FAQ underscores a broader shift: substances of concern compliance under PPWR isn't purely a chemical-restriction issue anymore — it's also a question of data management, traceability, and supplier documentation. Companies that start this work early will be in a much stronger position to manage compliance risk and keep their products moving smoothly into the EU market. Connect with Freyr to assess packaging risks, strengthen supplier documentation, and stay ahead of August 2026 requirements.
Explore how EU’s PPWR affects food & supplement packaging, recyclability, and labeling. Learn how to achieve compliance and avoid EU market
Explore how EU’s PPWR affects food & supplement packaging, recyclability, and labeling. Learn how to achieve compliance and avoid EU market entry risks.