PPWR: New Limits Under the Packaging Regulation 2026 – What You Need to Know from August 12

With the EU Packaging and Packaging Waste Regulation (Packaging and Packaging Waste Regulation, or PPWR for short), the legal framework for packaging in the European Union is undergoing a fundamental transformation. Regulation (EU) 2025/40 already entered into force on February 11, 2025, and will apply directly in all Member States from August 12, 2026. Unlike before, it is directly applicable as an EU regulation and no longer requires national implementation of a directive. For companies that manufacture, import, distribute, or place packaging or packaged products on the European market, this change means concrete action is required.

More Than Just New Limits

The new PPWR does not only establish new limits; it regulates the entire life cycle of packaging – from material selection and recyclability to labeling and documentation requirements in the form of the EU Declaration of Conformity.

Many of these requirements will be introduced gradually through 2040. However, the limits for PFAS and heavy metals, as well as key documentation requirements, will already apply from August 12, 2026.

The Specific Limits: PFAS and Heavy Metals Compared

From August 12, 2026, binding EU-wide limits for PFAS (per- and polyfluoroalkyl substances) will apply to food-contact packaging for the first time.

Until now, there has been no harmonized EU-wide regulation specifically governing PFAS in packaging. Some Member States had introduced national requirements.

While the limit for the total concentration of heavy metals is essentially carried over from the previous legislation, the PFAS requirements represent an entirely new regulatory obligation.

Here is an overview:

These changes will have a significant impact on packaging types where PFAS have traditionally been used for functional purposes, such as grease-, water-, or stain-resistant coatings on baking paper, fast-food packaging, or microwave popcorn bags.

What Packaging Manufacturers Need to Consider from August 12

Who Is Affected?

The PPWR is not limited to traditional packaging manufacturers. It applies to all economic operators that manufacture, import, distribute, or place packaging or packaged products on the EU market, regardless of the material used.

This includes:

• Importers bringing packaging or packaged products from non-EU countries onto the European market
• Brand owners and private-label companies that market products under their own name and, under certain circumstances, are therefore considered manufacturers under the regulation
• Distributors and retailers, who must ensure that the packaging they offer carries the required information and documentation
• E-commerce and logistics companies, for which the packaging minimization requirements are particularly relevant

What needs to be done?

To meet the requirements applicable from August 12, companies should take several steps:

• Review supplier information: What materials and compositions are used in your packaging? Are the existing supplier declarations sufficient, or is additional analytical clarification required?
• Migration studies and analytical testing: Where there is uncertainty regarding the material composition – particularly for food-contact packaging – targeted testing for PFAS, total fluorine, and heavy metals, as well as migration and food-safety testing, can provide reliable analytical evidence. Such studies are an important and objective component of conformity assessment, regardless of which service provider performs the testing.
• Prepare conformity assessment and technical documentation: Placing packaging on the market requires a conformity assessment, supported by technical documentation and an EU Declaration of Conformity.
• Clarify responsibilities: For private-label products in particular, it is often unclear who is considered the “manufacturer” under the regulation and therefore responsible for the corresponding obligations. These roles should be clarified at an early stage to ensure clear allocation of responsibilities throughout the supply chain.

Are Additional Measures Such as Training or Certification Required?

Since the PPWR affects numerous business functions – from quality assurance, procurement, research and development to sustainability and packaging design – targeted training of the relevant teams is recommended in many cases.

This helps ensure that requirements, responsibilities, and deadlines are understood and implemented consistently throughout the organization.

The PPWR itself does not impose a formal certification requirement. What matters is a structured and documented conformity assessment that can be clearly demonstrated to authorities or business partners if required.

Tentamus Group Supports Companies on Their Path to PPWR Compliance

Tentamus Group supports companies throughout the entire PPWR compliance process by combining analytical, technical, and regulatory expertise.

Our services include:

• PFAS and total fluorine analysis, as well as the determination of heavy metals (lead, cadmium, mercury, and hexavalent chromium) in packaging materials to provide analytical evidence of compliance with the new limits under Article 5 of the PPWR
• Migration and food-safety testing for food-contact packaging, including assessments of how material changes or reductions in packaging weight and volume may affect product safety
• Shelf-life studies to support packaging optimization and reduction while ensuring that material savings do not compromise product protection or quality
• Technical and regulatory assessments and gap analyses that translate the general PPWR requirements into concrete, company-specific action plans and document the results in a final report
  Support in establishing a conformity assessment system, including the preparation of technical documentation and the EU Declaration of Conformity
• Review of existing technical packaging documentation provided by suppliers, as well as PPWR training to give relevant business functions a practical overview of requirements, responsibilities, and deadlines

Whether you need an initial assessment, targeted laboratory analysis, or support in preparing complete conformity documentation, our experts support companies in the food, cosmetics, pharmaceutical, and consumer goods industries throughout the entire PPWR compliance process.

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If you have individual questions regarding your packaging and the deadlines applicable to your business, our team of experts will be happy to assist you.