On March 30, 2026, the European Commission released the final guidance document and accompanying Frequently Asked Questions (FAQ) for the Packaging and Packaging Waste Regulation (PPWR), providing compliance guidance for EU member states and economic operators.
Background
The PPWR officially entered into force on February 11, 2025, replacing the Packaging and Packaging Waste Directive (94/62/EC) that had been in place for nearly 30 years. Unlike the previous directive, the PPWR applies directly to all member states as an EU regulation without requiring individual transposition by each country. The regulation will become universally applicable from August 12, 2026.
Main Contents of the Guidance Document
I. Key Definitions
|
Definition |
Definition Explanation |
|
Packaging |
Items used to contain, protect, handle, deliver, or present products; must meet criteria regarding function, material, and design |
|
Packaging Manufacturer |
Not necessarily the actual producer, but the natural or legal person who "orders and determines the specifications of the packaging design"; brand owners are generally considered manufacturers |
|
Packaging Producer |
Manufacturers, importers, or distributors who first place packaging or packaged products on the market within a member state; responsible for extended producer responsibility (EPR) |
|
Importer |
Must be established within the EU (with independent legal personality); branches cannot serve as importers |
II. Compliance Deadlines
|
Date |
Requirement |
|
August 12, 2026 |
Universal application of the regulation; PFAS restrictions take effect (food contact packaging) |
|
February 12, 2028 |
Compostable packaging requirements take effect; Commission will request development of home composting standards |
|
August 12, 2028 |
Harmonized packaging labeling requirements take effect |
|
January 1, 2029 |
Deposit return systems (DRS) must be established to achieve 90% separate collection rate |
|
February 12, 2029 |
Reusable packaging labeling requirements take effect |
|
January 1, 2030 |
Packaging minimization requirements, empty space ratio requirements, reuse targets, packaging bans, and other core requirements take effect; Recyclability design requirements take effect (or 24 months after entry into force of relevant delegated acts, whichever is later) |
|
January 1, 2035 |
Large-scale recycling requirements take effect |
III. PFAS Restrictions (Effective August 12, 2026)
- Any single PFAS: ≤ 25 ppb (excluding polymeric PFAS)
- Sum of PFAS: ≤ 250 ppb (degradable precursors)
- All PFAS (including polymers): ≤ 50 ppm; if total fluorine > 50 mg/kg, proof must be provided
Commission Interpretation
1. Recommended Stepwise Approach for PFAS Testing
|
Step |
Testing Content |
Compliance Criteria |
|
Step 1 |
Quantification of Total Fluorine (TF) |
TF < 50 mg/kg → deemed compliant |
|
Step 2 |
If TF exceeds limit, use pyrolysis-GC/MS or similar methods to confirm whether fluorine is organic fluorine (PFAS) |
Organic fluorine < 50 mg/kg → deemed compliant |
|
Step 3 |
Direct TOP (Total Oxidizable Precursor) analysis |
Check compliance with 25 μg/kg and 250 μg/kg limits |
Note: Current evidence shows that samples passing Step 1 testing typically also meet Step 2 and Step 3 requirements.
2. Stock Depletion (No Transition Period)
|
Scenario |
Treatment |
|
Packaging placed on the market before August 12, 2026 |
May remain on the market without withdrawal |
|
Packaging placed on the market after August 12, 2026 |
Must comply with PFAS limits; no stock transition period |
|
Packaging containing recycled materials |
No exceptions; same rules apply |
3. Key Time Point Determination
- Sales packaging and grouped packaging: Generally deemed placed on the market when filling is completed (final processing steps such as sealing may affect compliance)
- Transport packaging and service packaging: Generally placed on the market in empty packaging state
- Imported packaging: Time point is determined by release for free circulation upon completion of customs procedures
IV. Relationship with Existing Regulations
- With Single-Use Plastics Directive (SUPD): The PPWR takes precedence over SUPD regarding packaging bans, but both regulations coexist; SUPD continues to apply to single-use plastic products not covered by PPWR bans
- With old Packaging Directive (94/62/EC): The PPWR replaces the old directive, but some existing standards and requirements may still serve as guidance until the new regulation is fully applicable
