On July 16, 2026, the European Chemicals Agency (ECHA) issued a consultation letter to global stakeholders regarding the draft list of "Substances of Concern" (SoC) under the Packaging and Packaging Waste Regulation (PPWR). The draft list identifies approximately 700 chemical substances present in various packaging materials, covering all categories of packaging applications including plastics, paper, metal, glass, and ceramics. Relevant enterprises and industry associations must submit feedback by August 24, 2026. Based on the draft and consultation letter, CIRS Group provides the following interpretation.
SoC Identification Criteria (Meeting Any One Criterion Is Sufficient)
ECHA screened substances based on the SoC criteria defined in Article 2(27) of the Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), ultimately identifying approximately 700 substances for inclusion in the draft list. The inclusion criteria fall into four categories:
- Substances of Very High Concern (SVHC): Substances listed on the REACH Candidate List;
- Chronic Health Hazards: Substances with harmonized classification for chronic effects such as carcinogenicity, mutagenicity, or reproductive toxicity;
- Persistent Organic Pollutants (POPs): Substances regulated under the Stockholm Convention;
- Recycling Impediments: Substances that negatively impact the recycling processes of plastics and other packaging materials, according to the Joint Research Centre (JRC) methodology and CEN design-for-recycling standards (EN 18120-1:2026).
Listed Substances
The listed substances are widely present throughout the packaging value chain.
- By packaging material, plastics (polyethylene, polypropylene, PVC, PET, polystyrene, etc.) and paper-based materials account for the highest proportion, while metal, glass, ceramics, and composite materials are also involved.
- From a functional perspective, in addition to the packaging substrates themselves, additives such as plasticizers (e.g., various phthalates), flame retardants (e.g., polybrominated diphenyl ethers, hexabromocyclododecane), inks and printing compounds, adhesives, light stabilizers/antioxidants, and pigments account for a significant proportion.
- The list includes both Intentionally Added Substances (IAS)—such as additives used to improve material properties—and Non-Intentionally Added Substances (NIAS)—such as by-products formed during production or contaminants remaining in recycled materials.
- Some common substances such as bisphenol A, perfluorooctanoic acid (PFOA), cadmium and its compounds, lead compounds, and polycyclic aromatic hydrocarbons (PAHs) are all included.
- Notably, various short-chain and long-chain per- and polyfluoroalkyl substances (PFAS)—including 6:2 FTOH, PFOS, PFOA, and their precursors—also appear on the list.
Industry Feedback Window Closing Soon
Key Feedback Points:
- The actual current use of the substance in packaging;
- Whether it is an Intentionally Added Substance (IAS);
- The specific packaging material, type, and format in which it is applied;
- A technical description of the substance's function.
Submission Method: Feedback can be submitted directly to ECHA's PPWR team at restriction-PPWR@echa.europa.eu via industry associations or enterprises; confidential information may be marked as such.
Deadline: August 24, 2026.
ChemRadar Insights
Inclusion of a substance on the SoC list or preliminary candidate restriction list does not automatically create regulatory obligations, nor does it mean the substance will be immediately banned. ECHA will submit its final research report to the European Commission by September 21, 2026, which will directly influence the recyclability requirements under the PPWR framework (Article 6). Going forward, packaging design and recycling standards will take the presence of SoC into account, and enterprises need to plan ahead in material selection and supply chain management.
