Summary: Regulation (EU) 2025/40 (PPWR) addresses substances in packaging and minimum recycled content in separate provisions. This reference focuses on PFAS limits for food-contact packaging and recycled content recovered from post-consumer plastic waste. Applicability depends on packaging use, material, product rules and the economic operator placing it on the EU market. A supplier statement or certification logo alone is not a substitute for technical evidence.
1. Start with the PPWR timeline and legal split
PPWR entered into force on 11 February 2025 and applies from 12 August 2026. It covers packaging placed on the EU market and addresses packaging design, composition, recyclability, labelling and waste management. This article does not merge EU rules with the UK regime, national EPR administration or platform policy.
| Track | Main reference | Preparation focus |
|---|---|---|
| Substances and PFAS | Article 5 | Confirm food-contact use, limits and technical records |
| Recycled plastic content | Article 7 | Trace post-consumer feedstock, quality and plant-level calculation |
| Technical file | Articles 5(6), 7(6) and Annex VII | Explain material, use, calculation and evidence basis |
2. PFAS: the rule is not a blanket ban on every package
Article 5(5) addresses food-contact packaging. From 12 August 2026, subject to the interaction with other Union legislation, such packaging must not be placed on the market at or above these levels:
- 25 ppb for any PFAS measured by targeted PFAS analysis;
- 250 ppb for the sum of PFAS measured by targeted analysis, where applicable after degradation of precursors;
- 50 ppm for PFAS including polymeric PFAS. If total fluorine exceeds 50 mg/kg, the relevant operator may need evidence showing how much fluorine is attributable to PFAS or non-PFAS substances for the Annex VII technical documentation.
A statement that a supplier did not intentionally add PFAS does not answer every regulatory question. Identify food-contact use, coatings, paper treatments, inks, adhesives and recycled feedstock first. Then select a laboratory method matching the parameter being demonstrated. The report should identify the sample, batch, component, method, limit of quantification and conclusion. Any parameter outside its scope should remain explicitly outside the conclusion.
The wider PFAS restriction proposal discussed by ECHA is a separate regulatory process. Its scientific and socio-economic assessment should not be presented as an already effective, single EU-wide ban covering every packaging use.
3. Recycled plastic content: 2030 is not “30% for every package”
Article 7 requires minimum recycled content recovered from post-consumer plastic waste by 1 January 2030, or three years after the relevant implementing act enters into force, whichever is later. The main targets are:
| Packaging type | 2030 | 2040 |
|---|---|---|
| Contact-sensitive packaging with PET as the major component, excluding single-use plastic beverage bottles | 30% | 50% |
| Contact-sensitive packaging made from plastics other than PET, excluding single-use plastic beverage bottles | 10% | 25% |
| Single-use plastic beverage bottles | 30% | 65% |
| Other plastic packaging | 35% | 65% |
The percentages are calculated as an annual average per manufacturing plant and by packaging type and format. The recycled material must come from post-consumer plastic waste meeting the collection and recycling conditions in Article 7. Article 7 also contains exceptions, including compostable plastic packaging, dangerous-goods transport packaging and certain medical, medicinal-product and young-child food packaging. Food-contact packaging may also be excepted where recycled content would create a food-contact compliance problem. Do not assign one percentage merely because an item is plastic or food-contact.
4. Build two evidence tracks around one SKU record
PFAS file: packaging-use and food-contact assessment, material and formulation list, coating/ink/adhesive supplier information, sample-to-batch mapping, test method and report, abnormal-batch disposition, and technical explanations supporting Annex VII.
Recycled-content file: packaging-unit and plastic-component list, component masses, post-consumer source, collection and recycling locations, supplier and batch traceability, purchase and production records, annual plant-level calculation, and verification or audit material required once the implementing measures are available. ISCC PLUS, GRS, RCS or another scheme may be useful supply-chain evidence, but its scope and evidential role must be checked; the scheme name does not automatically prove PPWR compliance.
Outer cartons, trays, lids, labels, adhesives and films may require different treatment depending on the actual packaging design and PPWR definitions. Integrated and separate components should not be replaced by one unexamined total-weight figure. For a multi-country SKU, keep one controlled mapping between the product record, packaging artwork, listing wording and technical file.
5. Six practical checks
- Confirm the target market, placing-on-the-market role, packaging use and food-contact status before applying a limit or percentage.
- List every packaging unit, separable component, material, mass and supplier by SKU.
- Create a PFAS assessment and testing plan for food-contact materials, recording method and report boundaries.
- Record post-consumer feedstock, collection, recycling, batches and the plant-level annual calculation for recycled content.
- Link supplier evidence, test reports, purchase and production records to the packaging version.
- Recheck the implementing and delegated acts and national execution requirements as they develop. Do not turn “prepared” into a claim of regulatory approval.
Sources
- Regulation (EU) 2025/40, especially Articles 5, 7 and 71 and Annex VII: official EUR-Lex text.
- European Commission, Packaging waste and Packaging and Packaging Waste Regulation pages.
- European Chemicals Agency, PFAS topic and restriction-process pages.
