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EU's new packaging regulation PPWR guidelines released: in-depth analysis of corporate green transformation and compliance challenges
Author.
LCS
Source:
Post time:
2026-04-20
The draft implementation guidelines for the EU Packaging and Packaging Waste Regulation (PPWR) have been officially released, providing key operational instructions for the full application of the regulation on August 12, 2026. This draft not only refines the core concepts, but also clarifies the specific technical standards and compliance paths that enterprises must comply with.
01 Core Concepts and Boundary Points
The definition scope of packaging: items and accessories that are used together with the product or can be discarded separately after use for the purposes of packaging, protection, handling, display, etc. Including disposable packaging, service packaging, integrated components, and accessories.
Manufacturer vs Packaging Manufacturer: The entity that actually manufactures packaging or packaged products at the physical level; Packaging manufacturers may be responsible for the same packaging in different countries as the main body responsible for extending producer responsibility when packaging is first introduced to the market in member countries.
The implementation focus of the guide is to clarify the division of responsibilities, supply chain traceability, compliance during the design phase, and alignment with recycling goals.
02 PFAS restriction: Food contact materials and products
Implementation time and objectives:
Starting from August 12, 2026, food contact materials and products with excessive PFAS content shall not be placed on the market; Products that are already in the market are allowed to be sold over time.
Specific limits:
Single PFAS (non polymer):<25 ppb
Total PFAS (non polymer, containing precursor degradation products):<250 ppb
Total fluorine content:<50 ppm; If it exceeds the requirement, technical documents must be provided to prove compliance
Detection and evaluation pathway (recommended three-step method in the guidelines):
Step 1: Total fluoride quantification. If it is less than 50 mg/kg, it is compliant;
Step 2: If the total fluoride is greater than 50 mg/kg, use pyrolysis GC/MS to distinguish between organic fluoride and inorganic fluoride; If organic fluorine is less than 50 mg/kg, it is compliant;
Step 3 and auxiliary methods: TOP (Total Analysis of Oxidizable Precursors) can be considered to verify whether the limits of 25 ppb and 250 ppb have been reached.
03 Exemption from Recycled Material Content and Future Trends
Exemption application situation (according to Article 7, Paragraph 5 of the law):
The use of recycled materials in food contact plastic packaging but with health risks is not included in the mandatory requirement;
If the proportion of plastic components in the total weight of the packaging is less than 5%, it can also be exempted.
Future direction and evaluation window:
The committee plans to evaluate whether to expand the exemption scope before January 1, 2028; At that time, adjustments may be made to the exemption conditions, coverage materials, and application scenarios.
Enterprise response strategy:
Based on our own product structure, evaluate the proportion of recycled materials used and the risk level of food contact. If necessary, optimize compliance costs by improving formulas and increasing the proportion of recycling and reuse.
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