Monday, March 2, 2026
PPWR: What It Is, What It Changes, and What to Expect From Customers in 2026
This article covers what PPWR is, what it means for Quality and ESG teams specifically, how to start preparing, and what customer requests will look like now that it's in force.
Maikel Fontein
Mar 2, 2026
2 min
min
For most food suppliers, packaging compliance has been a relatively stable part of the job. Approved materials, supplier declarations on file, and a questionnaire process that didn't change much year to year.
PPWR puts a hard deadline on data gaps that have always existed and were easy to ignore until now. Enforcement starts August 12, 2026, and customers are already restructuring their supplier questionnaires around it.
What PPWR actually is
PPWR (Regulation EU 2025/40) replaces the old Packaging Directive that's been in place since 1994. The key difference is that the old directive had to be turned into national law by each EU member state, which meant 27 different versions of the same rules. PPWR applies directly across all member states. Same rules, same timelines, everywhere.
The regulation covers the full lifecycle of packaging: how it's designed, what it's made of, how it's labelled, and what happens to it at end of life.
For food suppliers, the most immediately relevant changes fall into 5 areas:
Recycled content targets | From 2030, plastic food packaging must contain minimum post-consumer recycled (PCR) content. For food-grade PET (trays, bottles, containers): 30% by 2030, rising to 50% by 2040. For other food contact plastics: 10% by 2030, rising to 25% by 2040. |
Recyclability classification | All packaging will need to be assessed and classified under an EU Design for Recycling methodology, receiving a grade of Class A, B, or C based on how recyclable it actually is in EU collection systems. Packaging below 70% recyclability will be prohibited from market by 2030. The criterias are still being finalised in secondary legislation, but evidence requirements are already showing up in customer questionnaires now. |
Packaging minimisation | Packaging weight and volume must be reduced to the technically necessary minimum. From 2030, double walls, false bottoms, and unnecessary layers are prohibited. EPR fees will be tied to packaging weight data, making this a financial issue as much as an environmental one. |
PFAS restrictions in food contact packaging | From August 12, 2026, food-contact packaging containing intentionally added PFAS above defined thresholds cannot be placed on the EU market. There is no transition period and no grandfathering: even packaging manufactured before that date cannot be sold if it doesn't comply. For teams used to managing PFAS through migration testing, this introduces a different question entirely: you need to know whether PFAS were intentionally used as part of the packaging material, not just whether they migrate into food. |
EPR and labelling | Extended Producer Responsibility expands significantly, with mandatory registration in producer registries and regular reporting obligations by country and material type. Harmonised labelling rules come into effect from 2027, including standardised QR codes linking to recyclability and disposal information. |
What this means operationally
The shift is less about new concepts and more about the level of proof required.
Saying packaging is "recyclable" or that it contains "recycled content" is no longer enough. PPWR requires that those claims hold up with supplier documentation, traceable data, and, in some cases, third-party verification.
And unlike a food safety audit that happens once a year, this documentation needs to be current, consistent across markets, and retrievable on demand.
Demonstrating compliance requires an EU Declaration of Conformity backed by technical documentation, held for five years for single-use packaging and ten years for reusable. That documentation flows up the supply chain: packaging suppliers are now expected to provide compliance data the same way ingredient suppliers provide food safety documentation.
The other shift is cadence. Customers will send recurring data requests, quarterly and annually, across your full SKU portfolio. If QA, ESG, and procurement aren't aligned on packaging data internally, the inconsistencies will show up in submissions.
How to start preparing
The reality for most food suppliers is that packaging data is scattered. Supplier declarations are in email threads, material specs haven't been updated since the last product launch, and nobody is entirely sure which team owns the answer when a customer asks a detailed packaging question.
PPWR doesn't create that problem. It just makes it visible, because customers will now ask questions that require a real answer.
A few things worth doing now:
Map what you actually have, not what you think you have:
For each packaging format, could you produce the full material composition by layer, a current supplier declaration, and confirmation on PFAS use?
If the answer is no for any of your top-volume SKUs, that's where to start. An honest gap analysis beats a scramble when a customer portal deadline is two weeks away.
Identify your highest-exposure formats first:
Not all packaging carries the same risk. Multi-layer plastics, packaging with PFAS-based coatings (common in greasy food applications like paper trays and wraps), and formats with significant headspace or unnecessary secondary layers are the areas where PPWR requirements hit hardest. Prioritise those before working through the rest of your portfolio.
Update what you ask from packaging suppliers:
Most supplier declaration templates were built around food safety and don't cover PPWR data: recyclability classification, PCR content with certification, PFAS intentional use declarations.
Under PPWR, suppliers are legally required to provide documentation necessary for compliance. That gives you a clear basis for asking. The brands and retailers ahead of this are already making PPWR data a condition of supplier approval. Getting there now means less friction later.
Decide ownership internally:
PPWR sits across QA, ESG, and Procurement in a way that no single team naturally owns end-to-end. That ambiguity is manageable when requests are infrequent. It becomes a real problem when a customer needs a response by Friday for three markets and four SKUs.
Sorting ownership now is the lowest-effort, highest-impact thing most teams can do before August.
What your inbox will look like in 2026
PPWR won't arrive as a new questionnaire labelled "PPWR compliance." It will show up as more detailed, more frequent, and more specific requests inside the portals and questionnaires you already receive.
Here are the categories customers are already organising their requests around:
1. Recyclability evidence
This becomes the most frequent category of request.
Expect to provide:
EU recyclability classification (Class A/B/C) under the EU design-for-recycling methodology.
Confirmation of compatibility with EU municipal collection streams.
NIR detectability status and whether carbon black or optical-blocking pigments are present.
Whether labels, sleeves, or closures are detachable by consumers.
Full layer-by-layer material composition (% weight per component).
Barrier layers disclosed: EVOH, metallization, PVDC, aluminium coating (%).
Adhesives, inks, coatings, and primers.
Density of each plastic part.
Third-party recyclability report from RecyClass, Interseroh, Cyclos, or a recognised national scheme.
2. Recycled plastic content
This is where many food suppliers will struggle most, especially those that haven't previously needed to track recycled content at the component level.
Questions will include:
% post-consumer recycled (PCR) content per plastic component.
Source of recyclate.
Food-grade authorisation reference under EU Regulation 2022/1616 (recycled plastic in food contact).
Mass balance certification (ISCC+ or equivalent).
Consistency range of PCR % (minimum to maximum).
Expect these requests to come quarterly, not once.
3. Packaging minimisation
This is a genuinely new topic that many teams haven't dealt with before. PPWR requires companies to justify packaging size and weight, not just declare it.
New questions will include:
Total packaging weight per SKU.
Product-to-packaging weight ratio.
Headspace percentage.
Evidence that the packaging format is technically necessary.
Whether lightweighting studies have been performed.
Whether alternative formats were evaluated.
Fees and penalties under EPR schemes are directly linked to this data.
4. Reuse and refill
Even ingredient suppliers and B2B packaging providers will encounter this. Questions in this area include:
Whether packaging is designed for reuse.
Number of validated rotations.
Cleaning protocol validation.
Identification method (QR code, RFID, marking).
Participation in pooling systems.
5. EPR reporting data
This will become the most frequent recurring request and for many teams, the most operationally demanding. It moves packaging data firmly into legal reporting territory.
Monthly and annual requests will include:
Packaging weight by material (kg).
Country where packaging is placed on the EU market.
Material codes per EPR system.
Hazardous substances present.
Compostability standard (EN 13432) if claimed.
6. Claims and labelling proof
Marketing claims now require legal substantiation. Customers will ask for:
Evidence supporting any "recyclable" claim.
Evidence supporting any "bio-based" or "compostable" claim.
Disposal instructions provided on-pack.
Digital product passport availability (relevant now; mandatory further down the line).
7. Substances of concern
This expands beyond the traditional migration testing that food contact teams are used to.
New questions include:
Whether PFAS are intentionally added to any packaging component.
SVHC content above 0.1% under REACH.
Heavy metals in inks or pigments.
Whether an NIAS (Non-Intentionally Added Substances) risk assessment is available.
Where things are heading
The supplier approval questionnaire used to be a one-time exercise at onboarding. PPWR turns it into a recurring process: by SKU, by market, by quarter.
The question customers are already asking, and will keep asking more formally from August onwards, is not "is your product safe?" It's "can we legally place this packaging on the EU market right now, and can you prove it?"
The suppliers that build a reliable process for answering that question will be easier to work with. In a market where customers are tightening their supplier bases around compliance readiness, that's worth treating as more than a regulatory obligation.
