EU Packaging And Packaging Waste Regulation Begins To Apply August 12, 2026; Public Comment Opportunities Underway

On August 12, 2026, the European Union’s (EU) Packaging and Packaging Waste Regulation (PPWR) will officially replace the EU’s longstanding Packaging and Packaging Waste Directive (PPWD). Where the PPWD provided member states with both regulatory and implementation flexibility, meaning that each member state could take a different approach to implementation, the PPWR brings harmonized standards across the EU. This change seeks to bring cohesion across member states to encourage a circular economy and a consistent regulatory scheme. Manufacturers, importers, and other entities bringing or distributing packaging and packaged products into the EU should ensure familiarity with the PPWR’s requirements.

PPWR Implementation

The PPWR entered into force on February 11, 2025, but provided an 18-month period before its general application. The PPWR is designed to be implemented in phases, meaning that different requirements will become applicable over time. August 12, 2026, does not represent implementation of the PPWR in its entirety. It does, however, mark an important compliance date for several of the PPWR’s initial requirements.

Beginning August 12, 2026, packaging placed on the EU market must comply with the substance requirements established under Article 5 of the PPWR. Article 5(1) requires packaging to be manufactured so that the presence and concentration of substances of concern (SoC) in packaging materials and components are minimized, including with respect to emissions, waste-management outcomes, and adverse environmental impacts associated with microplastics.

Article 5 also establishes specific concentration limits for certain substances. Under Article 5(4), the sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium present in packaging or packaging components may not exceed 100 mg/kg.

The PPWR additionally establishes new restrictions specifically for per- and polyfluoroalkyl substances (PFAS) in food-contact packaging. Beginning August 12, 2026, food-contact packaging may not be placed on the EU market if it contains PFAS at or above the following thresholds:

• 25 parts per billion (ppb) for any PFAS measured through targeted PFAS analysis, excluding polymeric PFAS from quantification;

• 250 ppb for the sum of PFAS measured through targeted PFAS analysis, where applicable, with prior degradation of precursors and excluding polymeric PFAS from quantification; or

• 50 parts per million (ppm) for PFAS, including polymeric PFAS.

Compliance with the heavy-metal and PFAS requirements must be demonstrated in the technical documentation required under Annex VII of the PPWR.

Broader regulation of SoCs is expected to evolve as PPWR implementation continues. Under Article 5(2), the European Commission (EC), assisted by the European Chemicals Agency (ECHA), must prepare a report by December 31, 2026, assessing the presence of SoCs in packaging and packaging components and the extent to which they affect reuse, recycling, or chemical safety. The EC must also consider appropriate follow-up measures, which could include additional chemical restrictions under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) or restrictions incorporated into the PPWR’s design-for-recycling criteria.

Companies placing packaging or packaged products on the EU market should assess their products to determine compliance under the initial PPWR requirements in Article 5. Companies should remain aware of developing requirements for SoCs and other aspects of the PPWR that will emerge in future phases of the regulation’s implementation.

Public Comment Opportunities

The EC is currently seeking comments for two initiatives under the PPWR. The first has a comment period from August 6, 2026, to September 10, 2026, midnight Brussels time, and “aims to harmonize parts of extended producer responsibility schemes for packaging in EU countries. It sets out rules on the requirement for EU countries to establish a register of producers and the obligation on producers to report to their national schemes.”

The second was sent only to member groups that had previously commented on the PPWR; ECHA shared a cover document and a draft list of SoCs identified in packaging and packaging waste as part of its ongoing work under the PPWR. ECHA has extended the deadline for comments until August 24, 2026. Comment can be provided by reviewing the cover document and draft list information and contacting the ECHA PPWR team at restriction-PPWR@echa.europa.eu.