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PPWR roles, objectives and responsibilities at a glance
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PPWR and chemicals – what companies need to know
The European Union has introduced sweeping changes to packaging law with its Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40). While public debate has often focused on recycling targets, reusability provisions and the prevention of packaging waste, one aspect is often overlooked: the increasing importance of chemical and material conformity.
The PPWR consolidates provisions from packaging law, the circular economy and chemicals legislation to an extent not seen before in the EU. For companies, this means that their packaging not only has to be safe and legally compliant, but must also be designed to ensure its circularity.
Please note: This article is provided for general information only and does not constitute legal advice.
Why chemicals are important in the PPWR
Overall, the PPWR aims to maintain packaging within a well-functioning circular economy.
The problem at EU level: The high-quality recycling of materials is only possible if problematic substances are not permanently present within the material loop. In recent years, it has become clear that packaging often contains substances that make recycling more difficult or reduce the quality of recycled materials, and may also give rise to health or environmental risks.
The PPWR therefore takes a different approach: The circularity of a piece of packaging is therefore also considered to be dependent on the chemical composition of the packaging.
A new perspective: Compliance moves from chemicals to circularity
To date, material compliance has often focused on whether or not the substance being used is legally admissible. The PPWR goes one step further to ask whether the packaging is capable of being recycled.
Companies should think about the following questions:
- Is the substance permitted?
- Is the material REACH-compliant?
- Have limits been observed?
- Have substance prohibitions been observed?
As well as the following:
- Is the packaging circular-compatible?
- Is the material ready for high-quality recycling?
- Do some substances limit the recycling process?
- Can the packaging be used and reused in the loop?
PPWR and existing chemicals legislation
The PPWR supplements and extends the existing legal framework by expanding requirements for record-keeping and circularity. Key examples of previous legislation include: REACH, the CLP Regulation, the Food Contact Materials Regulation and the Single-Use Plastics Directive. In the future, packaging must therefore be REACH-compliant, compliant with food regulations, compliant with product safety law and PPWR-compliant.
New: EU-wide PFAS limits
PFAS (per- and polyfluoroalkyl substances) have been used for a long time in fast-food packaging, greaseproof paper packaging or packaging for baked goods, on account of their water-resistant, fat-resistant and dirt-resistant properties. These are ‘forever chemicals’, however, because they persist for a long time in the environment. Accordingly, the PPWR is the first EU law to introduce harmonised limits for PFAS in certain types of food contact packaging. From 12 August 2026, food contact packaging may no longer be placed on the market if it contains PFAS in concentrations that equal or exceed the limits as specified in Article 5(5) of the PPWR (Regulation (EU) 2025/40).
Three separate limits have been defined for PFAS:
- 25 ppb (0.025 mg/kg) for any individual PFAS (excluding polymeric PFAS) measured by targeted analysis
- 250 ppb (0.25 mg/kg) total for all PFAS (excluding polymeric PFAS) measured by targeted analysis
- 50 ppm (50 mg/kg) threshold for all PFAS in the packaging, including polymer PFAS
If any one of these limits is reached or exceeded, the packaging is considered non-compliant. In practice, compliance is often assessed using a stepwise analytical approach. Interzero is ready to advise and assist!
Please note: Paper and cardboard packaging in particular should be analysed for fluorinated coatings as soon as possible.
Limits for heavy metals
Limits for lead, cadmium, mercury and hexavalent chromium had already been defined in the previous Packaging Directive (Directive 94/62/EC). These same limits have been included in the PPWR.
Limit for all packaging (plastics, cardboard, glass, etc.): The sum total of all four heavy metals must not exceed 100 mg/kg (100 ppm).
Please note: Analyses for printing inks, pigments, additives and recycled materials should be completed as a matter of priority.
Substances of Very High Concern (SVHC)
Substances of Very High Concern (SVHC) are defined in the REACH Regulation. These substances may be carcinogenic, toxic for reproduction or especially persistent in the environment.
Relevant for packaging:
- SVHC may be present in plastics, printing inks, coatings, adhesives or additives.
- Duties to communicate information apply along the supply chain from concentrations greater than 0.1% by weight (art. 33 REACH Regulation).
- Companies may be required to provide information about SVHC included in packaging.
Substances of Concern
The PPWR pursues the goal of keeping ‘Substances of Concern’ out of material loops. These are substances that cause problems in recycling processes, reduce the quality of recycled materials and give rise to health or environmental risks.
The European Commission will develop additional assessment methods and criteria over the next few years. One may assume that regulations on substance transparency and assessment will continue to be tightened in the future.
Packaging materials: Substance-based requirements
Substance-based requirements in the PPWR apply to all packaging and packaging components, regardless of material (including printing inks, pigments, UV varnishes, coatings, adhesive systems, barrier layers and additives in plastics). The relevant substance-related risks and test criteria differ by material class, however. The requirements for recyclability pursuant to Article 6 of the Regulation (EU) 2025/40 also apply for all materials (applicable from 1 January 2030).
Please note: According to article 6(3) PPWR, this effective date is conditional on the delegated act on the assessment methodology. The authoritative date is 1 January 2030 or a point in time 24 months after the act enters into force – whichever is later. As this legislation has not yet been finalised, the effective date may well be deferred.
Plastics
In terms of substances, plastic packaging is the most complex class of materials. Alongside base polymers (polyethylene, polypropylene, polyethylene terephthalate, polystyrene), additives such as plasticisers, antioxidants, UV/thermal stabilisers, slip agents, colourants and flame retardants must all be assessed. Residual monomers, solvent residues and substances included unintentionally (NIAS, non-intentionally added substances) must also be accounted for – including degradation and reaction products of additives or contaminants from recycled materials.
Plastic packaging with food contact
For plastic packaging with food contact, Regulation (EU) No 10/2011 also applies: This law specifies a ‘Union list’ of approved monomers and additives, as well as a total migration limit of 10 mg/dm² and substance-specific migration limits (SMLs). Conformity is documented by conducting migration tests or applying recognised modelling methods.
Use of recycled materials
Article 7(1) of Regulation (EU) 2025/40 states that plastic packaging must include the following minimum percentages of post-consumer recycled content from 1 January 2030:
- 30% for contact-sensitive packaging having polyethylene terephthalate (PET) as its primary component
- 10% for contact-sensitive packaging made from other plastics
- 30% for single-use plastic beverage bottles
- 35% for other plastic packaging Absatz 2 (u. a. Ausnahmen für Verpackungen von Arzneimitteln und Medizinprodukten). Für Rezyklate mit Lebensmittelkontakt sind ausschließlich Recyclingverfahren zulässig, die nach der Verordnung (EU) 2022/1616 zugelassen sind.
From 1 January 2040, these targets increase according to Article 7(2) (some exemptions apply to packaging for medicines and medicinal products). For recycled materials with food contact, all recycling methods used must have been approved in accordance with Regulation (EU) 2022/1616.
Please note: The effective date of 1 January 2030 is provisional according to Article 7(1) PPWR. This date applies only if the entry into force of the implementing act on the calculation and verification methodology is at least three years before this date. If not, the date is deferred accordingly.
From an analytical perspective, the test criteria for plastics are as follows:
- Total heavy metal content (100 mg/kg)
- SVHC screening according to REACH
- Migration testing for food contact
- NIAS analysis
- Traceability of material origin and the quality of the decontamination method (for materials containing recycled content)
Other classes of materials
- Paper and cardboard: Substance testing here focuses on fluorinated coatings (PFAS), mineral oil components (MOSH/MOAH) from recycled fibres and printing inks, wet-strength agents and adhesives.
- Glass: This material is largely chemically inert; heavy metals can primarily be introduced by decorations, pigments or printing.
- Metals (aluminium, tinplate): Inner coatings and paints are important here; for food contact materials, Regulation (EU) 2024/3190 on the prohibition of bisphenol must be observed.
- Composite materials: Such materials combine the substance-related risks for individual materials and have reduced recyclability: they should be prioritised for assessment for compliance with substance requirements and for recyclability under Article 6.
Material compliance roadmap for companies
1. Analyse the packaging portfolio and clarify responsibilities
- What kinds of packaging are being placed on the market?
- Which materials and components are being used?
- Who is responsible for the respective packaging within the supply chain?
- Which kinds of packaging are subject to special requirements (e.g. food contact)?
2. Obtain substance information from suppliers
Companies should ensure their suppliers are actively involved, and request information about the materials and substances used (e.g. material and product specifications, details of PFAS conformity, information about SVHC according to REACH, proof of compliance with heavy metal limits, details of recyclability and material composition).
3. Evaluate critical substance groups
- Does the packaging contain any critical substances (PFAS, heavy metals, SVHC, etc.)?
- Are there any duties to communicate information/notify?
- Can critical substances be substituted?
4. Assess risks in the supply chain
Not all packaging needs the same level of testing. A risk-based assessment helps to ensure testing is relevant.
- A greater level of risk is present in the case of imported packaging, complex material composites, recycled material of unknown origin, and packaging with a lot of printing, coatings and functional layers.
- A lower level of risk can be assured by the use of established suppliers, well-documented materials and standardised packaging systems.
5. Complete testing and analysis work
A lab analysis should be used in the following specific cases:
- Available supplier documentation is inadequate
- Materials used involve a higher level of risk
- Analysis is a regulatory requirement
- Doubts exist about the material composition
If a lab analysis needs to be carried out, Interzero is your competent partner. Our internationally accredited Competence Centre combines the very latest analysis methods with comprehensive domain expertise, ensuring the reliable evaluation of your packaging and full compliance with PPWR requirements.
6. Compile the technical documentation
Companies must document the following:
- which packaging has been evaluated
- which requirements have been reviewed
- which records of compliance are available
- which tests have been carried out and
- which decisions have been made.
This documentation must be available to demonstrate compliance to the authorities. Our online Check for Recycling tool provides you with all you need here. For more information on the topic, see PPWR documentation.
7. Optimise packaging as soon as possible
If problematic substances are identified, companies should check the following:
- Can a material be substituted?
- Can a coating be avoided?
- Are PFAS-free alternatives available?
- Can the design be made more recycling-friendly?
- Can supplier requirements be modified?
Our Packaging Optimisation Team is happy to advise you!
Who bears responsibility?
The manufacturer is primarily responsible for ensuring chemical and technical conformity. Their tasks include the conformity assessment, technical documentation, EU declaration of conformity and records of material conformity.
The PPWR marks a watershed in packaging law. Previously, conformity focused more on ensuring the chemical suitability of individual substances. The new regulation adopts a significantly more comprehensive approach, however, which addresses the circularity of the packaging across its entire life cycle. Companies should familiarise themselves with the (new) requirements as soon as possible – with the help and support of Interzero!
