EU Packaging Regulation (PPWR) Countdown: PFAS Restrictions Take Effect in August

On March 30, 2026, the European Commission released the final guidance document and accompanying Frequently Asked Questions (FAQ) for the Packaging and Packaging Waste Regulation (PPWR), providing compliance guidance for EU member states and economic operators.

Background

The PPWR officially entered into force on February 11, 2025, replacing the Packaging and Packaging Waste Directive (94/62/EC) that had been in place for nearly 30 years. Unlike the previous directive, the PPWR applies directly to all member states as an EU regulation without requiring individual transposition by each country. The regulation will become universally applicable from August 12, 2026.

Main Contents of the Guidance Document

I. Key Definitions

Definition	Definition Explanation
Packaging	Items used to contain, protect, handle, deliver, or present products must meet criteria regarding function, material, and design
Packaging Manufacturer	Not necessarily the actual producer, but the natural or legal person who "orders and determines the specifications of the packaging design"; brand owners are generally considered manufacturers
Packaging Producer	Manufacturers, importers, or distributors who first place packaging or packaged products on the market within a member state are responsible for extended producer responsibility (EPR)
Importer	Must be established within the EU (with independent legal personality); branches cannot serve as importers

II. Compliance Deadlines

Date	Requirement
August 12, 2026	Universal application of the regulation; PFAS restrictions take effect (food contact packaging)
February 12, 2028	Compostable packaging requirements take effect; Commission will request development of home composting standards
August 12, 2028	Harmonized packaging labeling requirements take effect
January 1, 2029	Deposit return systems (DRS) must be established to achieve 90% separate collection rate
February 12, 2029	Reusable packaging labeling requirements take effect
January 1, 2030	Packaging minimization requirements, empty space ratio requirements, reuse targets, packaging bans, and other core requirements take effect; Recyclability design requirements take effect (or 24 months after entry into force of relevant delegated acts, whichever is later)
January 1, 2035	Large-scale recycling requirements take effect

III. PFAS Restrictions (Effective August 12, 2026)

Any single PFAS: ≤ 25 ppb (excluding polymeric PFAS)
Sum of PFAS: ≤ 250 ppb (degradable precursors)
All PFAS (including polymers): ≤ 50 ppm; if total fluorine > 50 mg/kg, proof must be provided

Commission Interpretation

Recommended Stepwise Approach for PFAS Testing

Step	Testing Content	Compliance Criteria
Step 1	Quantification of Total Fluorine (TF)	TF < 50 mg/kg → deemed compliant
Step 2	If TF exceeds limit, use pyrolysis-GC/MS or similar methods to confirm whether fluorine is organic fluorine (PFAS)	Organic fluorine < 50 mg/kg → deemed compliant
Step 3	Direct TOP (Total Oxidizable Precursor) analysis	Check compliance with 25 μg/kg and 250 μg/kg limits

Note: Current evidence shows that samples passing Step 1 testing typically also meet Step 2 and Step 3 requirements.

Stock Depletion (No Transition Period)

Scenario	Treatment
Packaging placed on the market before August 12, 2026	May remain on the market without withdrawal
Packaging placed on the market after August 12, 2026	Must comply with PFAS limits; no stock transition period
Packaging containing recycled materials	No exceptions; same rules apply

Key Time Point Determination
- Sales packaging and grouped packaging: Generally deemed placed on the market when filling is completed (final processing steps such as sealing may affect compliance)
- Transport packaging and service packaging: Generally placed on the market in empty packaging state
- Imported packaging: Time point is determined by release for free circulation upon completion of customs procedures

IV. Relationship with Existing Regulations

With Single-Use Plastics Directive (SUPD): The PPWR takes precedence over SUPD regarding packaging bans, but both regulations coexist; SUPD continues to apply to single-use plastic products not covered by PPWR bans
With the old Packaging Directive (94/62/EC): The PPWR replaces the old directive, but some existing standards and requirements may still serve as guidance until the new regulation is fully applicable

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branches in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

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Further Information

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