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The European Commission’s official FAQ on the Packaging and Packaging Waste Regulation (PPWR) -Regulation (EU) 2025/40 - provides important clarification on how substances of concern (SoC) in packaging will be regulated from August 2026 onward.
The PPWR requirements strengthen efforts to reduce harmful substances in packaging and packaging waste, while also supporting safer recycling and circularity practices across the EU.
What Qualifies as a Substance of Concern?
The PPWR adopts the ESPR-based definition for substances of concern. According to the Commission FAQ, a substance can qualify if it meets any one of the listed conditions - the criteria are not cumulative.
This includes:
- Substances identified under REACH Article 57 (REACH substances of very high concern). Click Here to know more about REACH SVHC
- Substances classified under relevant CLP hazard classes
- Substances regulated under Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POP)
- Substances that negatively affect the reuse or recycling of materials
- Other conditions covered under the ESPR SoC framework
This broader definition expands compliance obligations beyond traditional packaging restrictions and places greater emphasis on recyclability and circular material flows.
Key PPWR Changes Effective from 12 August 2026
Several major obligations under PPWR become applicable from 12 August 2026.
Obligation to Minimise SoC
Packaging must be manufactured so that the presence and concentration of substances of concern are minimised.
Heavy Metal Limits
Specific limits continue to apply for the four heavy metals in packaging:
- Lead
- Cadmium
- Mercury
- Hexavalent chromium
PFAS Restrictions in Packaging
PFAS limits for food-contact packaging also apply from the same date.
Importantly, the FAQ confirms that the PFAS restriction covers both:
- Intentionally added PFAS
- Unintentionally present PFAS
This clarification on food packaging PFAS is particularly relevant for companies using recycled materials, coatings, inks, adhesives, or complex packaging structures where unintended PFAS contamination may occur.
No Universal SoC Limit Under PPWR
The Commission also clarifies that PPWR does not establish one universal concentration limit for all substances of concern.
Instead:
- Specific limits apply to PFAS
- Specific limits apply to the four heavy metals
- Other SoC obligations focus on minimisation and conformity requirements
As a result, EU packaging compliance cannot rely on a single threshold-based approach. Businesses will need stronger packaging data management, supplier coordination, and technical documentation processes.
Supplier and Manufacturer Responsibilities
Under Article 16 of PPWR, suppliers must provide manufacturers with the information necessary to demonstrate conformity.
Manufacturers placing packaging on the EU market are responsible for using this information to:
- Identify substances of concern
- Assess compliance
- Prepare the EU PPWR Declaration of Conformity
This makes supply chain transparency and documentation critical to PPWR readiness.
Important Update on EN 13428:2004
The FAQ also states that Annex C of EN 13428:2004 can no longer create a presumption of conformity after 12 August 2026, as it does not reflect the broader SoC scope introduced under PPWR.
Companies relying on older packaging compliance frameworks may therefore need to reassess their conformity procedures and supporting documentation.
Preparing for PPWR Compliance
With the 2026 deadline approaching, the EU PPWR compliance steps for businesses
include:
- Reviewing packaging portfolios for SoC exposure
- Assessing PFAS risks
- Strengthening supplier documentation processes
- Improving packaging data visibility
- Updating conformity assessment procedures
The PPWR FAQ makes it clear that substances of concern compliance is no longer just a chemical restriction issue; it is also a packaging data, traceability, and supplier documentation challenge.
Organisations that act early will be better positioned to mitigate compliance risks and maintain seamless access to the EU market. Preparing for PPWR compliance? Connect with Freyr to assess packaging risks, strengthen supplier documentation, and stay ahead of August 2026 requirements.
