Today, several measures set out in the Packaging and Packaging Waste Regulation are officially enforced, and become legally binding. Here is everything you need to know about the new expectations, from the Declaration of Conformity to PFAS restrictions.
Declaration of Conformity
From today, businesses must provide a legally binding Declaration of Conformity (DoC) for every item of packaging they place on the EU market.
For an in-depth breakdown of the requirements, see Article 39 and Annex VIII of the Packaging and Packaging Waste Regulation – but in short, the DoC must prove that the packaging complies with the relevant legal requirements regarding recyclability, recycled content, reuse, minimization, empty space, and more.
Each format, material, and packaging configuration requires its own DoC. The documentation must include the manufacturer’s name and address, a sole responsibility statement, and a unique identification number for tracking.
A packaging identification section must cover the packaging’s type, material and batch or serial number, as well as a conformity statement referencing the legal text itself (specifically Articles 5 to 12) and a signature specifying the place and date.
Businesses may also refer to a specimen DoC, which Emission Core founder and CEO Adrian Reyes has walked us through.
Among other helpful advice, he emphasizes that an applicability matrix requires market operators to declare compliance as of the date of issue. This is intended to prevent over- or under-declaration of PPWR requirements, and Reyes warns that “if the matrix is wrong in any direction, the document is wrong.”
A new DoC must be created whenever the packaging is altered in such a way that it may impact legal conformity.
Substance restrictions
Under Article 5 of the PPWR, businesses may not distribute food-contact packaging on the EU market if it equals or exceeds the following concentrations of PFAS:
- 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification);
- 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors (polymeric PFAS excluded from quantification);
- 50 ppm ppm for PFASs (including polymeric PFAS); if total fluorine exceeds 50 mg/kg the manufacturer, importer or downstream user as defined respectively in Article 3, points (9), (11) and (13) of Regulation (EC) No 1907/2006 shall, upon request, provide to the manufacturer or the importer as defined respectively in Article 3(1), points (13) and (17), of this Regulation proof of the quantity of fluorine measured as content of either PFAS or non-PFAS in order for them to draw up the technical documentation as referred to in Annex VII to this Regulation.
The requirement has proven to be controversial. Back in April, several industry CEOs requested that the European Commission push back the application date until technical, legal, and methodological concerns were ironed out – a sentiment that other industry players disagreed with.
A coalition of wholesalers and retailers led by EuroCommerce also called for a twelve-month transition period in which businesses would not be penalized for adjusting to new legal expectations, including PFAS restrictions. Neither call has come to fruition.
A Commission Notice published in June 2026 explained that there is no harmonized methodology for calculating PFAS in food packaging at the EU level, instead recommending a stepwise approach of total fluorine quantification and direct total oxidizable precursors analysis.
Yet it went on to clarify that packaging that exceeds the PFAS limit but was produced before 12 August 2026 does not need to be withdrawn from the market.
In a recent Frequently Asked Questions document, the Commission also specified that “the minimization of dangerous substances or preparations and demonstrations of conformity” under EN 13428:2004 could “no longer create a presumption of conformity” after 12 August 2026.
This is because it does not account for the PPWR’s focus on holistic lifecycle impacts such as reuse, recycling and chemical safety, rather than end-of-life disposal alone; nor does it account for the PPWR’s expanded hazard scope.
The FAQ document states that “until the updated harmonized standard becomes available, the existing standard EN 13428:2004 can be used.”
Recyclability
As of today, Article 6(1) of the PPWR also applies: “All packaging placed on the market shall be recyclable.”
This means that it is designed for recyclability, using secondary raw materials of comparable quality to their primary counterparts. It must also be separately collected, sorted into specific waste streams without contaminating them, and recycled at scale.
Yet the Commission is not required to produce design for recycling criteria until 1 January 2028 at the latest. Until it does, Adrian Reyes states that businesses can refer to EN 13430 and the Packaging and Packaging Waste Directive’s framework to gauge their compliance with Article 5’s substance restrictions.
Commenting on the new measures as a whole, Commissioner for Environment, Water Resilience and a Competitive Circular Economy Jessika Roswall states: “The new Packaging and Packaging Waste Regulation is an investment in Europe’s future: it will help reduce waste, increase recycling, make food-contact packaging safer for the consumers by limiting harmful substances such as PFAS, and reduce our dependence on virgin raw materials. These are essential steps towards a truly circular economy.
“At the same time, the Regulation will replace fragmented national rules difficult to navigate for economic operators in the internal market. But new rules also come with adjustment costs, and we have worked intensively with market operators to implement the new rules in a pragmatic and unbureaucratic way.”
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