PPWR checklist: what to do before 12 August 2026

Why this is urgent

Regulation (EU) 2025/40 (PPWR) applies on 12 August 2026 across the EU. For the PFAS ban in food-contact packaging there is no transition period — anything placed on the market after that date must comply, even if it was manufactured earlier. A PFAS panel takes two to six weeks, so the window to test and, if needed, reformulate is closing.

The checklist

• +Map your packaging in scope — every food-contact pack, layer and component sold in the EU.
• +Collect a Declaration of Conformity from each packaging supplier. If your brand or name is on the pack, you must issue the DoC yourself.
• +Lab-test for PFAS — a supplier statement is not proof. Limits: ≤25 ppb for any single PFAS, ≤250 ppb for the sum. Allow two to six weeks.
• +Test heavy metals — sum of Pb+Cd+Hg+Cr(VI) ≤ 100 mg/kg, by ICP-MS, per material.
• +Replace or reformulate any packaging that fails — before 12 August 2026, not after.
• +Register with national EPR (extended producer responsibility) systems in each relevant Member State.
• +Keep the test data and the Declaration of Conformity on file — enforcement can ask for the evidence, not just the statement.

What comes later (so you can plan)

Some PPWR obligations land after the August 2026 deadline: harmonised recycling labelling from 12 August 2028, and recyclability performance grades and recycled-content targets from 2030. The Commission is due to publish the labelling technical specifications by 12 August 2026.

What it costs

The core PFAS + heavy-metals package is indicatively from €250 net per material, rising with the number of materials, layers and components. Use the calculator to scope your portfolio, or see the PPWR cost page.