PPWR Compliance Checklist: What Food Brands Must Have in Place by 12 August 2026

Updated 7 July 2026 · Free PDF at the end — no form, no email.

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In five weeks, Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — becomes generally applicable across all 27 EU member states. No national transposition. No grace period for new stock.

We are not lawyers, and this is not legal advice. We are a packaging converter, and for the past two years the PPWR has shaped almost every material conversation we have with food brands. This checklist is the engineering side of compliance: what to verify, what to ask your suppliers, and what can safely wait.

First, clear up the 2026 vs 2030 confusion

Most of the PPWR headlines are about 2030: recyclability performance grades A, B and C, recycled content targets for plastic packaging, harmonized sorting labels. Those matter — but they are not what changes on 12 August 2026.

What applies from 12 August 2026:

• PFAS restriction in food-contact packaging. Three thresholds: 25 ppb for any individual non-polymeric PFAS, 250 ppb for the sum of non-polymeric PFAS, and 50 ppm total fluorine. If total fluorine is below 50 ppm, the packaging is considered compliant — no further testing needed.
• Heavy metals limit. Lead, cadmium, mercury and hexavalent chromium: max 100 mg/kg combined. Carried over from the old Packaging Directive.
• Declaration of Conformity. Every packaging type placed on the EU market needs one, backed by technical documentation. If your brand name is on the packaging, the obligation may sit with you, not your converter.
• Operator identification. Manufacturer (and importer, where relevant) name and postal address on the packaging.
• EPR registration in every member state where you place packaging on the market for the first time.
• Minimization of substances of concern as a general obligation.

What does not apply yet: recyclability grades (2030), recycled content quotas for plastic (2030), harmonized labelling pictograms (being defined in implementing acts). Plan for them — but don't panic about them in August.

The point most brands haven't checked: PFAS in barrier papers

Here is the uncomfortable part for anyone buying grease-resistant or moisture-resistant paper packaging.

Fluorochemistry was the industry's default answer to grease resistance for decades. Compliance consultants now classify barrier-coated and grease-resistant papers as the highest-risk category for PFAS content. And the PPWR restriction has three properties that make it unusually strict:

No grandfathering. Packaging placed on the EU market after 12 August 2026 must comply — even if it was manufactured in 2025. Existing warehouse stock of non-compliant material cannot enter the market after the date.

The whole packaging unit counts. Compliance is assessed for the unit as a whole, including inks, varnishes, glues and adhesives. A PFAS-free paper with the wrong varnish fails.

Intent is irrelevant. The limits cover both intentionally added and non-intentionally present PFAS. Recycled fiber is a known carrier. "We never added it" is not a defence.

One more thing that surprises procurement teams: a supplier's self-declaration does not constitute proof. Market surveillance expects Certificates of Analysis from accredited laboratories, per packaging type. A test report for one structure is not valid proof for a different grammage, coating or laminate.

The practical screening path is simpler than it sounds: start with total fluorine (TF) analysis. Below 50 ppm — compliant, done. Above 50 ppm — further analysis is needed to show the fluorine is not from restricted PFAS.

One more quiet change: EN 13428 loses its safe-harbour status

Many technical files lean on EN 13428:2004 (prevention by source reduction) as presumption of conformity. From 12 August 2026, it no longer provides that presumption under the PPWR. Until updated harmonized standards arrive, your Declaration of Conformity has to stand on its own technical documentation. Worth telling whoever maintains your packaging technical files — this one is easy to miss.

The checklist

Work through these three blocks. Realistically, block A is a this-month job — PFAS testing turnaround at accredited labs runs 4–8 weeks, and the queue is growing.

A. Materials — verify before 12 August

• List every food-contact packaging type you place on the EU market (per structure, not per SKU)
• Flag the Tier 1 PFAS risks: grease-resistant papers, barrier coatings, laminates
• Request total fluorine (TF) data from every supplier of flagged structures — accredited lab, per packaging type
• Where TF exceeds 50 ppm, request evidence of PFAS vs non-PFAS origin — or start qualifying an alternative material now
• Confirm inks, varnishes and adhesives are covered by the data, not just the substrate
• Verify heavy metals documentation (≤100 mg/kg Pb+Cd+Hg+Cr VI)

B. Documentation — build the file

• Determine your economic operator role per packaging type (manufacturer, producer, importer, distributor) — it defines who issues the Declaration of Conformity
• Collect or issue Declarations of Conformity for every packaging type
• Assemble technical documentation behind each DoC; stop relying on EN 13428 as presumption of conformity
• Check operator identification on packaging: name, trade name, postal address
• Confirm EPR registration in every member state where you first place packaging on the market

C. Horizon — decide, don't rush

• Map your portfolio against 2030 recyclability grades (A ≥95%, B ≥80%, C ≥70% recyclability) — grade will drive EPR fee modulation
• For plastic packaging: note recycled content targets from 2030; plastic parts under 5% of unit weight are exempt (inks, paints and adhesives do not count as plastic)
• Watch the harmonized labelling implementing acts — don't print label changes before the pictograms are final
• If replacing a structure anyway: qualify once, for both the PFAS deadline and the 2030 grades — not twice

Where paper mono-material fits — and where it doesn't

Our position in this is straightforward. We engineer heat-sealable barrier papers with water-based coatings — grease and moisture resistance built without fluorochemistry. Our PAP 22 mono-material structures are PTS-tested for recyclability (our reference structure scores 99/100 unprinted), which addresses the 2030 grade question in the same move as the 2026 PFAS one.

Honest limits, because that is how we work: paper is not the answer for every product. High oxygen-barrier applications and wet or fatty products with long shelf life may still need structures we would not recommend paper for. When a customer's product doesn't fit, we say so — it saves everyone a failed line trial.

But for dry foods, tea, cutlery, confectionery and similar flow-wrap and envelope applications, a PAP 22 structure typically resolves the PFAS question, the recyclability grade question and the EPR fee question with one material decision.

Get the checklist — and one concrete offer

[Download the PDF checklist] — free, no form, no email. Print it, hand it to procurement, mark it up.

And if you want the fast answer instead of the homework: email us your current packaging structure (material, grammage, what it packs, your line type — HFFS/VFFS/other) and we will tell you within 48 hours whether a PFAS-free recyclable paper structure is realistic for your application. If it isn't, we will tell you that too.

info@leoprint.eu — subject line "PPWR check".