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

Updated 1 October 2026 · Free PDF at the end — no form, no email.

Since 12 August 2026, Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — has applied across all 27 EU member states. No national transposition. No grace period for stock placed on the market after that date.

If your packaging is not yet checked against the rules below, it is now a live compliance gap rather than a deadline. The checklist still works the same way; the order of urgency has simply moved up.

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.

The PPWR timeline at a glance

The regulation applies in stages. The dots below mark what already applies today and what comes next.

Two things are still open. The implementing acts on labelling and on the producer register are late, and the Commission's December 2025 simplification proposal, which would ease some obligations such as the authorised representative requirement, has not been adopted. Neither changes what applies today.

2026 vs 2030: what applies now and what can wait

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

What has applied since 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 PFAS, screened via total fluorine. If total fluorine is below 50 ppm, the 50 ppm limit is met, but the 25 ppb and 250 ppb limits still have to be confirmed by a targeted PFAS analysis.
• 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.
• Minimisation of substances of concern as a general obligation.

What does not apply yet: recyclability grades (2030), recycled content quotas for plastic (2030), harmonised labelling pictograms (the implementing act is still pending). Plan for them — but they are not today's problem.

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 since 12 August 2026 must comply — even if it was manufactured in 2025. Warehouse stock of non-compliant material can no longer enter the market.

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 fibre 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 — the 50 ppm limit is met; a targeted PFAS analysis then confirms the 25 ppb and 250 ppb limits. Above 50 ppm — further analysis is needed to show the fluorine is not from restricted PFAS.

One more quiet change: EN 13428 is now a stopgap

Many technical files lean on EN 13428:2004 (prevention by source reduction). The PPWR lets you keep using it until a new or updated harmonised standard is available (recital 60), but only as a stopgap: the PPWR’s own minimisation requirement (Article 10) applies from 1 January 2030, and its criteria (Annex IV) are stricter. Keep your EN 13428 file, and document your minimisation assessment against Annex IV so the new standard does not catch you out. Worth telling whoever maintains your packaging technical files — this one is easy to miss.

The checklist

Work through these three blocks. Block A is now overdue for anyone who has not done it — PFAS testing turnaround at accredited labs runs 4–8 weeks, so start it this week.

A. Materials — verify now

• 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, plus targeted PFAS analysis for the 25 ppb and 250 ppb limits
• 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; keep your EN 13428 file, but plan to update it against the PPWR minimisation criteria (Annex IV) before 2030
• 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 harmonised labelling implementing act — don't print label changes before the pictograms are final (August 2028 at the earliest)
• If replacing a structure anyway: qualify once, for both the PFAS limits 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 and 94/100 printed), which addresses the 2030 grade question in the same move as the PFAS one. What PAP 22 means, and when a coated paper can carry it.

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".