European food producers and packaging manufacturers face a major problem: compliance with EU Regulation 10/2011 or the PPWR does not transfer to the US, Japan or China, where divergent positive lists, extraction tests and migration limits require separate regulatory assessment.
Under the PPWR, private label operators whose name or trademark appears on packaging are classified as the manufacturer, bearing full responsibility for technical documentation, Declaration of Conformity and EPR registration in each Member State.
The PPWR’s minimisation, recyclability and substance restriction requirements now directly constrain packaging design decisions, while EPR fee modulation turns these technical choices into measurable financial consequences.
Biobased, biodegradable and compostable are often used interchangeably but describe three unrelated material properties. The PPWR addresses biobased feedstock and compostability separately under Articles 8 and 9, making the distinction a practical compliance question.
The summer of 2026 brings a series of compliance deadlines for food contact materials. From 16 September 2026, the EU 10/2011 amendments on substance purity, NIAS characterisation and supply chain documentation apply in full.
The bisphenol restriction under Regulation (EU) 2024/3190 applies from 20 July 2026 and PPWR Article 5 chemical requirements follow on 12 August 2026, with both demanding analytical verification.
Design for recycling flexible packaging EU: Full guide on PPWR rules, recycled content targets, EPR impact and compliance guidance.
Detailed guidance on PPWR 2026 requirements for PFAS and heavy metals in food contact packaging, including limits, testing and compliance steps.
Explore key packaging regulations 2025 worldwide, from EU PPWR and BPA bans to EPR and food contact rules impacting global compliance.
A practical overview of migration testing for plastic food-contact materials in the EU, explaining the relevant regulatory limits under specific regulations.
Since its publication in the Official Journal on 22 January 2025, Regulation (EU) 2025/40 (“PPWR”) has set a clear, phased timeline to transform packaging across the EU into sustainable, circular‐economy–friendly materials. From strict chemical limits and the first reusable packaging standards to binding recycled‐content…