PPWR: what the implementation of the European Packaging Regulation means for businesses
The European packaging regulation is no longer just a concern for material manufacturers. It now impacts procurement, product design, supplier monitoring, and waste management.
A European framework that is now operational
European Regulation 2025/40 on packaging and packaging waste, commonly known as the PPWR (Packaging and Packaging Waste Regulation), has been in effect in the European Union since August 12, 2026. It is gradually replacing the former framework based on the packaging directive and covers the entire lifecycle of packaging: design, placing on the market, use, and waste management.
Its goal is not just to reduce waste. The text also seeks to harmonize internal market rules, support the use of recycled materials, and strengthen packaging circularity. For companies that sell, import, use, or dispose of packaging, the issue goes beyond simple waste management. It also affects procurement, suppliers, product data, design, and customer relations.
The regulation is European and directly applicable. Therefore, it is not transposed like a directive into each Belgian region. However, the operational procedures related to waste, inspections, and industry sectors must still be coordinated with the relevant authorities in Wallonia, Brussels, and Flanders.
A first concrete deadline: PFAS in food-contact packaging
The most immediately tangible measure concerns per- and polyfluoroalkyl substances, or PFAS. Since August 12, 2026, packaging intended to come into contact with food may no longer be placed on the market if it contains PFAS at a concentration equal to or greater than the limits set by the regulation, unless another European provision already prohibits its placement on the market.
This provision specifically targets packaging designed to be water- or grease-resistant. It potentially affects takeout containers, food-grade paper, bakery packaging, or pizza boxes. The key takeaway for businesses is this: the analysis cannot be limited to the product purchased directly. It must trace back to the references used, suppliers, materials, and available compliance documentation.
The European Commission specifies that packaging placed on the market before August 12, 2026, may remain on the market. However, packaging placed on the market after this date must comply with the applicable limits. This distinction between the production date and the date of placement on the market should be verified in internal procedures, particularly for inventory and cross-border supply chains.
Compliance is driven by data and procurement
For a manufacturer, distributor, or user of packaging, the first step is to map the relevant flows. Which packaging is placed on the market in the European Union? What materials are used? Which suppliers can document the composition, recyclability, and potential presence of substances of concern? Which references are used for food contact?
This mapping then allows for the prioritization of checks. Food-contact packaging and imported products require special attention, but they are not the only ones affected. The PPWR introduces a broader framework for recyclability, labeling, waste prevention, reuse, and the integration of recycled materials, with staggered deadlines.
Data quality is therefore becoming a full-fledged environmental compliance issue. An incomplete supplier declaration, a misidentified reference, or a lack of traceability can complicate the demonstration of compliance, even when the material appears compatible with circularity goals at first glance.
Anticipating the next steps of the PPWR
The regulation takes effect on August 12, 2026, but not all obligations apply at the same time. The European Commission indicates that a harmonized packaging labeling system must be implemented starting August 12, 2028, to facilitate consumer sorting. Other measures for reducing packaging waste, limiting certain single-use plastic packaging, and promoting reuse and the use of recycled plastic are announced for 2030.
This gradual rollout is a reason to plan now. A company that waits for each deadline risks having to modify its packaging, procurement, and information materials on short notice. Conversely, an early review of references allows for the identification of potential substitutions, the request of missing supporting documents, and the integration of circularity criteria into future specifications.
There is also an economic stake. The PPWR aims to create a common framework for companies active in multiple European markets. Structured and reusable packaging data can be used for compliance, procurement, sustainability reporting, and circular economy initiatives. Regulatory constraints thus become a management tool rather than a reactive, one-off check.
What this means for you
If your company manufactures, imports, distributes, or uses packaging, the PPWR calls for a structured review of your flows. Start by identifying the packaging placed on the market in the European Union, food-contact uses, relevant suppliers, and available documentary evidence. Then, verify the application dates specific to the requirements that affect you and clearly distinguish between obligations already in effect and upcoming measures.
ABV Environment can help you turn this review into an action plan: mapping flows, analyzing available data, identifying key areas of concern, supporting the selection of more circular solutions, and integrating them into your environmental management system. The goal is simple: to secure your initiatives and ensure your decisions are backed by verifiable evidence.
