From 12 August 2026, Regulation (EU) 2025/40 makes two obligation sets binding for packaging sold into the EU: the substance limits of Article 5, including food-contact PFAS thresholds and a 100 mg/kg heavy-metals limit, and the conformity file plus EU Declaration of Conformity. Recyclability grading, recycled content and the harmonised label are readiness steps ahead of 2028 and 2030.
What is binding from 12 August 2026
Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, applies from 12 August 2026 and replaces Directive 94/62/EC. It covers all packaging placed on the EU market regardless of the material and regardless of whether it originates inside or outside the EU. Two obligation sets take effect on that date, and only these two are actual 12 August 2026 obligations.
- Substance limits under Article 5: food-contact packaging may not be placed on the EU market with PFAS at or above 25 ppb for any single substance by targeted analysis, 250 ppb for the sum, or 50 ppm total fluorine including polymeric PFAS; and the summed concentration of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg.
- The conformity file: the manufacturer runs the internal production control procedure (Annex VII, Article 38), holds the technical documentation, and draws up the EU Declaration of Conformity to the Annex VIII model (Article 39), kept available for authorities.
The six-step checklist
| Step | Action | When it bites |
|---|---|---|
| 1. Inventory packaging | List every pack by material and weight | Groundwork now |
| 2. Control substances | Meet the Article 5 PFAS and 100 mg/kg heavy-metals limits | Binding from 12 August 2026 |
| 3. Document and declare | Build the Annex VII conformity file and Annex VIII Declaration of Conformity | Binding from 12 August 2026 |
| 4. Grade recyclability | Grade each pack A, B or C | Readiness for 1 January 2030 |
| 5. Set recycled content | Plan post-consumer recycled content per plastic part | Readiness for 1 January 2030 |
| 6. Place the producer and label | Draw the producer line and prepare the harmonised label | Label from 12 August 2028; producer register per Member State |
What to ready ahead of 2028 and 2030
The harmonised, pictogram-based material-composition label becomes mandatory from 12 August 2028 (Article 12(1)). Recyclability grades A, B or C are required from 1 January 2030 (Article 6(3)), and minimum recycled content per plastic part applies from 1 January 2030 (Article 7). For an Indian exporter selling B2B to an EU importer, the importer is the producer under Article 3(15) and carries the national producer register and recycled-content duties, while the supplier prepares the data and conformity evidence. The EU PPWR solutions service maps the packaging, draws the producer line and assembles the conformity file, technical documentation and Declaration of Conformity for the producer to rely on, since the manufacturer self-declares under internal production control rather than through a third-party certificate. The EU PPWR guide walks the six steps in detail, and the PPWR discovery brief scopes the packaging portfolio against the staged dates.
Sources: Regulation (EU) 2025/40 (EUR-Lex) · European Commission, Packaging waste · European Commission, PPWR FAQ