On 22 January 2025, the European Union officially published Regulation (EU) 2025/40 on packaging and packaging waste (Packaging and Packaging Waste Regulation, "PPWR"). It will apply from 12 August 2026 and fully replace the existing Directive 94/62/EC, becoming the EU's principal legislation governing packaging and packaging waste management.

The PPWR systematically integrates requirements on substance restrictions, recycled content, recyclability performance grading (grades A–C) and packaging reduction targets, establishing a full life-cycle management framework for packaging. For the first time in the packaging sector, it elevates recycled content from an indicative target to a mandatory requirement, and sets out detailed, phased targets differentiated by plastic packaging type. The specific requirements are as follows.

■ Requirements relating to substances in packaging (Article 5)

Restriction of heavy metal content: Identical to the requirements laid down in Directive 94/62/EC; applicable since 11 February 2025.

The sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium present in packaging shall not exceed 100 mg/kg. Products within the scope of the Regulation must continue to comply with the requirements set out in Annex XVII to Regulation (EC) No 1907/2006 (REACH) or in Regulation (EC) No 1935/2004 on food contact materials (FCM) and articles.

New restriction on PFAS in food-contact packaging, applicable from 12 August 2026:

• Any individual PFAS: below 25 ppb (excluding polymeric PFAS);
• Sum of individual PFAS substances: below 250 ppb (excluding polymeric PFAS);
• Sum of all PFAS substances: below 50 ppm (including polymeric PFAS).

Where the total fluorine content exceeds 50 ppm, the manufacturer or importer shall provide downstream operators with evidence of the fluorine content present, indicating whether it derives from PFAS or from non-PFAS substances.

■ Recyclability of packaging (Article 6)

All packaging placed on the market shall be recyclable, and the Regulation lays down phased targets for achieving packaging recyclability. From 1 January 2030, only packaging that achieves a recyclability performance grade of C or above may be placed on the market; from 1 January 2038, this minimum requirement will be raised to grade B.

Tables 1 and 2

(The European Commission shall, by 1 January 2028, adopt delegated acts establishing the "design for recycling" criteria and the criteria for recyclability performance grades.)