The Final PPWR Guidance in Plain English: What Actually Applies on 12 August 2026

There are 14 days until Regulation (EU) 2025/40 — the PPWR — starts applying to every piece of packaging placed on the EU market. On 30 March 2026, the European Commission published its final Guidance document and FAQon the PPWR. It’s the closest thing to an official answer key that exists, and it’s what national market-surveillance authorities will use when they come knocking.

The guidance runs long and reads like it was written by lawyers, for lawyers — because it was. Here’s what it actually says, in plain English, and what you need to have in place before 12 August.

The two obligations that bite on 12 August 2026

Most PPWR requirements phase in between now and 2038. Two apply immediately, with no grace period:

1. Substance limits — PFAS limits for food-contact packaging and heavy-metal limits for all packaging (Article 5, Annex II).
2. Conformity assessment + Declaration of Conformity — every packaging type placed on the EU market needs a completed conformity assessment (Article 38, Annex VII) and a signed EU Declaration of Conformity backed by technical documentation (Article 39, Annex VIII).

Everything else — recyclability grades, recycled-content quotas, harmonised labelling, reuse targets — comes later. But these two are live in August, and the guidance closes off the loopholes people were hoping for.

If a tool or supplier tells you recyclability grades or recycled-content quotas are due in August, they’ve confused the deadline — only the left column bites on 12 August 2026.

PFAS: the guidance confirms the strict reading

The PPWR caps PFAS in food-contact packaging at:

• 25 ppb for any individual PFAS (targeted analysis)
• 250 ppb for the sum of targeted PFAS
• 50 ppm for total PFAS, including polymeric PFAS

The guidance settles four questions that mattered a lot to anyone holding inventory:

• No sell-through period.Food packaging over the limits cannot be placed on the EU market after 12 August 2026. Stock you’ve already manufactured doesn’t get grandfathered in.
• The whole packaging unit counts — including inks, coatings, adhesives, and lacquers. A compliant substrate with a non-compliant coating fails.
• Intent is irrelevant. The limits apply whether PFAS was intentionally added or is unintentionally present.
• No exemption for recycled content. Packaging made from recyclate meets the same limits.

On testing, the guidance recommends a stepwise approach: screen for total fluorinefirst — if it’s under 50 ppm, the sample “could be considered compliant.” If not, use pyrolysis-GC/MS to separate organic from inorganic fluorine, and TOP analysis to check the 25/250 ppb limits. Helpfully, the Commission notes that every sample passing the total-fluorine screen has, on current evidence, also passed the deeper tests. There’s still no harmonised EU test method, but total-fluorine analysis is cheap and widely available — start there.

Substances of concern: no list, but a real obligation

Beyond PFAS and heavy metals, Article 5 requires that substances of concern (defined as in the ESPR) be minimized in all packaging. The FAQ confirms there is no definitive SoC list and no general concentration thresholds — but manufacturers must be able to objectively demonstrateminimization. Translation: “we didn’t check” is not a defensible position. Keep supplier declarations and material data on file.

The Declaration of Conformity: your August paperwork

From 12 August, every unique packaging type needs a signed DoC. Annex VIII specifies what it must contain:

1. A unique declaration number, traceable to the packaging type
2. Manufacturer name and address (and authorised representative, if any)
3. A statement that the DoC is issued under the manufacturer’s sole responsibility
4. Identification of the packaging (type, batch or serial reference)
5. A statement of compliance with the relevant PPWR requirements (Articles 5–12)
6. References to harmonised standards used, where applicable
7. A pointer to the technical documentation (Annex VII)
8. The conformity assessment procedure used (Module A — internal production control)
9. Translation into the language(s) of each Member State where the packaging is placed
10. Signature, with name, function, place, and date

Two useful clarifications from the guidance: where packaging falls under multiple EU acts, a single combined DoC is permitted as long as each act is clearly identified. And there can only be one “manufacturer”per packaging supply chain — the guidance spells out who that is and how “manufacturer” differs from “producer” (the EPR concept). If you buy packaging and put your product in it, read that section carefully before assuming the DoC is someone else’s problem.

One more sleeper: the 5% plastic rule

The guidance clarifies that packaging containing 5% or more plastic by weightcounts as single-use plastic packaging for the Annex V bans arriving in 2030 (labels, varnishes, paints, inks, adhesives, and lacquers excluded from the calculation). Paper cups and trays with plastic barrier coatings above that line are in scope. Below 5%, they’re not — a notable departure from the Single-Use Plastics Directive, which has no such threshold. If you’re specifying coated paper formats now, this number decides their 2030 fate.

What to do this month

• Inventory your packaging types. Each unique type needs its own conformity assessment and DoC.
• Get PFAS data for food-contact SKUs. A total-fluorine screen per material is the cheapest path to demonstrable compliance.
• Collect supplier declarations covering substances of concern and heavy metals.
• Draft your DoCs now — the Annex VIII elements above are mandatory content, not suggestions.

Sources: Commission Guidance document on the PPWR + FAQ (C/2026/3084); PPWR FAQ; Regulation (EU) 2025/40.