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PPWR – Restricted substances and Declaration of Conformity

 

PPWR restricts the use of hazardous substances in packaging and requires manufacturers to demonstrate compliance through documented evidence by preparing an EU Declaration of Conformity (EU DoC).

PPWR Webinar Materials 

You can access presentation materials from the PPWR webinar held on 29 September 2026 here. The page also includes answers to questions asked during the webinar. 

You can also find the materials from the PPWR in Practice webinar held in spring 2026 via this link.

View materials

PPWR-webinaari-29-9-2026
 

Restricted substances in packaging 

 

Heavy metals in all packaging

The combined concentration of the following substances present in packaging or its components must not exceed 100 mg/kg:

  • lead
  • cadmium
  • mercury
  • hexavalent chromium

PFAS compounds (per- and polyfluoroalkyl substances) in food contact packaging

From 12 August 2026, packaging that comes into contact with food must not be placed on the market if it contains PFAS compounds above the following limits:

  • 25 ppb for an individual PFAS substance
  • 250 ppb for the sum of PFAS substances (targeted analysis)
  • 50 ppm for total PFAS (including polymeric PFAS)

Additionally, if the total fluorine content of the packaging exceeds 50 mg/kg, operators must be able to demonstrate the source of the fluorine (PFAS vs. other substances) for technical documentation purposes.

Packaging placed on the market before 12 August 2026 that does not comply with these requirements may still be sold until stocks are depleted and does not need to be withdrawn from the market.  Please note – the date the packaging was placed on the market must be taken into account! 

 

Declaration of Conformity 

 

The Manufacturer must demonstrate that the packaging meets the applicable requirements by preparing an EU Declaration of Conformity.

During the transitional phase (from 12 August 2026), the declaration applies only to Article 5: Restricted substances, including:

  • heavy metal limits
  • PFAS restrictions in food contact materials
  • packaging recyclability and minimisation requirements are already included in the Packaging Directive (in force until 2029) – the PPWR implementing legislation will be adopted later. 

The EU Declaration of Conformity must follow a specific format

  • template provided in Annex VIII 
  • subject of the declaration: unique identifier and description of the packaging 
  • manufacturer’s details 
  • references to legislation, standards and technical documentation 

EU DoCs must be retained 

  • single-use packaging: 5 years
  • reusable packaging: 10 years 
  • the documents must be provided to the authorities upon request
The EU DoC is based on technical documentation provided by the manufacturer.
PPWR - Technical Documentation

Finnish Packaging Association – PPWR interpretation guide and EU DoC template 

 

Declaration of Conformity – guidance and template (in Finnish)