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.
Key aspects include:
- compliance with limit values
(heavy metals and PFAS compounds) - a clear and comprehensive declaration of conformity
- up-to-date technical documentation
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2026 that does not comply with these requirements may still be sold until stocks are depleted and does not need to be withdrawn from the market.
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
The manufacturer may prepare a single company-level declaration, provided it specifies:
- which packaging is covered
→ identified, for example, by type, batch, or serial number - packaging types
→ classified according to Annex II
Key responsibilities of the Manufacturer
- Carry out a conformity assessment of packaging before placing it on the market
- Prepare technical documentation and the declaration of conformity
- Retain documentation; single-use packaging: 5 years and reusable packaging: 10 years
- Ensure continued compliance in serial production
- Take immediate action if packaging does not meet requirements
- Provide requested information to authorities
- Fulfil extended producer responsibility (EPR) obligations