Since 12 August 2026, every piece of packaging placed on the European Union market has been subject to an entirely new regulatory framework. The Packaging and Packaging Waste Regulation (PPWR) has replaced the old directive and introduced rules that go beyond waste disposal. They directly affect the design, composition and documentation of every pack. For food manufacturers, this is not a compliance issue that can be postponed. It is a change that begins at the drawing board, long before the first box reaches the production line.
What Has Actually Changed
Until now, packaging rules mainly dealt with what happens after the consumer throws the pack away. The new regulation shifts the perspective and introduces binding requirements for all operators in the chain, including manufacturers, importers and distributors, regardless of whether they are based inside or outside the EU. The focus is on preventing waste, increasing recyclability and reducing the presence of hazardous substances in materials that come into contact with food. What makes this change demanding is the fact that a large part of the obligations applies immediately, while certain requirements will be phased in until 2040.
PFAS and Heavy Metals Are No Longer Voluntary
The most concrete and urgent part of the new regulation concerns substances of concern. Since August 2026, food-contact packaging must not contain PFAS above strictly defined limits. The threshold is 25 parts per billion for any single PFAS, 250 parts per billion for their sum, and 50 parts per million for total content including polymeric PFAS. In addition, a combined limit has been introduced for lead, cadmium, mercury and hexavalent chromium, whose total concentration must not exceed 100 milligrams per kilogram.
These limits hit paper and board hardest. Fluorinated coatings were used for years to give paper grease and water resistance, and they now must be replaced by alternatives that deliver the same performance without prohibited substances. Manufacturers who relied on traditional coatings face the need to qualify new solutions quickly, as the compliance deadline has not been moved.
Recycled PET Gets New Rules from 18 November
Alongside the PPWR, an amendment to the regulation on recycled plastics in food contact is also entering into force. From 18 November 2026, importers of certain categories of recycled PET must present a declaration of compliance to customs authorities when requesting release for free circulation. Two new types of declarations, designated P and C, are being introduced to track the origin, composition and supply chain of recycled material.
This is not just an administrative hurdle. For manufacturers of beverages and food products using recycled PET, documentation becomes part of operational risk. Without the appropriate declaration, a shipment can be stopped at the border, regardless of how good the material itself is.
What This Means for Material Selection
The new rules do not favour any material in advance. They set a framework within which every material must prove that it is safe, recyclable and documented. For paper and board, the key challenge is PFAS-free coatings and proving that the fibres remain recyclable. For plastics, the focus is on recycled content and design for recycling, with recyclability grades from A to C introduced in 2030, and packaging below grade C no longer allowed on the market. For aluminium and glass, the advantage is that they are already highly recyclable, but they too must meet substance and documentation requirements.
In practice, material choice is no longer just about cost or appearance. A manufacturer must consider whether the material can be recycled in existing infrastructure, whether it contains substances that will disqualify it, and whether a complete technical file can be provided for every batch.
What Food Manufacturers Should Do Now
The first step is to review documentation. Every packaging item placed on the market must have a technical file and a declaration of conformity, and the manufacturer whose name appears on the pack is the one who signs that declaration and bears responsibility. The second step is testing for PFAS and heavy metals, because compliance cannot be assumed on the basis of a supplier’s declaration. The third step is a conversation with packaging suppliers about how their materials will perform in light of the new requirements for recyclability and recycled content.
Nutra monitors regulatory changes affecting the food industry and can help you understand how the new rules reflect on your products and your suppliers. Contact us for advice tailored to your needs.