2025
Reusable packaging
Article 11(1) establishes that, from 11 February 2025, packaging placed on the market shall be considered to be reusable where it fulfils all requirements listed in Article 11(1).
2026
Substances in packaging
Article 5(4) establishes that, from 12 August 2026, the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg.
Article 5(5) mandates that, from 12 August 2026, food contact packaging shall not be placed on the market if it contains PFAS in a concentration of or above certain given limits, notably:
(a) 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification);
(b) 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors (polymeric PFAS excluded from quantification); and
(c) 50 ppm for PFASs (including polymeric PFAS); if total fluorine exceeds 50 mg/kg the manufacturer, importer or downstream user as defined respectively in Article 3, points (9), (11) and (13) of Regulation (EC) No 1907/2006 shall, upon request, provide to the manufacturer or the importer as defined respectively in Article 3(1), points (13) and (17), of this Regulation proof of the quantity of fluorine measured as content of either PFAS or non-PFAS in order for them to draw up the technical documentation as referred to in Annex VII to this Regulation.
Please note that point 5 of the PPWR Guidance and Section III of the PPWR FAQ document provide helpful guidance on this provision.
2028
Compostable packaging
Article 9(2) mandates that, by 12 February 2028, packaging referred to in Article 3(1), point (1)(f) of PPWR and sticky labels affixed to fruit and vegetables to be compatible with the standard for composting in industrially controlled conditions in bio-waste treatment facilities and shall be compatible, where required by the Member States, with the home-composting standards referred to in paragraph 6 of Article 9.
Article 9(3) establishes that, by 12 February 2028, packaging other than that referred to in paragraphs 1 and 2, including packaging made of biodegradable plastic polymers and other biodegradable materials, shall be designed for material recycling in accordance with Article 6 without affecting the recyclability of other waste streams.
Please note that point 10 of the PPWR Guidance and Section VI of the PPWR FAQ document provide helpful guidance on these provisions.
2008
Packaging labelling (WSL and other labels)
Article 12(1) establishes that, from 12 August 2028 or 24 months from the date of entry into force of the relevant implementing acts, packaging placed on the market shall be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting (*).
Article 12(1) also foresees that packaging subject to deposit and return systems as referred to in Article 50(1) of PPWR, shall be marked with a clear and unambiguous label. In addition to the national label, packaging may be marked with a harmonised colour label established in the relevant implementing act adopted pursuant to Article 12(6).
Article 12(4) foresees that, from 12 August 2028 or 24 months from the date of entry into force of the relevant implementing act, whichever is the latest, packaging is marked with a label containing information on the share of recycled content. That label and, where applicable, the QR code or other digital data carrier shall comply with the specifications laid down in the relevant implementing act and be based on the methodology established pursuant to Article 7(8). Where packaging is marked with a label containing information on the share of biobased plastic content, that label shall comply with the specifications laid down in the relevant implementing act adopted pursuant to paragraph 6 of Article 12.
A clause on exhaustion of stocks is also foreseen under Article 12(12) and further specifications on how to display labels, QR codes or other standardised, open, digital-marking technology are also given under Article 12.
Please note that Section VIII of the PPWR FAQ document provide helpful guidance on these provisions.
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