The projects to start
now

The PFAS ban in food-contact packaging applies from 12 August 2026, with no grace period and no right to sell down existing stock. It is the only immediate, non-negotiable material obligation under the PPWR. It covers all food packaging with grease-resistant or moisture-resistant coatings or surface treatments. Examples: baking papers, coated cardboard trays, fast-food packaging, certain packaging films, microwaveable packaging.

• 1. Full mapping of food packaging with a coating or surface treatment
• 2. Collection of supplier technical sheets with a certificate confirming the absence of PFAS
• 3. Where no certificate is available: testing following the Commission guidance's three-tier methodology (total fluorine → pyrolysis GC/MS → TOP analysis)
• 4. Replacement of non-compliant suppliers before 12 August 2026

The PPWR requires a declaration of conformity and technical documentation for every packaging format placed on the EU market, from 12 August 2026. This is a new administrative obligation with no equivalent in the previous directive. In the event of an inspection or a dispute, it will be the first thing requested.

• 1. Description of the packaging and its components (materials, grammage, manufacturing process)
• 2. Compliance with the essential requirements (minimisation, absence of banned substances)
• 3. The recyclability information available at this stage
• 4. Supplier certificates on regulated substances

Before launching reformulation projects, you need to know precisely where you stand. The aim is to assess each format in the portfolio against the available guidance (RecyClass, CEFLEX, EMF, preliminary PPWR guidance) to estimate the risk of non-compliance in 2030. Waiting until 2028 to start this mapping forces a rushed reformulation of dozens of references over 18 months.

• 1. Non-separable multilayer packaging (plastic + aluminium, plastic + welded cardboard)
• 2. Plastic packaging with inks or adhesives that disrupt recycling
• 3. Paper or cardboard with a plastic coating above 5% (PPWR threshold)
• 4. Black packaging (carbon pigments incompatible with optical sorters)
• 5. Plastic films with non-separable resin blends

Building on the mapping, launch the reformulation work in order of priority. The high-risk formats that represent significant volumes or long development lead times should start first. Improving recyclability must not come at the expense of the barrier function, or it will generate food losses that would cancel out the environmental benefit.

• 1. Prioritise mono-material reformulations (monomaterial design) that maximise recyclability
• 2. Assess barrier alternatives: bio-based coating, cellulose barrier, AlOx/SiOx in place of aluminium
• 3. Document each technical choice along with the trade-offs accepted (recyclability vs barrier vs cost)
• 4. Anticipate the impact on packing lines (throughput, sealing temperatures, machine compatibility)

The PPWR sets recycled plastic content targets from 2030 (10% to 35% depending on use). These targets are calculated as an average per manufacturing plant per year. To declare them, you need to know precisely the recycled content rate of each reference you buy. Few teams currently have that traceability at resin level.

• 1. The 10% target for food-grade plastics other than PET runs into a regulatory bottleneck: the EFSA-approved processes for food contact concern almost exclusively PET from clear bottles
• 2. For PP, PE, PS: the EFSA approval files are not yet complete
• 3. Build the framework early: changes to supplier specifications, audits, third-party certifications

The PPWR delegates more than 30 operational criteria to delegated acts published progressively between 2026 and 2030. Each publication can change the priorities of the action plan. Setting up a quarterly monitoring process for Commission DG Environment publications is essential.

• 1. Publication of the recyclability criteria and classes A to E (expected early 2028)
• 2. Publication of the recycled content calculation method (end of 2026)
• 3. Clarification of Annex V on shrink film (promised for February 2027)

France EPR (EPRO) — eco-contributions begin

First financial contribution on commercial packaging. Check registration and declared volumes.

PPWR applies — PFAS + declarations of conformity

PFAS ban on food packaging. Technical documentation required per format. Identification of manufacturer/producer status.

Annex V clarification (shrink film)

The Commission has committed to publishing the clarification on the exact scope of the shrink film (grouping film) ban. A decision point for packing-line investment.

Harmonised labelling (pictograms; optional QR code) + recyclability delegated acts

Publication of the criteria for classes A to E. The tipping point: from here, reformulation projects must be in the final validation phase.

100% recyclability, recycled content, Annex V restrictions, reuse

All the major PPWR obligations come into force at once. Any non-compliant packaging can no longer be placed on the EU market.