PPWR is not addressed directly to buyers. But its requirements create obligations that inevitably travel up the supply chain. Whether your packaging is compliant depends largely on what your suppliers can deliver: PFAS-free materials, approved recycled plastics, recyclable materials, technical documentation.
For procurement teams the challenge is twofold: securing the compliance of current purchases before 12 August 2026, and preparing for the new sourcing requirements for 2028–2030 in a context where several material markets are still immature.
A specific supply risk for 2026
Global demand for food-contact-grade recycled plastics is set to soar in the years ahead. The volumes available will not be enough to meet every demand at once. Buyers who secure their supply early will gain a real competitive advantage.
Procurement risk map
By packaging category — level of supply risk linked to PPWR
Food packaging with a coating or grease-resistant barrier
PFAS from 12 August 2026. Check every supplier immediately. Risk of disruption if reformulation is needed.
Plastic shrink film (grouping) for multipacks
Potentially banned in 2030 (clarification February 2027). Do not enter into new long-term contracts for this format without an exit clause.
Food-contact recycled plastics (other than water PET)
Market all but non-existent. Sourcing impossible at the required scale until the EFSA dossiers are approved for PP, PE, PS.
Food-contact recycled PET (other than water)
Available in limited quantities. Strong competition between manufacturers. Priced higher than virgin PET. To secure early if you are targeting 30% by 2030.
Non-recyclable multi-layer packaging
Reformulation needed before 2030. Alternative suppliers to identify now to avoid supply pressures in 2028–2029.
Recyclable cardboard without a plastic coating
A sound regulatory position. Mature market. Risk relates to the price and availability of recycled board, not to compliance.
Recycled plastics for non-food contact
Better availability. More mature market. The 35% targets for 2030 are achievable with early sourcing.
Transparent mono-material PET
Good recyclability, mature stream (water bottles). A solid regulatory position for 2030.
New requirements to build into your supplier specifications
By obligation and by time horizon
| Requirement | Content of the clause | Horizon |
|---|---|---|
| PFAS attestation | A formal attestation of compliance with the PFAS thresholds in Regulation (EU) 2025/40 (individual PFAS < 25 ppb / total < 250 ppb). Mandatory for any food packaging with a surface treatment or barrier. To be renewed with every change of formulation. | Before 12 August 2026 |
| Compliance documentation | Provision of the technical documentation needed to draw up the PPWR declaration of conformity (Art. 38-39). Precise material composition, manufacturing process, relevant test results. | Before 12 August 2026 |
| Plastic content of paper/board | Declaration of the precise percentage of plastic in any paper or board packaging with a coating or treatment. Key PPWR threshold: 5% (above this = treated as single-use plastic). | Before 12 August 2026 |
| Recycled-content traceability | Certification of the post-consumer recycled content per batch, with chain-of-custody traceability. Third-party certification recommended (Recycled Claim Standard, EU Ecolabel). | Data before 2028 |
| Food-contact approval for recycled material | For recycled plastics intended for food contact: provision of the EFSA opinion and the approved process number. Without EFSA approval, the material cannot be used even if the recycled content is achieved. | Check from 2027 |
| Material recyclability | Recyclability assessment under RecyClass, CEFLEX or another recognised framework. To be refreshed when the PPWR delegated acts are published (expected 2028). Target: class A or B for all packaging supplied by 2030. | Assessment 2027, compliance 2030 |
| Regulatory exit clause | Build into every new multi-year packaging contract a termination or renegotiation clause should the format in question become non-compliant or banned through a change in PPWR or the AGEC law. Particularly important for shrink films and HORECA formats. | All new contracts from 2026 |
Procurement action plan 2026-2030
Concrete actions ranked by priority
Urgent — before August 2026
Collect PFAS attestations across the entire food packaging supplier panel
Identify every supplier of food packaging with a surface treatment (grease-resistant coating, moisture barrier, non-stick finish). For each one, obtain a formal attestation of compliance with the PPWR PFAS thresholds, or analysis results following the 3-tier methodology.
If a supplier cannot provide this attestation before 12 August 2026: urgently qualify a compliant alternative or stop using that format. No derogation is possible.
Urgent — 2026
Update supplier technical data sheets: plastic content of paper/board packaging
For all paper or board packaging that includes a coating, require a declaration of the precise percentage of plastic. This figure is needed to assess whether the packaging is caught by the PPWR 5% threshold — above it, the packaging is reclassified as single-use plastic.
Urgent — 2026
Review long-term contracts on formats with regulatory risk
Identify all multi-year contracts covering formats potentially banned in 2030 (shrink films, individual HORECA sachets, plastic fruit & veg packaging). Check whether exit or renegotiation clauses are present. If not, initiate contract amendments.
Pay particular attention to shrink films: the clarification on the “necessary for handling” exemption is not expected until February 2027. Do not commit to a contract renewal without a regulatory exit clause.
High priority — 2026-2027
Map the suppliers able to provide certified recycled plastic
Identify the current and potential suppliers able to provide plastics with certified recycled content and chain-of-custody traceability. Distinguish food-contact uses (far more restrictive, a very limited market) from non-food uses.
For food contact: check whether suppliers hold an EFSA-approved process. Without that approval, the material cannot be used even if it is technically recycled. This is the main bottleneck on the 2030 targets for plastic food packaging.
High priority — 2027-2028
Secure volumes of food-contact recycled PET
Global capacity for food-contact-approved recycled PET (mainly from transparent PET water bottles) is limited. Demand will rise significantly with PPWR. Manufacturers who sign long-term supply agreements early will gain a real edge on both price and availability.
Medium term — 2028
Build recyclability into supplier evaluation criteria
From the publication of the delegated acts on recyclability classes (expected early 2028), build the PPWR recyclability class into the scoring grid for packaging supplier evaluation. Target: purchase only class A or B packaging from 2029.
State of the market — availability of PPWR-compliant materials
Summary by material — May 2026
See the full PPWR roadmap for every deadline by packaging type and build them into your multi-year supply plan.
Full PPWR roadmapSources: Regulation (EU) 2025/40, Commission guidance of 30 March 2026, EFSA (register of approved processes), Recycled Claim Standard, CEFLEX. Content verified as at 10 May 2026. Does not constitute legal or commercial advice.