News Details

The European Chemicals Agency (ECHA) has developed a draft list of 731 substances of concern (SoCs) identified in packaging and packaging waste as part of work supporting the implementation of the EU Packaging and Packaging Waste Regulation (PPWR). ECHA is currently seeking feedback on the draft list from selected stakeholders.

The list covers substances associated with chemical safety and recycling concerns and provides information on their occurrence in different packaging materials and applications. It includes both intentionally added substances (IAS) and non-intentionally added substances (NIAS).

Background

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) became generally applicable on 12 August 2026. Among its requirements, Article 5 addresses substances of concern in packaging and requires their presence and concentration in packaging materials and components to be minimised.

Under Article 5(2), the European Commission, assisted by ECHA, must prepare a report on substances of concern present in packaging and packaging components by 31 December 2026. This report will assess the extent to which these substances negatively affect the reuse and recycling of materials or impact chemical safety.

The findings may inform possible follow-up measures, including potential restrictions under REACH or measures incorporated into the PPWR's design-for-recycling criteria.

Draft List of Substances of Concern

The draft ECHA list contains 731 entries identified in packaging and packaging waste. It brings together information on substances with relevant harmonised classifications, substances of very high concern (SVHCs), persistent organic pollutants (POPs), and substances identified as relevant to chemical safety or as having a negative impact on recycling.

Of the 731 entries, 345 are identified as having a negative impact on recycling. The different categories overlap, meaning that an individual substance may meet several of the criteria used in compiling the list.

The draft includes substances from several chemical groups of regulatory interest, including PFAS, phthalates and bisphenol A (BPA). For example, BPA is identified in connection with applications including recycled food packaging, PET bottles, can linings, polycarbonate containers and thermal paper.

The list also includes several PFAS, such as perfluorobutanoic acid (PFBA), perfluorohexanesulfonic acid (PFHxS), perfluorohexanoic acid (PFHxA), perfluorononanoic acid (PFNA) and perfluorooctanesulfonic acid (PFOS).

Packaging Materials and Functions

In addition to identifying the substances, the draft provides information on the packaging materials, packaging types and formats, and technical functions associated with them. Materials covered include plastics, paper and paperboard, metals, glass, ceramics and wood.

Technical functions identified in the list include use as plasticisers, inks and printing compounds, adhesives, stabilisers, pigments and processing aids. This information is intended to help establish where substances of concern occur in packaging and how they may affect chemical safety and recycling.

Stakeholder Feedback

Rather than holding a public consultation, ECHA is seeking feedback from selected stakeholders. This exercise is intended to validate and improve the information in the draft list, by identifying missing information and correcting potential gaps or errors.

At this stage, the draft list has not been officially published or adopted by ECHA.