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On 5 June 2026, the European Commission published its final guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). This provides clarification on selected provisions ahead of the regulation’s application from 12 August 2026.

The guidance aims to ensure consistent implementation of the PPWR across the European Union. It also addresses topics such as per- and polyfluoroalkyl substance (PFAS) restrictions in food-contact packaging, packaging definitions, the responsibilities of economic operators, recyclability requirements, recycled content, reusable packaging, labelling, deposit return systems, and compostable packaging.

PFAS Restrictions Apply Without a Stock-Exhaustion Period

Among the topics covered, the guidance provides further interpretation of the PFAS restrictions that will apply to food-contact packaging under the PPWR. The Commission confirms that the PPWR does not allow for a transitional period to use up existing stocks of food-contact packaging containing PFAS above the applicable limits.

According to the guidance, food-contact packaging placed on the market after 12 August 2026 must comply with the PFAS concentration limits set out in Article 5(5) of the PPWR:

• 25 ppb for any individual PFAS
• 250 ppb for the sum of PFAS
• 50 ppm for total PFAS, including polymeric PFAS.

Packaging placed on the market before this date may remain on the market and does not need to be withdrawn. The guidance also notes that no exceptions apply to packaging containing recycled material.

Recommended Approach for PFAS Testing

The guidance also addresses the enforcement of the PFAS restrictions. While several analytical methods are available, the Commission acknowledges that there is currently no harmonised EU methodology for testing PFAS in food-contact packaging.

To support enforcement activities, the guidance recommends a stepwise approach, beginning with the quantification of total fluorine. Where fluorine levels exceed the relevant threshold, additional analytical methods may be used to determine whether the fluorine is attributable to PFAS and whether the applicable concentration limits are exceeded.

Clarification on “Placing on the Market”

The guidance also explains how the concept of “placing on the market” should be interpreted for different types of food-contact packaging.

For sales and grouped packaging, placing on the market generally occurs when the packaging is filled, since final processing steps such as sealing may affect compliance. For transport and service packaging, placing on the market generally occurs when the packaging is supplied empty.

In line with the Blue Guide on the implementation of EU product rules, the Commission notes that placing on the market takes place when ownership, possession, or another property right is transferred, whether for payment or free of charge. For imported packaging and packaged products, the relevant point in time when they are released for free circulation following customs procedures.

Guidance Ahead of August 2026 Application

While the guidance is non-binding and does not amend the legal requirements established by the PPWR, it provides insight into how the Commission expects the Regulation to be interpreted and applied by economic operators and market surveillance authorities.