EU Packaging and Packaging Waste Regulation (PPWR) and Additives: 6 Articles That Change Packaging Formulations

Regulatory status verified: 24 September 2026.

The PPWR, Regulation (EU) 2025/40, has applied since 12 August 2026 and controls plastic additives through 6 articles: substances of concern, a 100 mg/kg heavy-metal sum, PFAS limits in food-contact packaging, design for recycling, minimum recycled content and compostability. Three of those limits are already enforceable and three arrive on fixed dates between 2028 and 2040, so which of them reaches the formulation on a compounder's desk today?

Article 5(1) and 5(2) set a minimisation duty for substances of concern in packaging, backed by a Commission report due 31 December 2026. Article 5(4) caps the sum of four heavy metals, lead, cadmium, mercury and hexavalent chromium, at 100 mg/kg. Article 5(5) sets three PFAS thresholds for food-contact packaging, from 25 ppb for a single substance to 50 ppm for total PFAS. All three have applied since 12 August 2026. Article 6 pushes packaging toward design-for-recycling criteria due by delegated act on 1 January 2028. Article 7 sets minimum recycled content per packaging category, from 10 to 35 percent in 2030 and 25 to 65 percent in 2040. Article 9 requires four packaging types to be industrially compostable, and everything else to be designed for material recycling, by 12 February 2028.

Regulation (EU) 2025/40 replaces the earlier packaging and packaging waste directive with a single, directly applicable EU law, and it pulls plastic additives in two directions at once: it removes lead and cadmium pigments, lead stabilizers and fluorinated processing aids from packaging, while it creates new demand for restabilizing antioxidants, compatibilizers, chain extenders and odour absorbers in recycled-content packaging. Compliance runs on two measurements, the sum of four heavy metals assessed on the packaging or the packaging component, and total fluorine screened against a 50 mg/kg trigger before targeted PFAS analysis. A dated timeline carries the regulation from its 22 January 2025 Official Journal publication through the 2040 recycled-content step, and the PPWR adds to, rather than replaces, Regulation (EU) No 10/2011 on food-contact plastics, REACH and the POPs Regulation. This page is a technical reference, not legal advice, and it states each limit's article number, value and date so a formulation can be checked against the official text.

What Is the PPWR and When Does It Apply?#

The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste, adopted on 19 December 2024, published in the Official Journal on 22 January 2025, in force since 11 February 2025 and applicable since 12 August 2026. It replaces the earlier packaging and packaging waste directive with a single regulation that applies directly across the European Union, and Article 71 sets 12 August 2026 as the general date of application, with one further provision, Article 67(5), following later on 12 February 2029.

Application brought Article 5(1) into force with every other substance-control article: packaging placed on the EU market since that date must be manufactured so that the presence and concentration of substances of concern is minimised, including in the packaging's emissions, in the recyclate it produces and in the microplastics it releases. That minimisation duty applies to every packaging placed on the market, regardless of format or country of origin, and it is the duty that Article 5(2) turns into a dated deliverable.

Which packaging does the PPWR reach, and which parts of it#

The PPWR's substance limits attach to the packaging and to every packaging component separately, so the 100 mg/kg heavy-metal sum is a limit on the printed film, the closure, the label and the colour masterbatch that goes into any of them. Each component is assessed on its own composition rather than diluted against the packaging as a whole, which means a small closure with a high pigment load can fail the limit even when the finished pack's average would pass it. Article 5(1)'s minimisation duty reaches further than the metal and PFAS limits, because it covers the packaging's emissions, the recyclate generated from it and any microplastics it releases, while Article 5(5)'s PFAS limits apply only to food-contact packaging, a narrower scope than the heavy-metal sum in Article 5(4).

The PPWR's substance limits attach to three distinct objects, and each one carries the duty separately:

• The packaging itself, assessed as the complete item placed on the EU market.
• Each packaging component, assessed on its own composition: the film, the closure, the label and the masterbatch that colours or stabilizes it.
• The recyclate, emissions and microplastics generated from the packaging, covered by the Article 5(1) minimisation duty.

What changed on 12 August 2026?#

Three PPWR limits became enforceable on 12 August 2026: the 100 mg/kg sum of lead, cadmium, mercury and hexavalent chromium in Article 5(4), the PFAS limits for food-contact packaging in Article 5(5), and the Article 5(1) duty to minimise substances of concern. The European Commission announced the regulation's entry into application in a news item dated 11 August 2026, a Commission announcement rather than a legal text in its own right. Two supporting dates frame that change: Member States had to supply the Commission with information on substances that hamper packaging recycling by 31 December 2025, and the Commission, assisted by ECHA, must report on substances of concern in packaging by 31 December 2026.

1. The 100 mg/kg heavy-metal sum under Article 5(4) starts applying to every packaging and packaging component.
2. The three PFAS thresholds under Article 5(5) start applying to food-contact packaging.
3. The Article 5(1) duty to minimise substances of concern starts applying to all packaging placed on the EU market.

What is the difference between the PPWD and the PPWR?#

The PPWR is a regulation and applies directly in every Member State, while the packaging and packaging waste directive it replaces had to be transposed into 27 national laws first, which is why the same heavy-metal sum of 100 mg/kg was enforced differently in each of them. Directive 94/62/EC already set that same 100 mg/kg sum of lead, cadmium, mercury and hexavalent chromium in its Article 11, so the PPWR continues an existing limit rather than introducing a new one. A regulation needs no transposition act, so the same wording and the same 12 August 2026 date now apply without a national implementing law standing in between.

The 6 PPWR Articles That Control Plastic Additives#

6 articles of the PPWR control plastic additives: Article 5(1) and 5(2) on substances of concern, Article 5(4) on heavy metals, Article 5(5) on PFAS, Article 6 on design for recycling, Article 7 on recycled content and Article 9 on compostability. Two articles remove specific additive families outright, one article limits a family by threshold, two articles create new demand for additive families that support recycled content, and one article treats compostable formulations as their own category.

These 6 articles reach only a part of the 43 families of plastic additives, the complete set of substances added to a polymer to make it processable, stable, coloured or fit for its application. The sections below take the 6 articles in ascending legal order, which is also the order of how directly each one removes or requires a substance.

1. Article 5(1) and 5(2): substances of concern in packaging#

Article 5(1) of the PPWR requires packaging to be manufactured so that the presence and concentration of substances of concern is minimised, and Article 5(2) gives that duty its teeth: the Commission, assisted by ECHA, must report on substances of concern in packaging by 31 December 2026. Article 5(1) sets no numeric limit of its own; it is a minimisation duty, covering the packaging's emissions, the recyclate it produces and the microplastics it releases, and it applies to every packaging component rather than to the packaging as an average. A "substance of concern" takes its definition from Article 2(27) of the Ecodesign for Sustainable Products Regulation, (EU) 2024/1781, which the PPWR adopts without change.

The Commission's report is the mechanism that will eventually turn Article 5(1) into enforceable numbers, and it follows one of two routes. A substance the report identifies as harmful can be restricted under REACH Article 68, the same mechanism behind every Annex XVII entry, or it can be addressed through the Article 6(4) design-for-recycling criteria if the concern is that it hampers recycling rather than that it is hazardous. Member States already supplied their own information on substances that hamper packaging recycling by 31 December 2025, one year ahead of the Commission's own deadline. The same Article 2(27) definition also drives the ESPR substances of concern regime and the Digital Product Passport, which apply the concept to product categories well beyond packaging.

Which plastic additives count as substances of concern?#

A plastic additive counts as a substance of concern under the PPWR when it meets one of the four criteria in Article 2(27) of the ESPR: it is on the REACH Candidate List, it carries one of the listed harmonised hazard classifications, it is a persistent organic pollutant, or it hampers reuse and recycling. ECHA screened about 6,000 substances reported in packaging and published a draft list of about 700 substances of concern in August 2026, built on Candidate List status, a harmonised chronic hazard classification or POP status; the Food Packaging Forum commented on 24 August 2026 that 42 hazardous chemicals were missing from the draft. That list is a draft screening, not a legal restriction, and the Commission's own report due 31 December 2026 is what will decide which substances move forward.

• SVHC additives: every plastic additive on the SVHC Candidate List meets the first criterion automatically, such as DEHP, which carries both a Candidate List entry and Annex XIV entry 4.
• POP additives: substances such as UV-328, listed in the Stockholm Convention's Annex A in 2023 (SC-11/11), and HBCDD and decaBDE, meet the third criterion.
• Harmonised-CMR additives: substances carrying one of the listed harmonised hazard classifications, such as dicumyl peroxide, added to the Candidate List on 27 June 2024 for reproductive toxicity, meet the second criterion.
• Additives that hamper recycling: substances the Commission's Article 5(2) report identifies as interfering with packaging recyclability meet the fourth criterion, a category the report has not yet populated.

2. Article 5(4): the 100 mg/kg heavy-metal sum#

Article 5(4) of the PPWR limits the sum of lead, cadmium, mercury and hexavalent chromium in packaging or in any packaging component to 100 mg/kg, and that limit has applied since 12 August 2026. The limit is a sum of four metals, not four separate 100 mg/kg limits, so a colour masterbatch, a heat stabilizer and a mineral filler in the same packaging component all draw against the same budget, and a formulation that passes on lead alone can still fail once cadmium and chromium are added in. Article 5(4) continues a limit that already stood in Article 11 of Directive 94/62/EC, the directive the PPWR replaces, so the value itself is not new even though its legal form is.

Lead stabilizers were already excluded from EU PVC packaging under REACH Annex XVII entry 63, which has limited lead in PVC to below 0.1 % since 29 November 2024, with recovered rigid PVC allowed up to 1.5 % lead until 28 May 2033. Cadmium already carries its own single-metal limit too: Annex XVII entry 23 keeps cadmium in plastics below 0.01 %, equivalent to 100 mg/kg of cadmium alone, so the PPWR's four-metal sum sits on top of an existing limit rather than replacing it.

Our source library holds no mercury-containing plastic additive. Mercury is verified as a contaminant, not designed in.

Which pigments and stabilizers does the heavy-metal limit remove?#

Lead chromate and cadmium pigments cannot be used as colorants in EU packaging under Article 5(4), because a pigment dosed at the level needed for colour puts the four-metal sum far above 100 mg/kg, while lead stabilizers were already out of EU PVC packaging under REACH Annex XVII entry 63. Complex inorganic pigments without lead or cadmium remain usable, because they sit well under the four-metal budget at normal colouring doses, which is why cadmium-free and lead-free grades already dominate new packaging formulations. The surviving inorganic pigments for plastics are the cadmium-free and lead-free complex inorganic types, dosed in the same low single-digit weight percent range typical of titanium dioxide and complex inorganic colour pigments generally.

3. Article 5(5): PFAS limits in food-contact packaging#

Article 5(5) of the PPWR sets three PFAS limits for food-contact packaging placed on the EU market since 12 August 2026: 25 ppb for any single PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS. The regulation defines a PFAS as a substance with at least one fully fluorinated CF3 or CF2 carbon atom, with a short list of exclusions, the same structural definition used across current EU PFAS policy. That definition is deliberately broad, and it captures fluoropolymers and side-chain fluorinated polymers alongside the small-molecule PFAS that most consumer coverage focuses on.

1. 25 ppb for any single targeted PFAS, measured by targeted analysis, with polymeric PFAS excluded from that quantification.
2. 250 ppb for the sum of targeted PFAS, including precursor degradation where applicable.
3. 50 ppm for total PFAS, the only one of the three thresholds that counts polymeric PFAS in full.

Total fluorine is the screening step that decides whether the other two thresholds get tested at all: above 50 mg/kg total fluorine, the supplier must provide proof on request of whether the fluorine is PFAS or non-PFAS in origin. The third limit, the 50 ppm total-PFAS threshold, is the one that reaches additives directly, because polymeric PFAS such as fluoropolymer processing aids are excluded from the 25 ppb and 250 ppb quantification but are counted in full toward the 50 ppm total. PFAS restrictions in the EU run well beyond this one packaging article, and the full set of six PFAS restrictions that reach plastic additives, including the pending EU-wide restriction, is covered on that page.

Do fluoropolymer processing aids still work in food-contact film?#

Fluoropolymer processing aids are polymeric PFAS, so they count in full toward the PPWR's 50 ppm total-PFAS limit for food-contact packaging, and a polyethylene film dosed at several hundred ppm of a 65 to 71 % fluorine grade sits in the range of that limit. Under 21 CFR 177.1520, the US clearance for olefin polymers allows fluoropolymer processing aids (PPA) at up to 0.2 wt% for grades with 65 to 71 % fluorine content and up to 1.0 wt% for grades with at least 87 % vinylidene fluoride, and EU compounders commonly use the same US-cleared grades because no separate EU food-contact clearance exists for the polymer class itself.

PPA loadings in commercial film run in the hundreds of parts per million, not in whole weight percent, because the additive functions at a processing-aid dose rather than as a bulk component. That places a typical polyethylene film's PPA content in the same order of magnitude as the PPWR's 50 ppm total-PFAS limit, an arithmetic comparison that is this site's own analysis of published dosage ranges against the regulatory threshold, not a Commission calculation or official guidance.

Compounders who need headroom under the 50 ppm limit are moving toward PFAS-free processing aids, which use polyethylene-glycol or acrylic chemistries instead of a fluoropolymer. The universal EU-wide PFAS restriction remains pending rather than in force: the Risk Assessment Committee adopted its final opinion on 2 March 2026, the Socio-Economic Analysis Committee's draft opinion followed on 10 March 2026, and a final opinion is expected by the end of 2026. Fluoropolymer PPAs are not prohibited today; the PPWR's total-PFAS limit for food-contact packaging is what applies, and no Commission guidance yet exists in the public record on how total PFAS is measured in a multilayer film structure.

4. Article 6: design for recycling and the delegated acts due 1 January 2028#

Article 6 of the PPWR makes recyclability a legal property of the packaging, but its design-for-recycling criteria and performance grades come from a delegated act due by 1 January 2028, and the grades apply from 1 January 2030 at the earliest. No recyclability grade exists today, and Article 5(2) already routes any substance the Commission's report finds to hamper recycling into these same Article 6(4) criteria rather than into a separate restriction. Until the delegated act is published, design for recycling in EU packaging runs on industry protocols rather than on PPWR text: the European PET Bottle Platform (EPBP), RecyClass and the Association of Plastic Recyclers (APR).

Design-for-recycling criteria, once they exist, are expected to measure additive properties that already show up in today's voluntary protocols:

• Barrier polymer content, capped in the EPBP guideline at a maximum of 5 % MXD6 in clear PET and 6 % in coloured PET.
• Colour and carbon content, which governs near-infrared sortability of dark and black packaging under RecyClass and APR protocols rather than under the PPWR text itself.
• Filler and mineral content, where mineral-filled polypropylene denser than about 1.0 g/cm3 sinks in float-sink separation, a mechanism RecyClass and APR address without a published numeric threshold at the time of writing.
• Adhesive and label compatibility, judged against the same recycling-stream protocols pending the Article 6 delegated act.

5. Article 7: minimum recycled content in 2030 and 2040#

Article 7 of the PPWR sets minimum post-consumer recycled content per plastic part of packaging from 1 January 2030, or 3 years after the implementing act on calculation and verification, whichever is later: 30 % for contact-sensitive PET, 10 % for other contact-sensitive plastic packaging, 30 % for single-use plastic beverage bottles and 35 % for all other plastic packaging. Those targets step up again on 1 January 2040 to 50 %, 25 %, 65 % and 65 % in the same order, and each percentage is calculated per manufacturing plant and year rather than per individual package.

Post-consumer recycled content per plastic part of the packaging, averaged per manufacturing plant and year. The 2030 dates apply from 1 January 2030 or 3 years after the implementing act on calculation and verification, whichever is later.

Article 7 is the one part of the PPWR that adds additives to a formulation rather than removing them, because post-consumer resin needs a support package that virgin resin does not. Restabilizing antioxidants at 0.1 to 0.3 wt% rebuild the oxidative stability that degrades through the recycling loop. A polyolefin elastomer compatibilizer at 2 to 5 %, typically 3 %, in a 70/30 HDPE/PP recyclate blend raises impact strength and elongation about threefold. Epoxy-functional styrene-acrylic chain extenders at 0.1 to 0.5 wt% rebuild molecular weight in degraded rPET, and 4 wt% of a zeolite odour absorber cuts recyclate odour intensity by about 45 %. The complete formulation guide for additives for recycled plastics covers all four families in full, and which recycling processes may feed food-contact packaging in the first place is covered separately by recycled plastics regulations, including Regulation (EU) 2022/1616.

6. Article 9: compostable packaging by 12 February 2028#

Article 9 of the PPWR requires four packaging types to be industrially compostable by 12 February 2028: permeable tea and coffee bags, other permeable beverage bags, soft single-serve units, and sticky labels on fruit and vegetables. Home compostability applies in addition where a Member State requires it, and Member States may extend the same duty to non-permeable beverage capsules and to very lightweight and lightweight carrier bags. The Commission had to request harmonised compostability standards by 12 February 2026, and industrial compostability itself is measured against EN 13432. Everything else, including packaging made from biodegradable polymers, follows a different rule under Article 9(3): it must be designed for material recycling by the same 12 February 2028 date, not for composting.

• Compostable by 12 February 2028: permeable tea, coffee and other beverage bags, soft single-serve units and sticky fruit and vegetable labels, industrially compostable at minimum, with home compostability added where a Member State requires it.
• Designed for material recycling by 12 February 2028: every other packaging format, including packaging made from biodegradable polymers, which Article 9(3) treats as a recyclability question rather than a compostability one.

The formulation risk list for a compostable pack follows directly from what industrial composting cannot process: metal-containing additives, non-biodegradable organics such as hindered amine light stabilizers, phosphites and silicone slip agents, fluoropolymer processing aids, and inorganic pigments carrying cadmium, lead or chromium. Compostable is not the same as oxo-degradable, and products made from oxo-degradable plastic have been banned in the EU since 3 July 2021 under Article 5 of Directive (EU) 2019/904, a ban that targets the pro-oxidant additive itself rather than the finished packaging format. The evidence and the bans on biodegradation additives for plastics are set out in full on the family page.

Which Additives Does the PPWR Restrict, and Which Does It Create Demand For?#

The PPWR pushes plastic additives in two directions: Article 5 removes heavy-metal pigments, lead stabilizers and fluorinated processing aids from packaging, while Article 7's recycled-content targets make restabilizing antioxidants, compatibilizers, chain extenders and odour absorbers a requirement rather than an option. Fourteen additive families sit on one side of that line or the other, spanning colorants, processing aids, stabilizers for recyclate and the barrier and scavenger chemistries used in food-contact film.

The complete package for additives for food packaging covers barrier, slip, antifog and oxygen-scavenger functions beyond what the PPWR itself regulates, and the table below lines up every family the PPWR touches against its controlling article, the effect and a typical dosage level from our source library.

How Do You Prove a Packaging Additive Complies With the PPWR?#

Prove PPWR compliance in 4 steps: collect an additive declaration for every packaging component, sum the four regulated metals across all of them, screen total fluorine and confirm by targeted PFAS analysis above 50 mg/kg, then file the results with the food-contact documentation. Each step maps to one PPWR limit, and the evidence chain runs from the additive supplier's declaration through the compounder's formulation record to the converter's finished packaging.

1. Collect the additive declarations for every packaging component, not only the resin.
2. Sum the four metals, lead, cadmium, mercury and hexavalent chromium, across pigments, stabilizers and fillers against the 100 mg/kg limit.
3. Screen total fluorine and, above 50 mg/kg, run targeted PFAS analysis by LC-MS/MS to confirm the 25 ppb and 250 ppb thresholds.
4. Keep the evidence with the food-contact documentation for the same packaging.

Food-contact packaging carries a second documentation duty alongside the PPWR: it must still meet Regulation (EU) No 10/2011, with its generic specific migration limit of 60 mg/kg, its overall migration limit of 10 mg/dm2 and its 0.01 mg/kg functional-barrier limit. The method chain for the fluorine and PFAS steps, total fluorine screening followed by targeted analysis, is set out in full on PFAS testing of plastics and packaging, and the same file carries the EU 10/2011 compliance evidence. No Commission guidance yet exists on how total PFAS is measured in a multilayer packaging structure, so the method above reflects current laboratory practice rather than a published standard, and the format of the declaration of compliance is set by the food-contact rules, not by the PPWR.

PPWR Deadlines for Compounders, Masterbatch Makers and Additive Suppliers#

The next PPWR deadline for an additive supplier is 31 December 2026, when the Commission's report on substances of concern in packaging is due, and the next formulation deadline is 12 February 2028 for compostable packaging.

How the PPWR Works Together With EU 10/2011, REACH and the POPs Regulation#

The PPWR adds to the rules that already apply to a packaging additive rather than replacing them: a food-contact additive still needs its Union list entry and its specific migration limit under Regulation (EU) No 10/2011, and a restricted additive is still restricted under REACH Annex XVII. Entries 23 (cadmium) and entry 63 (lead in PVC) are two of those REACH Annex XVII restrictions that keep applying underneath the PPWR's own metal sum.

The same Candidate List that feeds those Annex XVII entries is also where the PPWR's substance-of-concern definition draws its first criterion, so an additive already on the Candidate List meets the PPWR's Article 5(1) test automatically. Recycled plastics intended for food contact must still pass Regulation (EU) 2022/1616 before they can count toward an Article 7 target, so the PPWR's percentage targets and the food-contact recycling gate operate side by side rather than one replacing the other.

The POPs Regulation (EU) 2019/1021 adds a further layer: UV-328 has carried an EU limit of 100 mg/kg since 4 August 2025, falling to 10 mg/kg from 4 August 2027 and 1 mg/kg from 4 August 2029, and MCCP was listed in the Stockholm Convention's Annex A at COP-12 in 2025, with the EU's implementing delegated regulation adopted but not yet in force. REACH entry 78 restricts synthetic polymer microparticles, and the separate pellet-loss duties under Regulation (EU) 2025/2365 are the instrument Article 5(1) references through its microplastics clause.

The Article 5(1) minimisation duty also references packaging microplastics, covered separately by the EU microplastics restriction (REACH entry 78).

─── ─── ───

What the PPWR Requires Beyond Additives#

The PPWR contains far more than the 6 articles on this page, including packaging labelling, extended producer responsibility, reuse and refill targets and packaging-minimisation rules, and this reference covers only the articles that decide what may be added to the plastic. Those wider duties sit alongside the additive articles rather than inside them, and they are packaging-system obligations that fall on the brand owner and the packer-filler rather than on the compound formulation itself. The PPWR is one of 49 instruments indexed under plastic additive regulations, and the sections below answer only the questions this reference can support from its own source library.

Labelling, extended producer responsibility and reuse targets#

Packaging labelling, extended producer responsibility and reuse and refill targets are packaging-system duties under the PPWR, not formulation duties, and they fall on the packer-filler, the brand owner and the national producer-responsibility scheme rather than on the compounder or additive supplier. These provisions decide how a package is marked, who funds its collection and how often a format must be reusable, questions that sit outside what an additive does inside the plastic. The European Commission publishes its own guidance on all three areas, outside the scope of this reference.

Who does the PPWR apply to?#

The PPWR applies to packaging placed on the EU market, and because its additive limits attach to the packaging and to every packaging component separately, the duty reaches the converter and the brand owner directly and reaches the compounder and the additive supplier through the declaration chain each one passes upward. A supplier that is not itself in the chain of custody for a specific pack is not named in the regulation, but its declaration still becomes part of what the brand owner must be able to show.

Is the PPWR the same as EPR?#

No: extended producer responsibility is a national financing and take-back system, while the PPWR articles covered here are direct limits on what a packaging may contain. EPR schemes are run and funded per Member State, while the substance and content articles on this page apply directly and identically across the European Union without a national scheme standing in between.

Does the PPWR reach suppliers outside the EU?#

The PPWR's limits attach to packaging placed on the EU market, so an additive supplier based in India, China or the United States meets them through the declaration it gives its EU customer rather than through direct jurisdiction over its own factory. An exporter selling fluoropolymer processing aids or heavy-metal pigments into the EU packaging supply chain carries the same declaration burden as an EU-based compounder, even though the regulation itself has no extraterritorial registration duty.

The wider picture on fluorinated additives entering plastics from outside the packaging context, including anti-drip PTFE and fluorinated containers, is covered on PFAS in plastics, and imported recyclate carries its own legacy additives in recycled plastic risk, from brominated flame retardants to residual lead and cadmium, that the PPWR's forward-looking limits do not retroactively clean out of material already in circulation.

---