China (Guangzhou) International Exhibition on Packaging Products

The European Commission’s latest guidance on the Packaging and Packaging Waste Regulation (PPWR) is shifting the packaging industry from policy preparation to evidence-led implementation.Although the Regulation generally applies from 12 August 2026, the June guidance helps companies interpret selected requirements while confirming that Regulation (EU) 2025/40—not the guidance—remains the applicable law.  

The most urgent issue is PFAS in food-contact packaging. The guidance sets out a stepwise approach while a harmonised EU test method is still being developed. A total-fluorine screening result below 50 mg/kgmay support a compliance conclusion; higher results can require further analysis to distinguish organic from inorganic fluorine and assess the relevant limits.

For businesses, the key cut-off is clear: food-contact packaging first placed on the EU market from 12 August 2026 must meet the applicable PPWR requirements. Packaging already placed on the market before that date does not have to be withdrawn under the stock-treatment clarification described in the guidance.

The Notice also clarifies the meaning of “making available” for reusable beverage packaging. From 1 January 2030, final distributors must ensure that at least 10%of alcoholic and non-alcoholic beverages made available to consumers are offered in reusable packaging within a reuse system. This includes distance sales; it is not limited to a completed purchase.

What packaging companies should do now: build a SKU-level packaging inventory, collect supplier substance declarations and PFAS test evidence, map EU economic roles and markets, and retain clear records of the date each packaging format was first placed on the market.

The guidance resolves several immediate questions, but more detailed EU measures on labelling, recyclability and implementation methods will continue to emerge. The practical priority is therefore not to wait for every technical rule, but to create the data trail needed to support packaging claims when enforcement begins.