PPWR packaging
The PPWR (Regulation EU 2025/40) stands for the Packaging and Packaging Waste Regulation. It is the latest European packaging law, specifically created to make packaging rules stricter and much more consistent across Europe. A crucial part of this new legislation is Article 5, which focuses heavily on so-called 'substances of concern', such as heavy metals and PFAS. These specific rules will officially come into effect on August 12, 2026. From that day forward, they will apply directly and without any exceptions across all EU Member States.
Yes, you can use our packaging with complete peace of mind! Our pouches fully comply with the new PFAS restrictions. Article 5 of the PPWR sets strict limits for food contact packaging: there is a maximum of 25 ppb per individual PFAS substance, a maximum of 250 ppb in total, and a maximum of 50 ppm if you include polymeric PFAS. For all the materials and structures we offer, our suppliers have officially declared that no PFAS has been intentionally added. This means our products are perfectly in line with the new standard, ensuring your packaging is safe and compliant.
No, a lab report is not required by default. According to Article 5 of the PPWR, you are not obligated to prove compliance with the PFAS limits using a laboratory report. A simple written declaration from the manufacturer stating that no PFAS has been intentionally added is a completely valid and sufficient basis. You only need a lab report with concrete figures if PFAS is actually present in a product, or if the manufacturer cannot provide such a declaration. So, in most cases, you are good to go without any extra paperwork!
Yes, in addition to PFAS, there are also strict limits for heavy metals that you need to take into account. Article 5 of the PPWR sets a combined maximum limit of 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium. Fortunately, this isn't a major change or any reason to worry! This limit is actually not new; it originally comes from the older Directive 94/62/EC. It has simply been carried over unchanged into the new PPWR. So, if you were already compliant with the old rules, you are still good to go!
Yes, we make sure your paperwork is completely in order! In our Declaration of Conformity (DoC), you will find an explicit reference to Article 5 of the new Regulation (EU) 2025/40 (the PPWR). Besides that, the document naturally includes the familiar references to existing food contact legislation, such as Regulation (EC) 1935/2004 and Regulation (EU) 10/2011. Do you need this document to complete your own compliance file? You can always easily request this documentation from us.
There is an important rule for your older stock regarding the moment of filling. The European Commission states that unfilled sales packaging (like our empty pouches) is legally "placed on the market" at the exact moment you fill and seal them, and not when we deliver them to you. Practically, this means that any stock you fill and sell after August 12, 2026, will also fall under the new PPWR requirements, regardless of when we delivered the empty pouches. But don't worry at all! Just get in touch with us regarding this existing stock. We will gladly send you the updated declaration for each material structure, so you can simply use your current stock without having to reorder your products.
Within the supply chain, we all share the responsibility to comply with the PPWR. In this process, PouchDirect acts as the importer and distributor of the empty packaging. However, the moment you fill the pouches and place them on the market as a filled product under your own brand, you (as the filler or brand owner) are responsible for the reporting and registration obligations (such as with your national packaging registers). Of course, we won't leave you out in the cold! We fully support you in this obligation by providing all the necessary technical documentation regarding the packaging itself. Together, we will make sure everything is perfectly sorted!
No, transition periods exist. PouchDirect advises ordering PPWR-proof pouches now, preventing unsellable stock in the future.
Yes, but monitor the material. PouchDirect recommends labels made from the same material as the pouch, such as a PE-sticker on a PE-pouch. This keeps the entire package a mono,material and prevents your pouch from ending up in an incinerator due to a "polluting" label.
Yes, the law applies to everyone placing packaged products on the European market. PouchDirect supports everyone, from the starting coffee roaster to the large purchase manager.
