Since August 12, 2026, food-contact packaging that exceeds the European Union’s PFAS limits cannot be placed on the EU market under Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR). The measure applies across the EU as part of a wider overhaul of packaging composition and recyclability, with new rules for labeling and reuse. The regulation entered into force on February 11, 2025, but its general application began on August 12, 2026.
Article 5(5) sets three separate thresholds: no more than 25 parts per billion (25 micrograms per kilogram) for any individual PFAS; no more than 250 parts per billion (250 micrograms per kilogram) for the sum of targeted PFAS; and no more than 50 parts per million (50 milligrams per kilogram) of total fluorine, including polymeric PFAS. A package can fail if it exceeds any one of these limits. The thresholds measure concentration in the packaging itself, not the amount that migrates into food. They can apply even when PFAS were not intentionally added.
PFAS have been used to make paper and fibre packaging resist grease and moisture, including fast-food wrappers, main point containers and pizza boxes. Their persistence in the environment is a basic concern. For manufacturers and importers, compliance requires more than a declaration that PFAS were not deliberately used. Supplier details and composition records may need to be backed by analytical testing to show that targeted PFAS and total fluorine remain within the limits.
The rules apply to food-contact packaging placed on the EU market from August 12, 2026, including products manufactured earlier but introduced to the market after that date. Packaging already placed on the market before the application date may continue to be sold, but non-compliant stock introduced afterward cannot rely on a general sell-through period. The regulation applies directly in Spain and other EU member states, without national transposition. It does not ban all single-use packaging; it regulates the materials and composition of packaging covered by its requirements.
The PPWR also phases in broader technical and design requirements. The timeline sets 2028 as the target for a harmonized labeling system using pictograms to show packaging materials and help consumers sort waste. Reusable containers are scheduled to receive specific identification from February 2029. Until then, national labeling rules remain in effect, while QR codes and other digital tools can provide additional recycling information.
By 2030, stricter design standards are due to apply, including a minimum 30% recycled content for single-use plastic bottles and a requirement for beverage distributors to offer a minimum share of reusable packaging. Small hotel containers and single-portion hospitality packaging are also set to face restrictions on later timelines. The PFAS limits are one part of this staged regime, not a blanket prohibition on disposable containers.
For Spanish businesses, the immediate task is to document packaging composition and traceability, then confirm compliance with the product-level thresholds. The regulation also broadens the definition of packaging to cover items such as coffee capsules. Eurostat data cited in the article put EU packaging waste at nearly 80 million tonnes in 2023, or almost 178 kilograms per resident. More than 35 kilograms per person was plastic, and less than half of that plastic was recycled.
The rules affect businesses throughout the packaging supply chain, including producers and importers, as well as retailers and hospitality businesses. Consumers sorting packaging waste are affected too. For readers interested in how regulatory changes affect everyday life in Spain, including vehicle inspections and compliance, a recent article on upcoming ITV requirements for 2022 vehicles offers further understanding into the changing regulatory field.
The full text of Regulation (EU) 2025/40 is available on the official EU legal portal, and the European Commission has published guidance on its phased implementation. With the general application date now passed, businesses placing food-contact packaging on the EU market must meet the applicable composition requirements alongside the regulation’s wider packaging rules.
