The PPWR and the food industry – what do the new packaging regulations mean for food producers?

Food producers in the EU have long operated in a strictly regulated environment – food safety, labelling, production hygiene. The PPWR adds a new, equally demanding layer to this framework: regulations on packaging. For the food industry, the PPWR presents an exceptionally complex challenge, as food packaging must simultaneously meet requirements for food contact safety, recyclability and minimisation – and these objectives do not always go hand in hand.

Specific requirements for food-contact packaging

Under the PPWR, packaging that comes into direct contact with food is subject to stricter requirements than other categories of packaging – this stems from the need to protect both the environment and consumer health.

The most significant change, which comes into force on 12 August 2026, is a ban on exceeding the limits for PFAS (per- and polyfluoroalkyl substances) in packaging intended for contact with food. From 12 August 2026, a restriction on PFAS in food-contact packaging will come into force if they exceed specified thresholds. Specifically: food contact packaging must not exceed 25 ppb for a single PFAS compound, 250 ppb for the total PFAS content, or 50 ppm of total fluorine. This applies primarily to packaging used for greasy takeaway food – paper trays, boxes and bags – which are commonly treated with fluorinated compounds to make them grease-resistant. Food manufacturers and distributors must now verify the composition of their packaging and – if it contains PFAS above the permitted thresholds – switch to alternative solutions.

A second specific issue is the recycled content of plastic packaging intended for food contact. For plastic packaging intended for food contact, a 10 per cent recycled content will be required from 2030 and 50 per cent from 2040. This presents a technological challenge – recycled material must meet stringent safety requirements for food contact, and its availability on the market is limited. The limited availability of recycled materials will prompt manufacturers to seek alternatives – such as the use of paper. However, paper is not a universal substitute for plastics. It has limited barrier properties, lower process resistance and, in many applications, does not meet the parameters necessary to protect the product.

Recyclability of food packaging – a challenge for multi-material laminates

Food packaging is one of the most challenging categories in terms of meeting the PPWR’s recyclability requirements. Multi-material laminate structures – combining films made from different plastics, barrier coatings, metallisation and labels made from various materials – provide excellent food protection, but are difficult or impossible to recycle in the municipal waste stream.

The PPWR introduces a recyclability classification for packaging on a scale from A to E. From 2030, Class D packaging will be phased out of the market. From 2038, only Class A or B packaging will be permitted. For food manufacturers using multi-material protective packaging – films for cold cuts, cheese packaging, multi-layer meat trays, sauce sachets – this means they will have to redesign their packaging or change their material suppliers.

Processed food manufacturers will face the need to replace multi-material laminates with recyclable packaging. This is not a change that can be implemented overnight – it requires time for technical testing, verification of food safety in the new packaging, consumer acceptance and negotiations with suppliers. Companies that begin this process now will have a realistic chance of smoothly meeting the 2030 requirements. You can read more about how to design packaging that complies with the PPWR and what factors to take into account right from the design stage in the article ‘Designing PPWR-compliant packaging – what to look out for?’.

The obligation to offer reusable packaging in the food and drink sector

One of the most revolutionary aspects of the PPWR for the food industry is the obligation to offer reusable packaging schemes in specific market segments.

The PPWR introduces an obligation to offer reuse in the takeaway food and drink sector. Catering and takeaway outlets will have to ensure that consumers can bring their own reusable packaging and have their product dispensed into it. This applies to drinks, takeaway meals and other food products served directly to the consumer.

For fresh food suppliers and beverage producers, the requirements go further. By 2030, fresh food suppliers must switch to reusable packaging for secondary packaging. Reuse targets will increase in subsequent years – by 2030, 40 per cent of transport packaging must be reusable, and by 2040 this figure will rise to 70 per cent.

Implementing reuse systems is not just a change in packaging – it is a change in the logistics model. Reusable packaging requires tracking, a return system, cleaning and re-entry into circulation. For the food industry, where hygiene requirements are particularly stringent, building such systems requires careful planning and appropriate infrastructure investment.

The food industry is just one of the sectors covered by the new regulations. The PPWR introduces obligations covering all stages of the packaging life cycle – from design to the management of packaging waste.