PPWR: A New Era for Packaging – What Does It Mean for Food and Flexible Packaging?

The European Union’s new Packaging and Packaging Waste Regulation – PPWR (Packaging and Packaging Waste Regulation) – has now entered its general application phase.

What does this mean for a company that manufactures or uses flexible packaging for food products? The most important point is that not all packaging needs to be replaced on August 12. The PPWR introduces a longer transition process. Some requirements apply now, while others will become relevant in 2028 or as late as 2040.

What changes from August 12 onward?

The general application date of the PPWR is August 12, 2026. From this date, the Regulation is directly applicable in EU Member States, while Member States must also establish the national rules necessary for its implementation and enforcement. In Hungary, several legislative amendments required for the implementation of the PPWR have been introduced in 2026.

According to the National Association of Packaging and Material Handling (CSAOSZ), it is important to note that the complete PPWR framework is not yet available in its final, fully implementable form. Numerous detailed requirements will be defined by implementing and delegated acts to be adopted over the coming years.

For businesses, therefore, the task now is not to replace all packaging immediately, but rather to assess their existing packaging, collect the necessary data and documentation, and begin the transition towards structures that will meet future requirements.

What directly affects flexible food packaging?

One of the PPWR’s key objectives is to regulate the entire life cycle of packaging – from design and production through to waste management.

For flexible packaging – such as pouches, bags, films and laminated structures – four areas are particularly important:

1. Recyclability and “Design for Recycling”
2. The safety of food-contact packaging, including PFAS restrictions
3. Future requirements for recycled content in plastic packaging
4. Reducing packaging weight and volume and avoiding unnecessary packaging

These requirements are complemented by documentation, conformity assessment, labelling and EPR obligations.

Recyclable packaging: the biggest change for the flexible packaging sector

The basic principle of the PPWR is that all packaging placed on the market must be recyclable. However, the Regulation introduces the specific requirements related to this principle in stages.

The EU criteria required for detailed “Design for Recycling” assessments are to be adopted by the Commission by January 1, 2028. The specific recyclability requirements will apply from 2030, subject to the entry into force of the relevant legal acts. From 2035 onwards, it will also matter whether packaging waste is actually collected, sorted and recycled at an adequate scale.

This is particularly important for flexible packaging.

In the future, it will no longer be enough to simply describe packaging as “recyclable.” Questions such as these will become increasingly important:

What is it made of? What is its structure? How can it be sorted? Which recycling process can it enter? And does a system actually exist in practice where it can be recycled at an adequate scale?

This approach is already shaping the development of flexible packaging today. One of the key elements in preparing for the PPWR is the development of “Designed for Recycling” solutions and mono-material structures.

It is important to note, however, that the PPWR itself does not state that all flexible packaging must be mono-material. The key requirement is compliance with the recyclability criteria defined by the Regulation.

What does this mean in practice?

When developing flexible packaging, the following factors are becoming increasingly important:

• selecting the appropriate material structure,
• using compatible layers,
• reviewing unnecessarily complex laminates,
• ensuring the required barrier properties with the lowest possible material consumption,
• assessing the impact of printing inks, adhesives, coatings and other components,
• and demonstrating that the given structure meets the requirements of the relevant recycling system.

Sustainable packaging therefore does not simply mean “less plastic.” In food packaging, product safety, shelf life and the prevention of food waste remain fundamental considerations.

PFAS in food-contact packaging

The August 12 date has one aspect that is of immediate importance for flexible food packaging.

Under the PPWR, from August 12, 2026, food-contact packaging containing PFAS at or above the limits specified in the Regulation may not be placed on the market. The Regulation sets three specific limits: 25 ppb for individual PFAS, 250 ppb for the sum of specified PFAS, and 50 ppm for total PFAS, subject to the measurement conditions defined in the Regulation.

PFAS, or per- and polyfluoroalkyl substances – often referred to in plain language as “forever chemicals” – are highly persistent chemical compounds that break down very slowly in the environment. Since they can occur in a wide range of industrial applications, checking the entire material and supplier chain for food-contact packaging is becoming increasingly important.

The PPWR specifically requires compliance with the PFAS requirements to be demonstrated in the packaging’s technical documentation.

Therefore, it is not sufficient for a supplier simply to state verbally that a material is “PFAS-free.” Proper documentation and traceability of the relevant data are becoming increasingly important.

Less material, lower weight – but not at the expense of the product

One of the PPWR’s key principles is packaging minimisation.

From 2030, manufacturers and importers will have to design packaging so that its weight and volume are reduced to the minimum necessary to ensure its functionality. Solutions that unnecessarily increase packaging volume – such as false bottoms, double walls or unjustified layers – may become problematic.

This could even represent a competitive advantage for flexible packaging.

One of the key strengths of flexible packaging is precisely its ability to protect products while using relatively little material and having a low packaging weight.

Important deadlines at a glance

It is important to note that for some of these dates, the actual application of a requirement depends on the relevant implementing or delegated acts. Each deadline should therefore be interpreted together with the detailed legislation applicable to that particular requirement.