Packaging Legislation Update on PPWR, BPA and PFAS

The roll-out of environmental taxes continues apace, with the full force of the EU’s PPWR coming into effect on 12th August 2026. Packaging legislation is a potential minefield of taxation and tariffs, with movable timelines and liability governed by geography, the type of packaging and even the size of your business. Packaging regulations can be tricky to navigate, so in this article, we’ve pulled out the key points and the potential implications of PPWR for your business.  

EU Packaging Legislation Update: PPWR

The EU's Packaging and Packaging Waste Regulation (PPWR) is a comprehensive piece of legislation, and it comes into force on August 12th 2026. PPWR includes statutes on everything from what packaging can be made from to its recyclability. The main focus of PPWR includes:

• Chemical restrictions on BPA and PFAS
• Designing for Recyclability
• Increasing Recycled Content
• Standardised Labelling across the EU
• Reducing empty space in packaging 

PPWR Chemical Restrictions August 2026

The ban on the use of potentially harmful chemicals in packaging is one of the first parts of PPWR to be implemented. The two categories of harmful substances to be banned are BPAs and PFAS; a ban on the use of both happens this summer. 

• BPA-Ban: July 20th 2026: No packaging containing BPAs intended for food contact can be placed on the market. This escalates to a ban on the use of any packaging containing BPA for food use by July 20th 2027.
• PFAS Ban: August 12th 2026: Packaging containing perfluoroalkyl and polyfluoroalkyl substances (PFAS), or“forever chemicals”, intended for food contact is banned.

PPWR Mandatory Recyclability by 1st January 2030

The EU has introduced a Design for Recycling (DfR) mandate for all packaging. This means packaging must be designed for recyclability. To drive this initiative, the EU is introducing an A to E recyclability grading system.

Packaging will be graded from A to E based on how much of the material can be re-used. It will also mean that certain types of packaging, those graded as D or E (70% or less recyclable), will be banned from use in the EU altogether by 2030.

PPWR means that ultimately, all packaging placed on the EU market must be legally recyclable. This means that recyclability will become a mandatory legal requirement for all packaging used in Europe after 2030.

One of the key aims of PPWR is to make all packaging recyclable by 2030

PPWR Mandatory Recycled Content 2030

In tandem with this, the EU is moving the dial on the amount of recycled content that must be used. This is likely to be a minimum of 30% recycled plastic for PET and single-use plastic bottles, 10% for contact-sensitive plastic packaging (such as food packaging) and 35% for all other plastic packaging by 2030.

However, the targets for PCR (Post-Consumer Recycled) material are not static. The EU is increasing the amount of post-consumer recycled plastic so that by 2040 the minimum percentages will be 50% for contact-sensitive PET plastics, 25% for contact-sensitive non-PET plastics, 65% for single-use beverage bottles and 65% for all other plastic packaging (such as soft plastics).

PPWR Standardised Labelling August 2028 (Expected deadline)

The EU is introducing a harmonised recycling labelling system. This means that recycling logos and instructions will be standardised across Europe. From August 12th 2026, the exact graphic designs will be adopted. If packaging is made from multiple components, each part must be separately labelled.

A period of transition will follow to allow businesses to adapt to these changes, including changes to artwork and labelling. The current timeline is for standardised labelling to be required from August 2028, although this is still subject to review. 

PPWR Void Space Limits

PPWR states that from August 12th 2026, businesses should seek to minimise empty, "wasted" space in their packaging. The hard, legally binding 50% rule is not slated to come into force for another four years. This gives businesses time to test and adapt the type of packaging they use.

Phase 1: August 12th 2026: General Minimisation: Manufacturers and retailers must reduce packaging weight and volume to a minimum

Phase 2: January 1st 2030: Empty Space Cap: Excessive packaging ban, including a mandatory 50% empty space maximum for e-commerce and transport shipments

How will PPWR legislation affect UK businesses?

PPWR packaging legislation is a uniform directive, which means it applies equally to all 27 EU member states. Any UK company exporting goods into the EU market must therefore comply with PPWR. Failure to meet strict PPWR standards could lead to shipments being rejected at the border and long supply chain delays. 

PPWR has massive operational and financial implications for UK companies:

• Mandatory Export Compliance: Any UK business exporting goods to the EU must fully comply with PPWR standards. Non-compliant items risk immediate rejection at EU borders, customs delays, or heavy fines.
• The Windsor Framework (see below): Most PPWR requirements apply directly to the Northern Ireland market, creating a dual-regulatory landscape for British businesses operating across the UK.
• Supply Chain & Import Shifts: UK companies importing from the EU will see changes in incoming packaging dimensions, materials, and labels, requiring logistical adaptations in British warehouses.
• Commercial Convergence: Leading UK retailers are already aligning their internal supplier standards with PPWR rules to prevent dual-inventory costs, making compliance a necessity even for domestic-only UK suppliers.

Northern Ireland, The Windsor Agreement and Packaging Legislation

Northern Ireland has dual market alignment, so both UK and EU legislation applies. The Windsor Agreement is applied using a Red Lane and Green Lane system. The Red Lane is for goods that may enter the Irish or EU market; these shipments must fully comply with all EU rules, such as those mandated by PPWR. The Green Lane is the UK’s Internal Market Scheme, which is for goods solely destined for Northern Ireland. Notable exceptions to this are medicines and “not for EU” agrifoods, which are exempt from EU packaging legislation. 

How can Invopak help with PPWR legislation?

PPWR may be EU legislation, but we understand that it is affecting many of our UK customers. We have made some moves ahead of the legislation, and can also help ensure your packaging is compliant with PPWR.

• A Declaration of Conformity (DoC). We can supply DoCs for EU-bound goods, including all the technical documentation necessary for PPWR compliance. Please speak to your account manager or get in touch with the Invopak team if you need DoCs. This will also cover harmful substances, such as PFAS and heavy metals; separate PFAS statements can also be supplied when applicable
• Recyclability: All of our products are recyclable and carry either the recycling triangle or stamp. Most of our rigid plastic and metal containers are made of a single type of material, so they are easy to recycle
• BPA-free Packaging: Our HDPE and PP plastic buckets, bottles, tubs and jerry cans are all BPA-free, and our Tournaire aluminium bottles are switching to a BPA-free lacquer finish. BPA-free lacquer is also an available option on Invo Metal cans.
• Recycled Plastic Packaging: We stock a wide selection of recycled plastic packaging, including jerry cans, buckets, IBCs, tighthead barrels and drums
• Fluorinated products are PPWR compliant: The PFAS level of our fluorinated packaging is below the minimum threshold levels
• Product specifications can be supplied on request

Our team are always on hand to help, so whether you need a DoC, would like a packaging audit or product samples for testing, please get in touch or speak to your account manager.