New EU packaging guidance: what the food industry needs to know

With the publication of the new interpretative guidance and the FAQs on the Packaging and Packaging Waste Regulation (PPWR), the European Commission has clarified several points that had remained only partially defined for food companies, importers, exporters and packaging suppliers. The aim is to make some practical aspects easier to understand: who is actually responsible, which obligations start in 2026, which ones will apply later, and which areas already require technical documentation and internal checks.

For companies operating in the food sector, understanding the timetable and the way the rules will apply is particularly useful. The PPWR will apply from 12 August 2026, but not all provisions follow the same schedule. Some rules apply immediately, while others depend on future delegated or implementing acts, and this is precisely where the Commission's guidance provides important clarification.

PFAS in food contact packaging

One of the most relevant clarifications for the food sector concerns PFAS in packaging intended for contact with food. From 12 August 2026, this packaging may no longer be placed on the market if it exceeds the limits laid down by the regulation. The guidance also makes it clear that there is no general sell-through period for existing stock: food contact packaging placed on the market after that date will have to comply, while packaging already placed on the market beforehand may remain in circulation and will not need to be withdrawn.

For companies, this has a practical operational impact. In the case of sales and grouped packaging, placing on the market generally occurs when the packaging is filled, because final stages such as sealing can also affect compliance. For transport and service packaging, by contrast, the relevant point is usually when the empty packaging is first placed on the market. The guidance also specifies that there are no exemptions for packaging containing recycled material.

Another useful point concerns controls. In the absence of a single harmonised EU method to verify PFAS in food contact packaging, the Commission proposes a multi-step control approach designed to help authorities and, indirectly, suppliers organise tests and checks more consistently.

Recyclability, general obligation from 2026 but full technical criteria later on

One of the most important clarifications concerns recyclability. The guidance confirms that the principle according to which all packaging placed on the market must be recyclable already applies from 12 August 2026. At the same time, however, it also makes clear that the full technical criteria on design for recycling will not apply straight away: the more detailed part of Article 6, linked to the Commission's delegated acts, will apply from 1 January 2030 or 24 months after those acts enter into force, if later.

In practical terms, this means that until then producers will need to continue relying on the previous framework for recoverability through material recycling and on the harmonised standards already in place. This is an important clarification because it avoids an overly rigid interpretation according to which, from August 2026, all the new PPWR technical criteria should already be fully available and applicable. The Commission also clarifies that the conformity assessment procedure for recyclability, in the sense of full PPWR compliance, does not yet apply until the delegated acts for this area enter into force.

Recycled content in plastic: exemptions and documentary evidence

The minimum recycled content targets for plastic packaging will not start in 2026, but from 1 January 2030 or three years after the entry into force of the implementing act setting out how recycled content is to be calculated, if later. Here again, the Commission provides clarifications on practical cases that are particularly relevant for the food sector.

The first point is that some exemptions apply directly, without the need for prior authorisation from the Commission or a national authority. This is the case for plastic packaging intended for food contact where the use of recycled content would create a risk to human health and lead to non-compliance with food contact materials legislation. However, this exemption is not automatic in practical terms: the manufacturer must demonstrate it in the technical documentation, specifying the polymer concerned and documenting, among other things, the absence of an authorised recycling technology available at industrial scale for that specific use.

A second clarification concerns the exemptions linked to recycled content in plastic packaging. On the one hand, Article 7(5)(b) excludes from the obligation plastic parts accounting for less than 5% of the total weight of the packaging unit. This may apply, for example, to certain labels or small secondary plastic components. On the other hand, the Commission clarifies that in some cases the exemption depends not on the individual component itself, but on the type of packaging it is used with. This is why plastic caps used for milk packaging must comply with future recycled content targets, since milk does not fall within the exempt categories. The situation is different for caps used in infant formula milk powder packaging, which benefit from the specific exemption laid down in Article 7(4)(g). In other words, what matters is not only the cap itself, but the regime that applies to the packaging unit as a whole.

Importers should also keep another point in mind. When it comes to recycled plastic intended for food contact use, imported packaging must also comply with EU rules on recycled plastics for food contact applications. It is therefore not enough to source recycled material outside the Union - companies must also be able to show that the material meets the applicable European requirements.

Compostability: the guidance narrows the scope and clarifies the cases of coffee and tea

The new European documents also help clear up a common misunderstanding. In particular, the PPWR does not promote generalised compostability for packaging, but limits it to specific applications. For the food sector, the most relevant point concerns filters, bags and single-serve units for tea and coffee.

The FAQs clarify that permeable bags for tea, coffee or other beverages, as well as certain "soft after-use" single-serve units, are among the formats for which compostability is mandatory. The situation is different for non-permeable capsules intended for machines: they are not automatically subject to a general compostability requirement at EU level. Member States may nevertheless require it within their territory where adequate organic waste collection and treatment infrastructure is in place. The Commission also clarifies that the possibility for Member States to require compostability for certain beverage capsules does not apply to metal capsules - in other words, Member States cannot ban them on that basis under the PPWR.

Another useful timing detail is that the article on compostability will apply from 12 February 2028. Until then, Member States are not obliged to accept these packaging formats in the bio-waste stream, although the Commission encourages them to do so.

Packaging reduction and empty space: the clarifications that affect design

The guidance and FAQs also address another issue that is likely to affect packaging development: packaging minimisation. Both parts of Article 10 will apply from 1 January 2030. The Commission clarifies that elements such as double walls, false bottoms, front flaps and additional layers may not be used simply to create the impression of a larger product volume. They will be allowed only where they genuinely serve a packaging function or add a legitimate function, and this will have to be justified in the technical documentation.

For the food sector, the relationship between minimisation and empty space is also particularly relevant. The 50% limit does not apply to all packaging, but only to grouped, transport and e-commerce packaging. For sales packaging, by contrast, there is no single numerical threshold that applies across the board, but there is still an obligation to reduce empty space to the minimum necessary and to be able to prove it. The FAQs also specify that filler materials such as paper, air cushions, foam, shavings or polystyrene chips are treated, for calculation purposes, as empty space.

As a general rule, design protection must be kept separate from the empty-space limit. Even where certain packaging features may be justified by design considerations, this does not automatically allow companies to exceed the 50% empty-space threshold laid down in Article 24 for the packaging formats to which it applies.

Labelling: towards a single European system

For companies selling across multiple EU markets, one of the most relevant points concerns harmonised labelling. The European rules on pictograms for correct waste sorting will apply from 12 August 2028 or 24 months after the implementing act defining their specifications enters into force, if later. The Commission clarifies that the labelling framework set out in Article 12 is exhaustive and fully harmonised. In practice, Member States will not be able to maintain other national mandatory disposal-labelling systems alongside it beyond the transitional period.

The FAQs also clarify some useful boundaries. The obligation to provide sorting information does not apply to transport packaging, except for e-commerce packaging, nor to packaging covered by a deposit return system. In addition, information related to extended producer responsibility must not appear as a physical label, since the regulation allows this information only in digital format.

Another point worth noting is that the old material identification codes based on Decision 97/129/EC may continue to be used only until 12 August 2028. After that date, they will no longer be permitted. Finally, the guidance clarifies that indicating recycled or bio-based content on the label is not mandatory; however, operators choosing to do so will have to comply with the relevant EU harmonised technical specifications.

Bans: fruit and vegetables, HoReCa and beverages

Many of the PPWR bans will apply from 2030, but the new documentation already helps identify where the main areas of focus will be. In food service, one important clarification concerns single-use plastic portions for condiments, preserves, sauces, coffee creamers, sugar and seasonings in the HoReCa channel. The Commission confirms that the explicit exemptions are limited to take-away ready food intended for immediate consumption and the healthcare sector. At present, there is no legal basis to extend those derogations to other situations.

For fruit and vegetables, the FAQs reiterate that fresh unprocessed fruit and vegetable products under 1.5 kg may not be sold in pre-packaged form, except in cases that will be clarified later in the Commission's specific guidelines.

By contrast, fresh-cut products, such as bagged salads, are likely to remain outside this specific ban. The FAQs clarify that the restriction concerns fresh fruit and vegetables that are not altered. As a result, products that have already been washed, selected, cut or prepared for consumption do not appear, in general terms, to fall within the notion of fresh unprocessed fruit and vegetables. That said, the Commission's future guidelines are expected to provide more detailed clarification on this point.

As regards multipacks, the ban will apply to single-use plastic grouped packaging used as convenience packaging at the point of sale when it is designed to facilitate transport and encourage the purchase of multiple units. This means the ban concerns only retail points of sale intended for the final consumer, and not packaging used in B2B supply chain transactions.

For the beverage sector, the clarifications on reuse are also worth following closely. Final distributors, including bars and restaurants, are generally covered by the reuse targets for beverages from 2030, although important exemptions remain, including one for outlets with a surface area below 100 m².

As for deposit return systems (DRS), the key benchmark remains the 90% separate collection target by 1 January 2029 for single-use plastic bottles and metal beverage containers up to three litres, subject to any national exemptions available in the cases provided for. If that threshold is not met, Member States will have to ensure that a deposit return system is in operation for the formats concerned, unless they have obtained, within the required timeframe, an exemption based on at least 80% collection in 2026 and a credible plan to reach 90% by 2029.

Operational priorities for food companies and suppliers

In light of these clarifications, the work that companies need to start now is fairly clear. The first step is a mapping of food contact packaging, with particular attention to PFAS, available recycling technologies and material documentation. At the same time, it makes sense to distinguish early between what requires short-term adjustments and what will depend on later acts, avoiding both overreaction and delay.

Some of the points that food & beverage companies and packaging suppliers should keep under close review are the following:

• check which food contact formats are most exposed to the PFAS issue and gather the related compliance evidence;
• review packaging projects based on overpackaging, unnecessary thickness or artificially enlarged perceived volumes;
• clarify, for each product line and each market, who the manufacturer is (generally the party that defines the packaging and is responsible for compliance) and who the producer is (the operator that places it on the market for the first time in the individual Member State for EPR purposes);
• prepare a strategy for future obligations relating to the share of recycled content, especially for plastics used in contact with food;
• closely monitor future implementing acts (which make the legislation operational) on labelling, recycled content calculation, empty space and recycling-oriented packaging design.

In other words, the new guidance helps companies understand where action is needed immediately and where compliance will still depend on later technical steps. For the food industry, this is already a useful indication for preparing for the operational phase. Packaging is not only an environmental or communication issue - it also affects planning, design, legal responsibility, market access and supply chain organisation.