PPWR and Food Packaging Suppliers: A Guide for EU Importers

Short answer: the PPWR is the EU Packaging and Packaging Waste Regulation, officially Regulation (EU) 2025/40. It has applied directly to packaging on the EU market since August 12, 2026. If you buy food containers from outside the EU, your role decides who issues the declaration of conformity.

This guide is for EU importers, distributors and food brands that source food containers from outside the EU, for example from Turkey. For each obligation, we give the article number and show who it binds and from when. We also list the questions to ask your supplier and the documents a non-EU supplier should provide.

The information reflects the official text on EUR-Lex as of October 19, 2026.

What is the PPWR, and what changed for food packaging?

The PPWR brings the EU's packaging rules together in a single regulation. The European Parliament and the Council signed the text on December 19, 2024, and the Official Journal of the EU published it on January 22, 2025. The regulation entered into force on February 11, 2025 and has applied since August 12, 2026 (Article 71).

The previous framework was the Packaging Directive 94/62/EC. The regulation repealed that directive as of August 12, 2026, apart from some transitional provisions (Article 70). The difference is simple: member states applied the directive through national laws, while the regulation is directly binding in every member state.

The regulation covers packaging design, substances, labeling, waste management and reuse (Article 1). However, most rules do not start on the same day. So start with the timeline.

PPWR timeline: when does each rule apply?

The PPWR uses three kinds of dates: fixed dates, a "this date or a set period after a secondary act, whichever is later" pattern, and deadlines for the Commission. The table below lists the rules that matter to food container buyers, with the article in the official text.

The "whichever is later" pattern matters most. If the Commission adopts the relevant act late, the start date also moves later. For example, the recycled content rule for plastic starts at least 3 years after the act that sets the calculation method.

Who is the manufacturer when you source food packaging from outside the EU?

The PPWR has no "exporter" or "buyer" role; it ties each obligation to a role in the supply chain. The core roles are manufacturer, supplier, importer and distributor (Article 3(1), points 13, 16, 17 and 18). The manufacturer issues the EU declaration of conformity and carries legal responsibility for it (Article 39(4)).

According to the Commission guidance of June 10, 2026, the manufacturer of service packaging, such as takeaway containers filled at the point of sale, is usually the company that makes the container. However, if the container bears the user's name or trademark, the user becomes the manufacturer. For sales packaging, the manufacturer is usually the brand owner that fills and closes the packaging.

The guidance also stresses that a supply chain has only one manufacturer. So put the split of roles in writing in your supply contract.

What PPWR requirements apply since August 12, 2026?

Five core obligations apply today. They do not wait for the 2030 rules, so they affect every shipment placed on the EU market after August 2026.

• Heavy metals: the total of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg (Article 5(4)).
• PFAS: food-contact packaging has limits of 25 ppb for any single PFAS, 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS, including polymeric PFAS (Article 5(5)).
• Documents: before placing packaging on the market, the manufacturer draws up technical documentation under Annex VII and issues an EU declaration of conformity (Article 15(2)).
• Traceability: the packaging carries a type, batch or serial number and the manufacturer's name and postal address; if its size does not allow this, the information goes in an accompanying document (Article 15(5)-(6)).
• Importer details: the EU importer also adds its name and address to the packaging or to an accompanying document (Article 18(3)).

The Commission guidance highlights two more details. First, there is no sell-through period for the PFAS limits. Second, for imported packaging, the moment of placing on the market is release for free circulation at customs.

Recyclability has a transitional regime. According to the guidance, until the act that sets design criteria applies, the manufacturer follows the requirements of the old directive and the EN 13430:2004 standard. So no separate conformity assessment for recyclability is needed in this period.

What do the EU declaration of conformity and technical documentation include?

The EU declaration of conformity is the document in which the manufacturer states, under its own responsibility, that the packaging meets Articles 5 to 12 (Article 39). The technical documentation is the evidence behind that declaration. The procedure is internal production control by the manufacturer (Annex VII, Module A), so there is no separate "PPWR certificate".

Under Annex VII, the technical documentation contains the following parts, where applicable:

• a general description of the packaging and its intended use,
• design, manufacturing drawings and component materials,
• the harmonized standards or other technical specifications applied,
• an explanation of how the assessments under Articles 6, 10 and 11 were carried out,
• test reports.

The declaration follows the model in Annex VIII: declaration number, manufacturer's name and address, a description that allows the packaging to be traced, the legislation applied and a signature. It must also be in the language that the member state where the packaging is sold requires (Article 39(2)).

For single-use packaging, the manufacturer keeps the declaration and the documentation for 5 years (Article 15(3)). If a national authority asks, the manufacturer provides the documents within 10 days (Article 15(10)).

Is the food-contact declaration the same as the PPWR declaration?

No, the two documents answer different questions. The food-contact declaration under Regulation (EU) 10/2011 shows that migration from the container into food stays within limits. The PPWR declaration, by contrast, covers heavy metals, PFAS and the sustainability requirements.

So file the two separately. Even so, Article 16(2) requires the supplier to include food-contact documents in the information it gives the manufacturer. We explain food-contact documents in detail in our food-safe plastics guide.

What changes for PET and PP thermoformed containers?

PET and PP containers follow the same PPWR rules; the real difference is the minimum recycled content in plastic. The regulation classes food containers as "contact-sensitive packaging" (Article 3(1), point 49). In that group, the rate for packaging with PET as the major component is higher than for other plastics.

Article 7(5) contains two exemptions. First, the rate does not apply if recycled content poses a threat to human health and leads to non-compliance with food law. Second, plastic parts that make up less than 5% of the total weight of the packaging unit are out of scope.

One more detail matters when your supplier is in Turkey. Plastic collected and recycled in a third country counts toward the rate only if equivalent standards apply (Article 7(3)). For rPET and mono-material design, see our plastic recycling codes article; for how the two materials differ in use, see our PP vs PET guide.

Are single-use plastic containers banned in HoReCa?

Takeaway containers are not banned, because the restriction covers food and drinks filled and consumed on the premises. From January 1, 2030, the third entry in Annex V restricts single-use plastic trays, plates, cups, bags and boxes for on-site consumption in HoReCa (Article 25(1)). Businesses without access to drinking water are exempt.

Sauce portions and fresh fruit and vegetable packaging

Annex V has two more entries that matter to container buyers. The fourth entry restricts single-use plastic portion packaging in HoReCa for sauces, condiments, jam, coffee creamer, sugar and seasonings. Portions supplied with takeaway food are exempt, a distinction that matters if you buy sauce cups.

The second entry restricts single-use plastic packaging for unprocessed fresh fruit and vegetables under 1.5 kg. However, member states may grant justified exemptions.

Composite packaging, national rules and guidance

According to the Commission guidance, composite packaging with at least 5% plastic also falls under these restrictions. Some member states may keep national restrictions that match the second and third entries until January 1, 2030 (Article 70(4)). Guidance with examples for Annex V is due by February 12, 2027; it has not been published yet.

What are the reuse and refill rules for takeaway?

These rules bind the final distributor in the EU, meaning the restaurant or cafe, not the container. From February 12, 2027, HoReCa businesses that offer takeaway must provide a system for filling the customer's own container (Article 32). They may not charge more than for the same product in single-use packaging.

From February 12, 2028, the same businesses must also offer a reuse option; micro-enterprises are exempt (Article 33). From 2030, they also strive to offer 10% of their products in that format. So single-use container sales continue, but restaurants add a second option.

Transport packaging also has reuse targets (Article 29). Cardboard boxes, however, are exempt from these targets (Article 29(4)(d)). Our takeaway container selection guide covers the practical criteria on the container side.

When do the empty space, minimization and labeling rules start?

These three rules start between 2028 and 2030, and all three depend on Commission secondary legislation. So wait for the official methods before you change container designs.

Packaging minimization

From January 1, 2030, the manufacturer reduces packaging weight and volume to the minimum its function needs (Article 10(1)). Designs that only make packaging look bigger, such as double walls and false bottoms, are banned. Until then, the existing EN 13428:2004 framework continues.

Empty space ratio

Businesses that fill grouped, transport and e-commerce packaging keep the empty space ratio at 50% or less (Article 24(1)). The rule starts on January 1, 2030 or 3 years after the act that sets the calculation method. The Commission is due to adopt that act by February 12, 2028; it has not been published yet.

EU harmonized label

The EU label that shows material composition with pictograms becomes mandatory on August 12, 2028 or 24 months after the relevant act (Article 12(1)). The regulation expected that act by August 12, 2026. However, as of October 19, 2026, no labeling act has been published on EUR-Lex.

PPWR importer obligations: what to ask your food packaging supplier

If you are the importer, you must verify the manufacturer's work before you place the packaging on the market (Article 18(2)). If you are the manufacturer, you need the information that Article 16 requires from your supplier. In both cases, ask these questions at the quote stage:

• Who is the manufacturer of this container under the PPWR, and who issues the EU declaration of conformity?
• Which product codes, dimensions and lids does the declaration cover?
• What test or supplier data covers the heavy metal total and the PFAS limits?
• Are the batch number and the manufacturer's address on the container or in an accompanying document?
• Who adds the importer details, and where?
• Is the food-contact declaration under Regulation (EU) 10/2011 up to date?
• Are the bowl and the lid made from the same polymer?
• Does the plastic contain recycled content, and if so, how is it documented?

The PPWR information note from Turkey's Ministry of Trade (in Turkish) makes a useful point: not every customer request comes from the PPWR. Some forms come from internal company policy. So tell your supplier which requests rest on the regulation and which on your own policy.

What documents should a non-EU food packaging supplier provide?

If your supplier is the manufacturer, the technical documentation and the EU declaration of conformity are its job. If it is a supplier under Article 16, it prepares the information package that feeds your own documentation. In both cases, the list below helps.

1. Product family list: product code, dimensions, material and matching lid.
2. Raw material documents: declarations and material composition from the resin or sheet supplier.
3. Substance data: heavy metal total and, for food-contact packaging, PFAS; inks and labels included.
4. Food-contact file: food-contact declaration and migration test reports.
5. Batch system: a record that links the code to the technical documentation and the declaration.
6. EU declaration of conformity: if the supplier is the manufacturer, in the language your country requires.
7. Retention: at least 5 years for single-use packaging.

According to the Ministry note, one declaration can cover several sizes of containers made from the same material, if the size difference does not affect conformity. The reasoning must still appear in the technical documentation. The note also states that no general provision requires the declaration to go to customs with every import.

Shipping documents are a separate topic; we summarize loading and export documents in our container and carton calculation guide.

Secondary legislation not yet published

Many PPWR rules depend on implementing and delegated acts that the Commission has yet to adopt. As of October 19, 2026, the only binding act on EUR-Lex based on this regulation is Delegated Decision (EU) 2026/429 on pallet wrapping and straps. The Commission also published a guidance notice in June 2026 and an FAQ document in August 2026.

The following acts have not been published yet, so their content is not known:

• EU harmonized label and format rules (Article 12(6), due August 12, 2026).
• Method for calculating and verifying recycled content (Article 7(8), December 31, 2026).
• Sustainability criteria for plastic recycling technologies (Article 7(9), December 31, 2026).
• Equivalence of plastic collected and recycled in third countries (Article 7(10), December 31, 2026).
• Annex V guidance (Article 25(6), February 12, 2027).
• Design for recycling criteria and performance grades (Article 6(4), January 1, 2028).
• Calculation method for the empty space ratio (Article 24(2), February 12, 2028).
• Assessment method for recycled at scale (Article 6(5), January 1, 2030).

So treat any document that promises "full PPWR compliance" today with caution. No one can yet show the criteria for the 2030 rules in an official text.

Sourcing food containers from Dipack for the EU market

Dipack is a brand of Onursan Ambalaj and makes PET and PP containers by thermoforming at its factory in Dursunbey (Balıkesir), Turkey. The plant is BRCGS certified, and the products ship across Turkey and to more than 30 countries. The company makes its containers from a single polymer, meaning mono-material PET or PP.

However, in sets where the bowl and the lid use different polymers, as with cheese containers, assess the two parts separately. For custom packaging that carries your logo, the PPWR manufacturer role usually moves to you. You can find company details on our about us page.

Document and data needs vary by product and order structure. So share your PPWR questions with us at the quote stage, and we will confirm before the order which information we can provide and with which document.

Frequently asked questions about the PPWR