EU PPWR Enforcement Just Weeks Away — PFAS and Reuse Requirements Now Finalized

Overview

The EU Packaging and Packaging Waste Regulation (PPWR), which entered into force on February 11, 2025, becomes fully applicable without exemption on August 12, 2026. On June 5, the European Commission published a Commission Notice with interpretive guidance that clarifies several points the industry had found confusing — how PFAS restrictions apply, how reuse targets are calculated, and the transition timeline for transport packaging.

References: Packaging Europe — Diving deeper into the EU's latest guidance on the PPWR, EUROPEN — Packaging News July 2026

With fewer than three weeks left before enforcement, Korea's Ministry of Food and Drug Safety has reportedly also notified domestic exporters of the need to prepare.

Reference: Cosin Korea — EU PPWR takes effect this August 12 (Korean)

1. PFAS Limits — Effective Immediately, No Grace Period

PFAS (per- and polyfluoroalkyl substances) restrictions on food-contact packaging take effect on August 12 with no grace period. According to Korean media reports, compliance requires meeting all three of the following thresholds simultaneously:

Reference: Ecomedia — EU packaging regulation PPWR: PFAS restrictions take full effect in 2026 (Korean)

According to Packaging Europe, the European Commission has also laid out a phased testing methodology: total fluorine is measured first, and a result below 50 mg/kg is presumed compliant; if that threshold is exceeded, further testing — such as pyrolysis-GC/MS — is used to confirm whether organic fluorine content exceeds the limit. (The precise relationship between this 50 mg/kg screening threshold and the three limits above should be re-verified against the full text of the Commission Notice.)

The scope covers not only intentionally added PFAS but also PFAS unintentionally introduced during manufacturing. Stock produced before August 12 is not subject to recall, but any packaging newly placed on the market after that date must comply immediately.

Korean reporting on the ground identifies water/oil-resistant coated paper food packaging, takeout containers, and recycled paper/plastic packaging as priority items for inspection.

Reference: KCTDI — "Can't export to Europe because of the packaging" (Korean)

2. Heavy Metal Content Ceiling

According to Korean reporting citing the Ministry of Food and Drug Safety's notice, the combined concentration of lead, cadmium, mercury, and hexavalent chromium may not exceed 100 mg/kg. This is a separate hazardous-substance minimization requirement that applies to all packaging, independent of the PFAS rules.

Reference: Cosin Korea — EU PPWR takes effect this August 12; Ministry of Food and Drug Safety urges quality control and documentation readiness (Korean)

3. Beverage Reuse Targets and the Transport Packaging Transition Timeline

According to Packaging Europe, final distributors must offer at least 10% of the beverages they sell in reusable packaging. B2B containers such as beer kegs are excluded from this calculation unless they ultimately reach the end consumer in sales packaging form.

For transport packaging, packaging placed on the market between February 2025 and August 2026 reportedly receives a grace period to meet new labeling rules by February 2032. Korean reporting indicates that corrugated boxes themselves are excluded from transport-packaging reuse targets, though some components may be included — with detailed criteria to be clarified in future implementing rules.

Reference: Packaging Europe — Diving deeper into the EU's latest guidance on the PPWR

From 2030, packaging must in principle be designed to be recyclable, and a minimum recyclability grade (Grade C, 70% or higher) will apply by 2035. Industry experts cited in Korean reporting note that multilayer film structures containing aluminum are likely to receive lower recyclability grades, since the recycling process struggles to separate the materials.

Reference: KCTDI — "Can't export to Europe because of the packaging" (Korean)

4. What Korean Exporters Need to Prepare

PPWR applies equally to packaging produced within the EU and to imported packaging or the packaging of imported products. According to Korean reporting, exporters should prioritize the following:

References: Cosin Korea — EU PPWR (Korean), KCTDI — field correspondent reporting (Korean)

Industry concerns note that non-compliance could result in direct and indirect costs, including customs rejection, recall expenses, and higher Extended Producer Responsibility (EPR) fees.

5. Outlook

In its July newsletter, EUROPEN referred to August 12 with the phrase "Ready or Not," suggesting that industry preparedness remains uneven. The newsletter also reportedly flagged disparities in EPR implementation across EU member states and concerns about fragmentation of the single market.

Reference: EUROPEN — Packaging News July 2026

With the enforcement date imminent, companies handling packaging destined for the EU market should move quickly on composition testing and documentation, while also factoring the 2028 label unification and 2030 recyclability grade requirements into their longer-term material transition planning.