PPWR Substance Restrictions from 12 August 2026 – New Evidence Requirements for Businesses

From 12 August 2026, the substance restrictions under the EU Packaging and Packaging Waste Regulation (PPWR) will apply. For companies placing packaging on the market or using it, this translates into immediate need for action, particularly in the context of conformity assessment and technical documentation. 

Scope of Substance Restrictions 

The PPWR sets out requirements for hazardous substances in packaging and packaging components, including in particular: 

  • Heavy metals (lead, cadmium, mercury and hexavalent chromium), which remain subject to strict concentration limits  
  • PFAS (per- and polyfluoroalkyl substances) in food contact packaging, where specific restrictions apply  

Shift in Focus: From Compliance to Demonstrable Compliance 

The most significant change is not the existence of substance restrictions themselves, but the formalisation of evidence requirements. 

Going forward, companies must be able to demonstrate compliance as part of their conformity assessment documentation. This requires a structured and auditable approach to compliance management. 

Key implications include: 

  • Ensuring robust, verifiable evidence of substance compliance  
  • Embedding this evidence into technical documentation frameworks  
  • Aligning and, where necessary, upgrading existing compliance and product release processes  

In the absence of adequate documentation, compliance can no longer be assumed—it must be proven. 

Supply Chain: Critical for Compliance Delivery 

In practice, compliance will depend heavily on the availability of reliable data from the supply chain. Companies should therefore proactively engage with suppliers to ensure transparency and data readiness. 

Recommended measures include: 

  • Obtaining analytical test reports (e.g. for heavy metals and, where relevant, PFAS in food contact materials)  
  • Securing supplier declarations confirming regulatory compliance  
  • Implementing contractual safeguards to ensure ongoing data provision  

The objective is to build a consistent, traceable and audit-ready documentation framework across the entire supply chain. 

Act Now to Mitigate Risk 

With a fixed implementation date, companies should act without delay: 

  • Identify affected packaging portfolios  
  • Assess current data availability and gaps  
  • Engage suppliers on future evidence requirements  
  • Establish or enhance internal documentation and governance processes