From 12 August 2026 in the EU: Food contact packaging with PFAS above the legal thresholds may no longer be placed on the market. Every packaging type needs a valid Declaration of Conformity. EPR data must be complete, country-specific, and broken down by material. For Food & Beverage companies with wide SKU portfolios, seasonal packaging, and complex barrier materials, this is not just a compliance project - it is a data project.
This guide is written for packaging managers, quality teams, and regulatory affairs teams in the food industry. Not a generic PPWR overview - but the concrete challenges only Food & Beverage teams know.
PPWR-Deadline: 12 August 2026. From that date, all food-contact packaging placed on the EU market must comply with the PFAS limit values, present a valid Declaration of Conformity (DoC), and be reported in accordance with EPR. Packaging without proof may no longer be marketed.
Why Food & Beverage is the toughest PPWR sector
No other sector combines as many PPWR challenges at the same time as Food & Beverage. When you look at upcoming food packaging regulations, the pressure is highest here:
- The PFAS ban hits the core business. Grease- and moisture-resistant coatings are widely used in food contact packaging - in snack packs, burger wraps, bakery boxes, freezer trays, and barrier packaging for fresh products.
- Broad portfolios multiply the effort. If you manage 300, 500 or even 1,000+ packaging types - each with different formats, materials, and suppliers - you must create and maintain a DoC for every single one.
- Food packaging is the largest EPR category by weight. That means the highest financial exposure to EPR fees - and the biggest savings potential through more recyclable alternatives and smarter food packaging recycling choices.
- Seasonal packaging increases complexity. Christmas, Easter, and promotion packs are temporary variants - but each still needs its own compliance check.
- Retailers demand structured data. Retail groups such as REWE, Edeka, and Lidl increasingly require verifiable sustainability data from suppliers. Without structured packaging data, you risk losing your listing.
| Requirement | Effective from | F&B Special Consideration |
|---|---|---|
| PFAS limits (Art. 5 PPWR) | 12 August 2026 | Only for food-contact packaging - affects almost the entire F&B portfolio |
| Declaration of Conformity (DoC) | 12 August 2026 | Each packaging type requires a separate DoC - with 500+ SKUs, digitization is hardly feasible |
| EPR registration & reporting obligation | Already in effect / PPWR from 2026 | Food packaging is the largest EPR category by weight - highest fee burden |
| Recyclability (Class A/B) | Design requirement from 2030 | Multi-layer barriers, flexible foils and composite materials are high-risk formats |
| Labeling (material composition) | From 2028 (after Implementing Act) | Requires complete, structured material specification data per SKU |
PFAS in food contact packaging: The toughest hurdle first
The PFAS ban in food packaging is not new as a topic in food packaging law - but for many companies it is still not a fully clarified data reality. That is exactly where the problem lies.
From 12 August 2026, all food contact packaging is subject to limits of a maximum of 25 ppb per individual substance, 250 ppb total PFAS, and a threshold of 50 ppm for total fluorine content. If the total fluorine content exceeds 50 milligrams per kilogram, proof of origin is required.
Formats that use PFAS as a grease and moisture barrier are particularly affected:
- Coated paper and board (burger wraps, fast-food boxes, bakery bags)
- Flexible packaging films with barrier coatings
- Laminates and composite structures for frozen, fresh, and deli products
- Heat-sealable trays and bowls with protective layers
What this means in practice: Legal responsibility for compliance lies with the company that places the packaged product on the EU market - not with the packaging supplier. Even if your supplier manufactures the packaging, you as the brand or producer must prove and document PFAS conformity.
Companies such as Pickerd, Lebensbaum, and Paul Reber - Packa customers in the food segment - face exactly this challenge: assess PFAS risks across a broad portfolio, coordinate suppliers, and document all evidence centrally. Without digital packaging management, this is not scalable for hundreds of packaging types.
500+ SKUs, each needs a DoC - the DoC problem in Food & Beverage
From 12 August 2026, every packaging type placed on the EU market must have a valid PPWR Declaration of Conformity (DoC). Technically, every packaging type - not every SKU - needs a DoC. But in a typical Food & Beverage company with hundreds of items across different formats (bottle, can, pouch, tray, carton, glass, film), you quickly end up with dozens or even hundreds of distinct packaging types.
The core problem: The DoC is not a simple template exercise. It must include:
- Complete material specification (including coatings, adhesives, printing inks)
- PFAS test results or exemption statements
- Recyclability class and basis for the assessment
- Manufacturer data, supplier details, and technical documentation
- Reference to relevant PPWR articles and applied standards
For a company that has so far managed packaging data in Excel sheets, PDF specs, and ERP exports, creating DoCs is not a formality - it is a data problem. Without structured specification data, you cannot produce a valid DoC.
Packa digitizes technical data sheets from any format into structured, machine-readable data sets - in under 2.5 minutes per specification. Packa then uses this data to generate DoCs automatically, audit-proof, and for the entire portfolio at once.
Read more about the PPWR Declaration of Conformity and what it must contain.
EPR optimization: Food packaging pays the most - and can save the most
Food packaging is the largest product category by weight in the European EPR system. Concretely, that means: if you place many heavy packaging units on different EU markets, you will pay more EPR fees in total than almost any other industry.
At the same time, PPWR eco-modulation offers the biggest savings potential: In future, EPR fees will be tiered according to the environmental performance of the packaging - recyclable packaging with higher recycled content will pay less, hard-to-recycle packaging more.
For F&B teams, this means:
- Composite materials, multi-layer films, and coated board push EPR costs up
- Switching materials to mono-material plastics or recyclable paper reduces fees
- Country-specific EPR requirements vary significantly - if you sell in seven EU countries, you must register and report separately in seven countries
The good news: if your packaging data is fully structured, you can not only calculate EPR fees correctly, you can systematically optimize them in line with food packaging regulations and food packaging recycling targets.
Packa's EPR module calculates fees by material, by country, and by eco-modulation factor - and makes potential savings visible.
PPWR software for packaging management
Check your PPWR readinessRecyclability of complex food packaging: No longer a nice-to-have
For the first time, the PPWR defines at EU level what counts as recyclable packaging. From 1 January 2030, all packaging must be recyclable - at least 70 percent of the packaging weight must be materially recoverable; from 2038 this quota rises to 80 percent.
For Food & Beverage companies, this is a structural challenge. Many standard packaging formats in the sector currently do not fully meet these requirements:
- Flexible films (chips, frozen food, coffee) are often multi-layer and hard to recycle
- Food-contaminated packaging (grease, liquids) worsens recyclability
- Composite cartons (Tetra Pak-like formats) are more complex to recycle than mono-materials
- Shrink labels on PET bottles can reduce the recyclability class of the entire bottle
The PPWR classifies recyclability into three classes: A (>95% recyclable), B (>80%), and C (non-recyclable). From 1 January 2030, only packaging in classes A and B may be placed on the EU market.
What this already means today: if you do not know the recyclability class of your portfolio, you cannot realistically plan EPR costs, meet retailer requirements, or secure your CSRD reporting.
Retailer compliance: What REWE, Edeka, and Lidl will demand from 2026
Packaging managers in the food industry know: retailers set their own standards - often stricter than the legal minimum under food packaging law. What used to be "nice to have" will become a listing criterion from 2026 onwards:
- Recyclability class documented using a recognized method
- PFAS-free status for food contact packaging proven
- CO₂ footprint of the packaging as part of the supplier data sheet
- Recycled content share documented for each material type
The problem: this data has to be independent of any single supplier and exportable. If you have to piece it together from email threads, you will not meet the requirement - and you risk listing conditions or delistings.
Packa is the single source of truth for exactly this data: from one platform you can export recyclability reports, PFAS documentation, and CO₂ analyses for every retail partner and every authority.
Seasonal packaging: A predictable compliance trap
An underestimated topic: seasonal and promotional packaging. A Food & Beverage company with Christmas, Easter, and summer editions doubles or even triples its active packaging types temporarily. Every variant:
- Is its own packaging type in the sense of the PPWR
- Needs a DoC - even if it is only on the market for 6 weeks
- Must be PFAS-compliant
- Flows into the EPR reporting
In practice, this means: compliance processes must be scalable and automated. A company that creates DoCs manually cannot manage seasonal launch cycles in a PPWR-compliant way. Those who digitize packaging management create the basis to manage even temporary packaging variants efficiently and audit-proof.
The step-by-step plan: PPWR compliance for F&B by August 2026
Capture all packaging types (primary, secondary, and transport) by material, weight, and food contact. Don't forget seasonal and promotional packaging—each variant counts as its own packaging type and requires a DoC.
Check all food-contact packaging for PFAS. Prioritize high-risk formats: coated paper/cardboard, barrier layers, flexible films, laminates. Limits: max. 25 ppb per individual substance, 250 ppb total.
Engage suppliers with structured questionnaires on material composition, PFAS evidence, and recyclability. Store conformity proofs and certificates centrally.
For each packaging type, issue a complete DoC in accordance with PPWR Art. 35-39. The documentation must include material specifications, PFAS results, recyclability class, and producer data.
Take eco-modulation into account: multi-materials, non-recyclable films, and PFAS-containing packaging can incur higher EPR fees. Calculate potential fees by country and material.
REWE, Edeka, Lidl & Co. require structured sustainability data. The recyclability class, recycled content shares, and PFAS status must be exportable and independently verifiable.
Migrate packaging data from Excel, PDF, and ERP exports to a central, auditable platform. This is the only way to manage 500+ SKUs PPWR-compliant, automatically generate DoCs, and submit EPR filings on time.
Test your PPWR readiness now
How well is your F&B packaging portfolio prepared for 12 August 2026? Do the quick check:
How Packa makes Food & Beverage teams PPWR-ready
Packa is not generic compliance software. The platform was developed from 850+ real packaging projects with 300+ enterprise customers - many of them in Food & Beverage, confectionery, and specialty food. That is the difference between generic SaaS thinking and real industry expertise in food packaging regulations.
What Packa delivers for F&B teams in concrete terms:
AI-powered spec digitization
Technical data sheets - whether PDF, Excel, or ERP export - are converted into structured, machine-readable specification data in under 2.5 minutes. 100% digitized packaging data is the prerequisite for everything that follows: DoC, EPR, PFAS checks, recyclability analysis.
Automated DoC generation
Packa creates Declarations of Conformity from the digitized specification data - for individual SKUs or the entire portfolio. Seasonal packaging variants are also managed efficiently.
PFAS compliance tracking
All food contact packaging is checked for PFAS risk. Supplier questionnaires are managed in a structured workflow, and all evidence is stored centrally.
EPR calculation with eco-modulation
Packa calculates EPR fees by material, by country, and by recyclability class. Savings potential from material changes becomes immediately visible.
Sustainability cockpit for retailer reporting
Recyclability class, CO₂ footprint, recycled content share, and PFAS status in one exportable report - for retail partners, auditors, and CSRD reporting.
Practical compliance checklist: Making F&B packaging PPWR-ready
Your compact checklist for the next few weeks:
- Portfolio inventory - Record all packaging types (including seasonal packaging), document material and weight per type
- Food contact mapping - Identify all packaging that comes into contact with food
- Start PFAS screening - Prioritize high-risk formats (coated paper, barrier films, laminates), contact suppliers
- Start DoC creation - Begin with your most important packaging types, capture specification data completely
- Assess recyclability - Determine class A/B/C for complex formats, review composite materials
- Check EPR data - Ensure completeness and material-level detail for each country of sale
- Clarify retailer data format - What exactly do REWE, Edeka, Lidl require? Prepare export format
- Centralize your data base - Move away from Excel and scattered PDFs towards a single source of truth
Conclusion: Act now to avoid being excluded from the market
12 August 2026 is not an abstract regulatory date. It is the day on which packaging without a valid DoC, without PFAS documentation, and without EPR conformity must be removed from the EU market.
For Food & Beverage companies, this is not a small project. It is a structural transformation of how packaging data is captured, managed, and documented under modern food packaging law.
Companies that start today - build a portfolio inventory, approach suppliers in a structured way, centralize data - still have sufficient time. Those who wait risk more than fines. They risk exclusion from the market, loss of listings, and operational blockages in the launch process.
Scattered packaging data becomes a usable data foundation. With Packa. Pack the future.
Frequently asked questions (FAQ)
Does the PFAS ban apply to all food packaging or only to certain formats?
The PFAS ban pursuant to Art. 5 PPWR applies to all packaging that comes into contact with food - regardless of material. Particularly affected are coated paper and cardboard (e.g., burger wrappers, bakery bags), flexible films with barrier coatings, laminates and composite materials. From 12 August 2026, limits of max. 25 ppb per single substance and 250 ppb total will apply.
Does every single SKU need its own Declaration of Conformity (DoC)?
Technically, every packaging type (not every individual SKU) needs a DoC. In practice: if you use the same packaging construction for different products, one DoC for that type is sufficient. However, different material compositions, coatings or formats require separate DoCs. For portfolios with hundreds of SKUs and different packaging formats (bottles, cans, pouches, trays), dozens to hundreds of DoCs can quickly add up.
How does eco-modulation work in EPR for food packaging?
Eco-modulation means: EPR fees are tiered based on the environmental friendliness of the packaging. Packaging with higher recyclability, higher recycled content and without problematic substances pay less. Multi-layer composites, PFAS-containing coatings and non-recyclable flexible films can significantly increase the fees. This also makes recyclability analyses a cost-reducing instrument.
What are retailers like REWE or Edeka specifically demanding starting in 2026?
Wholesalers and supermarket chains are increasingly requiring suppliers to provide structured sustainability data: recyclability class, recycled content, CO₂ footprint per packaging unit and PFAS evidence. Those who cannot provide these data supplier-independent and digitally risk listing requirements or losses.
What happens if my packaging is not PPWR-compliant by 12 August 2026?
Non-compliant packaging may no longer be placed on the market in the EU as of 12 August 2026. That means: market exclusion, no listing with retail partners, potential fines. In the case of PFAS exceedances, the consequence is immediate: no placing on the market possible. Companies that start the transition now still have ample time for material changes, supplier alignment and DoC creation.
