The new PPWR enact a single set of rules to prevent unnecessary packaging waste and to promote reuse, refill and recycling to contribute to circular economy and climate neutrality by 2050.
Three obligations take effect this week: A mandatory EU Declaration of Conformity, a PFAS ban in food-contact packaging, and producer registration in the national packaging register of every member state where packaging is placed on the market.
However, the European Commission (EC) has urged authorities in Member State to give operators a reasonable period of time to take corrective action, before any product ban or withdrawals.
“August 12th is not a cliff edge,” said Valerie Vercammen, managing director of be-sup, the Belgian federation of the food supplements industry.
“Under Article 62, an authority that finds non-compliance has to require the operator to correct it and allow a reasonable period before any prohibition or recall,” she added, noting that authorities will assess whether a company can show a documented, good-faith position.
Industry’s obligations today
As of Aug. 12, every company placing products on the EU market must be able to show that they have assessed their packaging, documented their compliance plan and started steps toward minimizing, recycling and safely sourcing materials.
All assessments and decisions should be documented, including explanations of why weight or volume cannot be further reduced without compromising product stability or consumer use.
Also in force from this week, the new regulations ban the intentional use of per and polyfluoroalkyl substances (PFAS), or ‘forever chemicals’, in food-contact packaging. No packaging intended for food contact can contain PFAS at or above 25 ppb for any individually-measured PFAS, or 250 ppb for the sum of targeted PFAS. The limits apply to the base material as well as any inks, varnishes, coatings and adhesives used on labels or seals.
This is despite the fact that there is not currently a harmonized analytical method for testing these chemicals adopted across Member States.
Timeline of changes
Moving forward, the EC will develop guidance for measuring and verifying recycled plastic content by Dec. 31, 2026, including criteria for recognizing recycled material sourced from outside the EU as equivalent to material recycled within the bloc.
By Feb. 12, 2027, it will require standards bodies to develop or update methods for measuring and checking whether packaging meets minimization requirements. The design-for-recycling criteria are expected to be available from January 2028.
From Jan. 1, 2030, the empty space ratio will be capped at 50% for grouped, transport and e-commerce packaging, and certain single-use formats, including single-dose and sachet formats, will be banned.
Also from the beginning of 2030, all products will be expected to fall into recyclability grades A, B or C, meaning that 70% or more of all packaging will be recyclable.
Between 2035 and 2038, the industry will be expected to move toward higher recycled content thresholds, with grade C banned by 2038.
The full phase-in is expected by 2040, with a 15% per-capita waste reduction target and climate-neutral trajectory.
Industry ‘headache’
While the supplements industry has welcomed the move towards a more circular economy, several have been involved in lobbying for more realistic implementation deadlines given the complexities involved in packaging ingredients which rely on packaging to protect the product from moisture, oxygen and light throughout its shelf life.
“Probiotics are the clearest case: living organisms that have to stay viable to the end of a 24 or 36 month shelf life, where inadequate moisture control can take a product below its specification within months,” said Vercammen, who also acts as chair of the European Federation of Associations of Health Product Manufacturers’ (EHPM) Task Force on PPWR. “If the barrier fails, the product no longer meets its label. The same applies to other types of food supplements.”
She said the supplements industry is in an ‘odd position’, as it uses the same high-barrier formats, stability methodology and specialized suppliers as the pharma industry but it has not been granted the same exemptions or extended timelines granted to pharma.
“The Regulation already classifies our packaging as contact-sensitive under Article 3(49),” she said. “The technical constraints are recognized; the flexibility is not.”
Martín Salcedo, regulatory consultant at LegaleGo Regulatory Affairs, told NutraIngredients the changes are a particular challenge for SMEs which don’t have the required resources or in-house regulatory expertise.
“The shift toward recyclable-by-design packaging is a real technical headache for this category, as supplement sachets and stick packs typically rely on multi-layer laminates, and those needs don’t line up easily with mono-material, easily-recyclable formats,” he explained.
“It’s the SME brands, which make up a large share of this industry, that are struggling with the fragmented, country-by-country compliance picture,” he added.
Lobbying for extension
Vercammen pointed out that with the design-for-recycling criteria not expected until 2028 and real-time stability studies typically taking 24 to 36 months, the deadline timelines simply do not align.
For this reason, EHPM’s PPWR task force prepared a position paper and submitted it to the EC ahead of the summer break with the objective to obtain an extension of the deadline for the food supplements sector in order to give companies sufficient time to test and validate alternative solutions. The association is currently awaiting the Commission’s feedback.
Vercammen said that member surveys by be-sup and EHPM in mid-2025 and May 2026 indicated a highly engaged sector actively working towards the new obligations, but structural challenges mean validation by 2030 is not a realistic deadline.
“Our reading of the evidence is that full compliance with design-for-recycling grades A, B or C by that date is not achievable for stability-critical formats within the current timeline and that this follows from the validation science rather than from any reluctance,” she said.
Luca Bucchini, managing director at Hylobates Consulting, warned the EC is likely to avoid extensions following the experience of the EU Deforestation Regulation, which has been repeatedly delayed following industry lobbying and has snowballed into broader political re-negotiations.
“Regarding deadlines, as far as I know, the European Commission has resisted pressure to grant extensions,” Bucchini said. “They likely want to avoid opening a Pandora’s box of delays, especially after the experience with the deforestation regulation.”
The EC was contact for comment, but a full response had been received at the time of publication.
