EHPM fully supports the objectives of the PPWR and the European Union’s ambition to reduce packaging waste, increase circularity and accelerate the transition towards more sustainable packaging systems.
However, the new publication highlights the need for a science-based, proportionate and pragmatic implementation framework that takes account of the specific technical requirements of food supplement packaging.
“The food supplement sector fully supports the objectives of the PPWR and is committed to the transition towards more sustainable packaging, said Livia Menichetti, director general of EHPM. “What we need now is an implementation framework that recognizes the technical realities facing our sector. Sustainability and consumer protection must progress together, ensuring that companies have sufficient time to identify, test and validate alternative packaging solutions without compromising product quality or safety.”
Protecting product quality and consumer safety
Many food supplements are stability-critical products and require packaging that provides effective protection against factors such as moisture, oxygen and light. These barrier properties are essential to maintaining product quality, declared nutrient or ingredient content, safety and intended nutritional or physiological function throughout the product’s shelf life.
EHPM considers that this requires particular attention because medicinal products, medical devices and certain medical-nutrition categories benefit from specific regulatory flexibility, while food supplements with comparable stability and barrier requirements are not expressly covered.
The paper identifies two principal implementation challenges for the sector.
- The first concerns the PFAS restrictions and Declaration of Conformity obligations which became applicable from Aug. 12, 2026. While important guidance has been provided by the European Commission, practical uncertainties remain around areas including compliance verification, technical documentation, analytical methodologies and the treatment of existing packaging stocks.
- The second concerns the implementation timeline for the PPWR’s recyclability and recycled-content requirements. Design-for-Recycling criteria are expected by 2028, while real-time stability studies for food supplements typically require 24 to 36 months. Suitable food-contact recycled materials also remain unavailable or limited for several polymer streams used by the sector.
Industry evidence highlights practical challenges
EHPM’s position is supported by industry evidence gathered through surveys conducted by the Belgian federation for the supplement industry (be-sup) in Belgium in 2025 and EHPM across Europe in 2026.
The results demonstrate a high level of industry awareness and show that companies are actively investigating alternative and more sustainable packaging solutions. However, they also indicate that validation work remains ongoing, stability studies are largely incomplete and fully validated alternatives are not yet available for a number of packaging applications, particularly high-barrier formats such as blisters.
“The feedback from companies in Belgium shows that industry is taking the PPWR seriously and is already investing significant effort in understanding and preparing for the new requirements,” said Valerie Vercammen, managing director of be-sup. “The challenge is not a lack of willingness to change, but the practical availability of suitable alternatives and the time required to demonstrate that new packaging can adequately protect products throughout their shelf life. The regulatory timeline needs to reflect that reality.”
The Belgian findings, subsequently complemented by EHPM’s wider European survey, provide important practical evidence of the challenges companies face as they work to adapt their packaging portfolios to the new framework.
EHPM calls for proportionate implementation
To support a workable transition while maintaining the PPWR’s sustainability objectives, EHPM is calling on the European Commission to consider a number of measures, including:
- a temporary and time-limited derogation until 2035 for food supplements in relation to recyclability requirements where validated alternatives remain unavailable;
- a harmonized, proportionate and risk-based approach to demonstrating and enforcing compliance with the PFAS limits, supported by clear legal and technical guidance, agreed analytical protocols and consistent application across Member States;
- practical guidance ensuring that Declarations of Conformity can be substantiated consistently on the basis of available methodologies and reliable information throughout the packaging supply chain;
- an adapted approach to recycled-content requirements for contact-sensitive food supplement packagingwhere suitable authorized materials are unavailable;
- format-specific flexibility for packaging requiring essential barrier functions;
- additional legal and technical guidance on outstanding implementation questions;
- consistent application across Member States of the placing-on-the-market rules for existing packaging stocks, including clear treatment of empty packaging, filled products and the supporting evidence required from economic operators; and
- continued structured dialogue with industry stakeholders.
EHPM remains fully committed to supporting the transition towards more sustainable packaging solutions.
A realistic implementation framework that reflects scientific validation timelines, technological readiness and consumer protection requirements will be essential to ensuring that the PPWR’s objectives can be achieved without compromising the quality, safety, availability or innovation of food supplements.
Read the full EHPM position paper here: PPWR Position Paper 2026
