EU PPWR 2026: What Packaging Paper Buyers Must Verify Before Ordering

What the EU PPWR Actually Requires

The Packaging and Packaging Waste Regulation (PPWR) is the EU's successor to the older Packaging Directive (Directive 94/62/EC). It entered into force on 11 February 2025 and its core packaging obligations — substance restrictions, recyclability, and the EU Declaration of Conformity — have applied to all packaging placed on the EU market since 12 August 2026. Rather than setting one single rule, it layers several requirements onto packaging placed on the EU market, and it repealed the old directive directly in every member state.

The requirements that matter most for paper buyers are: (1) substance restrictions — heavy metals and PFAS limits (covered in the next section); (2) recyclability — packaging must be designed so it can be recycled in practice; (3) recycled content — certain plastic packaging must contain a minimum share of recycled material; (4) reduction of empty space and unnecessary packaging; and (5) clearer labeling, including material identification and waste-stream markings. A ban on some single-use plastic formats also applies, though it targets plastics rather than paper.

The headline for a paper mill is simple: PPWR rewards single-material, recyclable packaging and penalizes difficult-to-sort composites. That is good news for most paper substrates — and a reason to look carefully at any coating, lamination, or chemical treatment, especially on food-contact grades.

Substance Restrictions: Heavy Metals and PFAS

Two substance limits took effect for packaging on the EU market on 12 August 2026 under PPWR Article 5. The first is heavy metals: the combined concentration of lead, cadmium, mercury, and hexavalent chromium (Cr(VI)) in any packaging must not exceed 100 mg/kg. This is a hard total that applies to the packaging as a whole — including inks, coatings, and adhesives — not just the paper substrate.

The second is PFAS. From 12 August 2026, food-contact packaging must not be placed on the EU market if it contains PFAS at or above these thresholds: 25 ppb for any single PFAS (by targeted analysis, polymeric PFAS excluded), 250 ppb for the sum of PFAS, and 50 ppm for total PFAS including polymeric forms. If total fluorine exceeds 50 mg/kg, the supplier must be able to document how much of that fluorine comes from PFAS. Critically, the PPWR sets no stock-exhaustion period for PFAS — food-contact packaging placed on the market on or after 12 August 2026 must comply, with no grace period to run down old inventory.

For greaseproof and other food-contact papers, this is the single most consequential change. Plain, untreated greaseproof paper is inherently PFAS-free and therefore the safest starting point for EU food packaging. A silicone- or PE-coated sheet is not automatically non-compliant, but any intentionally added PFAS — once common in grease-resistant treatments — is now barred, so coated grades need a test report to prove they are clean.

• Ask for a PFAS test report (or a PFAS-free declaration) confirming the 25 ppb / 250 ppb / 50 ppm thresholds — these apply specifically to food-contact packaging.
• Ask for a heavy-metals (Pb / Cd / Hg / Cr(VI)) test report confirming the combined ≤100 mg/kg total.
• Confirm whether the grade is food-contact rated; if so, the PFAS limits are mandatory, and you should request the documentation rather than assume.

Which Paper Packaging Is Naturally PPWR-Aligned

Most of the paper grades used in retail and food packaging sit comfortably on the favorable side of PPWR. Uncoated kraft, tissue, and plain wrapping papers are single-material cellulose substrates already accepted in mainstream paper recycling streams. Brown kraft also supports recycled-content goals because it tolerates high post-consumer content.

Coated grades need a more specific conversation. Plain (uncoated) greaseproof paper is single-material and straightforward to recycle. Silicone-coated greaseproof is single-material paper with a thin release layer; acceptance in paper recycling depends on local facilities. PE-coated greaseproof adds a plastic barrier and behaves more like a paper-plastic composite at end of life. None of these is universally right or wrong - it depends on the destination market's recycling infrastructure and on whether a high moisture barrier is actually required.

The practical rule we give buyers: start from the plainest grade that meets the performance need. Move to a coating only when the application demands it, and request the material-composition report so the end-of-life path is documented rather than assumed.

• PFAS and heavy-metal test reports for food-contact grades — PPWR Article 5 sets binding limits (25 ppb / 250 ppb / 50 ppm for PFAS; ≤100 mg/kg for heavy metals) that took effect on 12 August 2026.

Documents to Request From Your Supplier

PPWR does not issue a single certificate you can wave at a customs officer. Compliance is demonstrated through a paper trail. Before ordering, ask your supplier for four things:

A newer differentiator is PFAS readiness. Since 12 August 2026, any supplier offering food-contact paper must be able to show a PFAS-free position — for plain grades that is straightforward, for coated grades it requires a test report. A supplier who cannot answer the PFAS question is not ready for the EU food-packaging market.

• FSC or PEFC chain-of-custody certification - proves the fiber comes from responsibly managed forests and supports recyclability and ESG claims.
• Material-composition report - lists every layer and coating so you can confirm the sheet is single-material or understand the composite.
• Recyclability statement - the supplier's position on how the product should be sorted, ideally referencing the relevant standard.
• Market-specific compliance documentation - test reports or declarations aligned to the destination (for example, food-contact or chemical-safety reports for the EU).
• We publish the certificates and test reports we hold on our certifications page and issue material-composition reports per order on request.

How Suppliers Differ Under PPWR

PPWR widens the gap between two kinds of supplier. The first is the single-material mill - kraft, tissue, plain paper - that was already PPWR-aligned before the regulation existed. The second is the composite or laminate producer whose multi-material packaging now faces pressure to change.

A capable supplier sits in between and is honest about it: offering both plain and coated grades, and backing each with documentation rather than marketing language. If a supplier cannot tell you what a coating is made of, that is the signal to keep looking. Buyers should weigh a supplier's transparency and document readiness as heavily as price.

• Can you provide PFAS and heavy-metal test reports for food-contact grades (PPWR Article 5 limits: 25 ppb / 250 ppb / 50 ppm PFAS; ≤100 mg/kg heavy metals)?

5 Questions to Ask Your Paper Supplier

Use these before you commit to a large order: For food-contact grades, add one more check to that paper trail: a PFAS-free position and a heavy-metals test report, both now mandatory under Article 5.

• Is this grade single-material, or does it contain a plastic or other coating? (Ask for the material-composition report.)
• Do you hold FSC or PEFC chain-of-custody certification, and can you share the license code?
• How should this product be sorted at end of life in my destination market?
• Can you provide food-contact and chemical-safety documentation if the paper touches food?
• What is your minimum order quantity, and do you supply pre-printed or custom-printed versions?

Conclusion: Verify, Don't Assume

PPWR is less a threat to paper packaging than a filter that favors the single-material, well-documented products many mills already make. For buyers, the work is straightforward: confirm the material, confirm the certification, and confirm the end-of-life path for your market. Suppliers who hand you that paper trail without hesitation are the ones worth specifying into your 2026 packaging program.

If you source kraft, tissue, or greaseproof paper and want to review documentation before ordering, our certifications page lists what we hold, and our product pages cover the plain and coated grades we manufacture.

Use our free EU PPWR Compliance Checklist for Paper Packaging Buyers to turn these questions into a supplier questionnaire you can send today — six questions, the documents to collect, and a fillable scoring grid.