Which materials are banned under PPWR packaging rules?
Under the EU Packaging and Packaging Waste Regulation (PPWR), the materials and formats most directly targeted are single-use plastics used in specific packaging applications, along with substances such as PFAS and heavy metals that exceed defined concentration limits in food-contact packaging. The regulation does not ban entire material categories outright, but it sets format-specific prohibitions, chemical restrictions, and mandatory recyclability thresholds that together make certain packaging designs commercially unviable in the EU market. This article unpacks which specific formats are prohibited, which substances trigger restrictions, how recyclability is assessed, and whether fibre-based packaging enjoys any special status under the rules.
Which packaging formats does PPWR specifically prohibit?
The PPWR bans a defined list of single-use plastic packaging formats from 1 January 2030. These prohibited formats are set out in Article 25 and Annex V of the regulation and include: single-use plastic grouped packaging for cans, tins, pots, and tubs; single-use plastic packaging for pre-packed fresh fruit and vegetables weighing under 1.5 kg; single-use plastic packaging for individual portions of condiments, sauces, coffee creamer, sugar, and spices in the hospitality sector; single-use hotel miniature toiletries under 50 ml or 100 g; and very lightweight plastic carrier bags under 15 microns.
These prohibitions build on the earlier EU Single-Use Plastics Directive and extend its scope to packaging formats that were previously unregulated at EU level. Economic operators will not be permitted to place these formats on the EU market after the 2030 deadline. It is worth noting that the Annex V list can be updated through delegated acts as technical and scientific understanding develops, so the list of banned formats is not necessarily final.
One important scope rule applies to composite packaging, packaging made from a combination of materials including plastic. For the format bans covering fresh produce, condiment portions, and grouped packaging, composite packaging with a plastic content of 5% or less by total weight falls outside the Annex V bans. This threshold has significant practical implications for food manufacturers considering fibre-based alternatives that incorporate a thin plastic barrier layer.
From 12 August 2026, all packaging placed on the EU market must also be accompanied by a Declaration of Conformity, a new documentation requirement that did not exist under the previous Packaging and Packaging Waste Directive.
What materials trigger PPWR restrictions beyond outright bans?
Beyond the format-specific prohibitions, the PPWR restricts certain substances in food-contact packaging regardless of the packaging format. The two primary chemical restrictions in force from 12 August 2026 are PFAS concentration limits and heavy metal limits. PFAS, per- and polyfluoroalkyl substances, cannot exceed defined thresholds in food-contact packaging, and the combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg across all packaging types placed on the EU market.
PFAS restrictions in food-contact packaging
PFAS have historically been used as grease and water repellents in paper, board, and moulded fibre packaging, making food-service and food-retail packaging among the most exposed categories. From August 2026, food-contact packaging cannot exceed 25 ppb for any single PFAS compound, 250 ppb for the sum of PFAS, or 50 ppm for all PFAS including polymeric forms. The European Commission recommends a total fluorine screening approach: if total fluorine measures below 50 ppm, the packaging can generally be considered compliant without further targeted analysis.
Many fibre-based food packaging products that relied on PFAS-based barrier coatings will need to be reformulated using alternative technologies to meet the August 2026 deadline. PFAS-free barrier alternatives are now commercially available for many applications, but their performance must be validated under specific product and supply chain conditions before switching.
Heavy metals and BPA
The heavy metal restriction, covering lead, cadmium, mercury, and hexavalent chromium, carries over from the previous Packaging Directive and applies to all packaging, not just food-contact formats. Separately, Bisphenol A (BPA) is banned in food-contact packaging materials under a dedicated regulation that entered into force in January 2025, applying alongside the PPWR’s own chemical restrictions.
Looking ahead, the European Commission and the European Chemicals Agency (ECHA) are required to publish a report on substances of concern in packaging by the end of 2026. That report may identify further restricted substances beyond PFAS, so the chemical compliance landscape for packaging is likely to evolve beyond the current restrictions.
The PPWR also introduces mandatory recycled content targets for plastic packaging, phased in from 2030. For food-contact plastic packaging other than PET, the target starts at 10% post-consumer recycled content, rising over time. These targets do not apply where using recycled content would cause non-compliance with EU food contact safety rules, but that exemption requires format-specific technical evidence, not a general claim that packaging is food-contact.
How does PPWR define ‘recyclable’ and why does it affect material choices?
Under Article 6 of the PPWR, packaging is considered recyclable if it meets two conditions: it is designed for material recycling so that the resulting recycled material is of sufficient quality to replace virgin raw materials, and it can be separately collected, sorted, and recycled at scale without negatively affecting the recyclability of other waste streams. Recyclability is therefore a system-level question, not simply a question of what a material is made from.
The regulation establishes three recyclability performance grades assessed by weight of the packaging unit. Grade A covers packaging where at least 95% is recyclable; Grade B covers at least 80%; and Grade C covers at least 70%. Packaging that falls below the Grade C threshold is classified as non-recyclable. From 1 January 2030, only packaging achieving at minimum Grade C can be placed on the EU market. From 2038, only Grades A and B will be permitted, effectively phasing out Grade C packaging as well.
These grades matter for material choices because a packaging unit made from a widely recycled material can still receive a lower grade if its design features, barrier coatings, adhesives, multi-layer constructions, or plastic windows, interfere with sorting or recycling. The grade is calculated across the full packaging unit, not assessed material by material in isolation. This means that switching to a paper or board substrate does not automatically guarantee a high recyclability grade if the overall pack design is not optimised for the recycling system.
The detailed Design for Recycling criteria that will underpin formal grade assessments are to be set through delegated acts due by 1 January 2028. Until those acts are published, the industry reference methodology is RecyClass, but no operator can classify its portfolio with full legal certainty before the delegated acts are adopted. From 2035, a further “Recycled at Scale” criterion will apply, requiring packaging to be actually collected, sorted, and recycled in significant volumes across EU infrastructure, not merely theoretically recyclable.
Recyclability grades will also directly affect Extended Producer Responsibility (EPR) fees across EU member states, with higher grades receiving larger fee discounts. This creates a direct financial incentive for food manufacturers and packaging buyers to prioritise packaging designs that achieve Grade A or B, rather than treating Grade C as an acceptable minimum.
Are fibre-based and paper packaging materials exempt from PPWR bans?
Fibre-based and paper packaging are not exempt from PPWR requirements as a category. The regulation applies to all packaging regardless of material type. Paper and board packaging must comply with PFAS restrictions from August 2026, meet recyclability grade requirements from 2030, satisfy substance of concern rules, and be accompanied by a Declaration of Conformity. The fact that a packaging material is derived from wood fibre or recycled paper does not place it outside the regulation’s scope.
The most practically significant point for fibre-based food packaging is the PFAS restriction. Because PFAS have historically been the go-to solution for grease and moisture resistance in paper and board packaging, a wide range of products, from greaseproof papers to board-based food trays with barrier coatings, will need reformulation before the August 2026 deadline. The technical challenge is finding barrier alternatives that solve the PFAS problem without creating a new recyclability problem, since some alternative coatings, particularly wax-based ones, can complicate paper recycling.
The 5% plastic threshold in Annex V provides a meaningful, but carefully bounded, advantage for composite fibre-based packaging. For the specific format bans covering fresh produce packaging, condiment portions, and grouped packaging, a fibre-based tray or carton with a plastic content at or below 5% of total weight by design falls outside those particular bans. This is a scope rule, not a universal safe harbour: PFAS limits, recyclability requirements, minimisation obligations, and other PPWR duties still apply in full.
For food manufacturers considering the transition away from conventional plastic trays, fibre-based tray solutions that incorporate a thin inner barrier film rather than a PFAS coating represent a practical route to navigating both the format bans and the chemical restrictions simultaneously. At Jospak, our cardboard tray uses at least 85% recycled fibre content and is designed so that the cardboard shell and the thin inner film can be separated, allowing the fibre component to re-enter existing cardboard recycling streams. The tray’s plastic fraction is kept well below the 5% Annex V threshold, placing it outside the scope of the format bans that will apply from 2030.
It is also worth noting that recycled content targets for plastic packaging do not apply to paper and cardboard packaging in the same way they apply to plastic packs. A fibre-based pack with a plastic fraction at or below 5% by weight does not carry the same recycled plastic content obligations as a fully plastic tray. However, this distinction does not remove all compliance obligations, recyclability grading, PFAS compliance, and minimisation requirements apply regardless of whether the primary material is plastic or fibre.
The broader picture is that PPWR packaging requirements are material-neutral by design: the regulation rewards packaging that performs well across recyclability, chemical safety, and minimisation criteria, regardless of what it is made from. Fibre-based packaging has structural advantages in several of those areas, but those advantages only translate into compliance certainty when the full pack design, including any barrier layers, coatings, or sealing films, is assessed against the complete set of PPWR obligations.
