PPWR 2026: Takeaway Packaging and PFAS
PPWR applies from 12 August 2026. Three PFAS limits in food packaging, who is really responsible for them and what to demand from your supplier.
On 12 August 2026 the EU regulation on packaging, PPWR for short, began to apply. For a takeaway venue one provision matters most: packaging intended for contact with food can no longer be placed on the market if it contains PFAS above the stated limits. This concerns grease-resistant boxes, chip bags and coated papers, that is, the range you have in your storeroom.
This article explains what has really changed, who is responsible for it (because that is not obvious) and what to demand from a packaging supplier. At the end there is a ready-made enquiry template that you can send today.
The key points in brief
- PPWR is Regulation (EU) 2025/40 of 19 December 2024. It entered into force in February 2025, but it applies only from 12 August 2026 (Art. 71).
- The PFAS ban in packaging intended for contact with food applies from the same date and has three different limits, not one.
- The obligation does not rest directly on you. The provision speaks of placing on the market, and you buy packaging, you do not place it on the market. Your task is to choose a supplier who can carry it.
- PPWR, the SUP fee and the deposit return system are three separate obligations. They are easy to confuse, because all concern packaging.
What PPWR is and why it concerns your venue
The full name is Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste. It was published in the Official Journal of the EU on 22 January 2025. It repeals the old Directive 94/62/EC and amends two other acts: Regulation (EU) 2019/1020 on market surveillance and Directive (EU) 2019/904, that is, the single-use plastics directive.
The key difference from the previous state: this is a regulation, not a directive. A directive must be implemented by a Member State through its own act. A regulation applies directly, without the Polish legislator in between. You are therefore not waiting for a Polish act for the provision to start applying.
For foodservice, what matters is that takeaway packaging is packaging intended for contact with food. The whole range in which you hand out food falls within the scope of this regulation.
What exactly changed on 12 August 2026
Article 5, paragraph 5 of the regulation says directly: from 12 August 2026, packaging intended for contact with food is not placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) at a concentration equal to or higher than the stated limits.
There are three limits, and this is where most guides on the internet go wrong, giving only the first two:
| Limit | What it concerns |
|---|---|
| 25 ppb | for any PFAS measured by targeted PFAS analysis (polymeric PFAS excluded from quantification) |
| 250 ppb | for the sum of PFAS measured as the sum of targeted analysis, where relevant with prior degradation of precursors (polymeric PFAS excluded) |
| 50 ppm | for PFAS including polymeric ones, if the total fluorine content exceeds 50 mg/kg |
Exceeding any one of these thresholds is enough. This is not a list from which you pick one condition.
A reservation from the provision itself: the restriction applies where the given use of PFAS is not already prohibited under another Union legal act. The aim is to avoid overlap of rules, not to create a loophole.
Which packaging is really at risk
PFAS get into packaging not by accident, but on purpose. They provide the grease and water barrier, which is exactly what is expected of takeaway packaging. The risk is therefore concentrated where packaging comes into contact with fat:
- grease-resistant boxes for burgers, zapiekanki (Polish toasted baguettes) and ready meals
- chip bags and bags for fried snacks
- coated papers for wrapping sandwiches and kebabs
- paper tableware with a grease barrier
- liners and inserts for baskets
The paradox is that the packaging most at risk is that sold as an ecological alternative to plastic. Paper without a coating lets fat through, so manufacturers give it a barrier, and one of the cheaper methods was precisely fluorinated compounds.
Who is actually responsible: you or the supplier
This is the most important part of this article, and most materials on the Polish internet skip it.
The provision speaks of placing on the market. The one placing on the market is whoever first makes the packaging available on the EU market: the manufacturer, importer or distributor. A restaurant that buys boxes at a wholesaler and hands out food in them is not placing that packaging on the market. The obligation under Art. 5(5) therefore does not rest directly on you.
That does not mean the matter does not concern you. It only means that your role is different: you choose the supplier and gather proof that you chose knowingly. If you buy from someone who cannot confirm compliance, you risk two things: that the goods disappear from the market in the middle of the season, and that in an inspection you will have nothing with which to show due diligence.
Market surveillance is carried out under Regulation (EU) 2019/1020, which PPWR amends. Polish implementing provisions and sanctions are a separate issue, which it is worth checking in the current legal status before you build business decisions on it. This article does not settle them.
What to demand from a packaging supplier
One thing to do this week. Write to the supplier and ask for something concrete, not for an assurance. An assurance over the phone leaves no trace.
What to ask:
- whether the packaging complies with Art. 5(5) of Regulation (EU) 2025/40 as regards PFAS
- on what basis the supplier states this: a laboratory test, a manufacturer's declaration, material documentation
- which specific product code the answer concerns, because ranges are sometimes mixed
- from when a given batch applies and whether older stock differs in composition
- whether the supplier plans to withdraw any of the codes you use
A ready-made template to copy:
Hello,
in connection with the application from 12 August 2026 of Regulation (EU) 2025/40 (PPWR), I ask you to confirm whether the packaging intended for contact with food that we buy from your company meets the requirements of Art. 5(5) of that regulation as regards PFAS content.
Please state: 1) which product codes the confirmation concerns, 2) on what basis it was issued (a test, a manufacturer's declaration, material documentation), 3) whether you plan to withdraw or change the composition of any of these codes.
Please reply in writing or by email. The document will be added to our purchasing documentation.
Kind regards,
File the reply in your purchasing documentation and keep it together with the invoices for packaging. If the supplier replies evasively or not at all, that is in itself information about whom you are relying on.
PPWR, the SUP fee and the deposit are three different things
All three concern packaging, so it is easy to put them in one drawer. In practice they work completely differently.
| Obligation | What it concerns | What you do |
|---|---|---|
| PPWR (2025/40) | composition and properties of packaging | you choose a compliant range and collect confirmations from the supplier |
| SUP fee (single-use plastics fee) | single-use cups and containers containing plastic | you charge the fee to the customer, keep records and file a report |
| Deposit return system | selected beverage packaging | you handle the deposit in line with the role of your venue |
We described the other two separately: BDO obligations and waste reports in foodservice (BDO is Poland's waste database register) and the deposit return system in foodservice.
A 30-day plan for a takeaway venue
- Week 1. List the packaging range in which you hand out food. Mark separately everything that comes into contact with fat.
- Week 1. Send the enquiry to suppliers using the template above. To each one, not only the main one.
- Weeks 2-3. Collect the replies. Note also a lack of reply, with the date the enquiry was sent.
- Week 3. For codes without confirmation, look for an alternative before the stock runs out.
- Week 4. File the whole set in your purchasing documentation and set a reminder to review it in six months.
Frequently asked questions
Since when does PPWR apply?
Regulation (EU) 2025/40 applies from 12 August 2026. This follows directly from Art. 71. The regulation itself entered into force earlier, on the twentieth day after publication in the Official Journal of the EU of 22 January 2025, but the date of application is the one that matters in practice. One provision, Art. 67(5), applies only from 12 February 2029.
What are the PFAS limits in food packaging?
Three: 25 ppb for any PFAS measured by targeted analysis, 250 ppb for the sum of PFAS, and 50 ppm for PFAS including polymeric ones, if the total fluorine content exceeds 50 mg/kg. Exceeding any threshold means the packaging may not be placed on the market.
Is a restaurant responsible for non-compliant packaging?
The ban in Art. 5(5) concerns placing on the market, that is, the manufacturer, importer or distributor. A venue that buys packaging and hands out food in it is not the one placing it on the market. The practical role of the restaurateur is to choose the supplier and collect confirmations of compliance, so as not to be left with goods that cannot be used.
Is paper packaging automatically safe?
No. Paper without a coating lets fat through, so paper packaging for fatty dishes often has a barrier, and one of the ways to obtain it was fluorinated compounds. The packaging material does not decide compliance; the composition of the specific product code does.
Do I have to throw away stock bought before 12 August 2026?
The regulation prohibits placing on the market, not holding stock by the end user. Settle the question of old batches with the supplier and document it, because the supplier is responsible for what it placed on the market. If in doubt about a specific batch, consult before deciding to keep using it.
Legal status as of: 1 September 2026
Legal basis: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (Official Journal of the EU, L 2025/40 of 22.01.2025), in particular Art. 5(5) and Art. 71.
Last review: 1 September 2026
Are you on top of your waste and packaging obligations?
PPWR is one of several obligations that tie together around packaging: next to it are the BDO entry, records, reports and the SUP fee. GastroReady has a ready-made set of documents and registers (records) for this. The documents are sent by email after payment.