Packaging Regulation in the food sector: what applies
Food undertakings are subject to all the general requirements of Regulation (EU) 2025/40 and, in addition, to two rules that concern contact with food specifically: the three PFAS limits, applicable from 12 August 2026, and the format bans in Annex V, applicable from 1 January 2030.
- Legal reference
- Art. 5 · Annex V
- Last updated
- Official text
- Regulation (EU) 2025/40
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The requirements do not depend on the product but on the packaging: they apply to sales packaging, to grouped packaging and to transport packaging.
What applies from 12 August 2026
The three PFAS limits. Packaging intended for contact with food products is not placed on the market if it contains PFAS at a concentration equal to or above 25 ppb for targeted analysis, 250 ppb as the sum of targeted analysis, and 50 ppm for PFAS including polymeric PFAS (Art. 5(5)). If total fluorine exceeds 50 mg/kg, the supplier must provide, on request, evidence of the fluorine quantity measured.
The heavy metals limit. The sum of lead, cadmium, mercury and hexavalent chromium present in the packaging or in one of its components does not exceed 100 mg/kg (Art. 5(4)).
Technical documentation and the EU declaration of conformity. These are drawn up for each type of packaging, under Annexes VII and VIII, and the documentation demonstrates compliance with the two limits above (Art. 5(6)).
What arrives from 1 January 2030
Banned formats. Article 25 bans placing on the market packaging in the formats and for the uses listed in Annex V. Three entries closely concern the food supply chain:
| Format | Restriction |
|---|---|
| Single-use plastic grouped packaging | Stretch or shrink film used at the point of sale to group products sold in bottles, cans, tins, jars, tubs and trays. Packaging needed to facilitate handling is excluded |
| Single-use plastic for fresh fruit and vegetables | Banned for pre-packed fresh produce under 1.5 kg, subject to exemptions Member States may introduce for water or turgor loss, microbiological risks, impact damage, oxidation or separation from organic produce |
| Single-use plastic in hospitality, catering and food service | Banned for food and beverages filled and intended for consumption on the premises. Establishments without access to drinking water are exempted |
A fourth entry concerns individual portions of condiments, preserves, sauces, coffee creamer and sugar in the same sector, with two exceptions: packaging supplied together with ready-to-eat takeaway food, and packaging needed to ensure safety and hygiene in healthcare facilities.
Recycled content. From 1 January 2030, or three years after the entry into force of the relevant implementing act if later, the plastic parts of packaging must contain a minimum percentage of post-consumer recycled content: 30% for contact-sensitive PET packaging, 10% for contact-sensitive packaging in other plastics, 30% for single-use beverage bottles, 35% for other plastic packaging (Art. 7(1)). Food packaging falls within the notion of contact-sensitive packaging, which Article 3 defines by reference, among others, to Regulation (EC) No 1935/2004.
The order worth following
- Take stock of formats, distinguishing sales packaging, grouped packaging and transport packaging.
- Separate contact-sensitive packaging from the rest: the PFAS limits apply to it.
- Ask suppliers for the data, citing Article 16, which places the obligation to provide it on them.
- Draw up technical documentation and the declaration for each type of packaging.
- Check formats against Annex V, to know which ones will need replacing by 2030.
References
Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, in OJ L of 22 January 2025.
- Art. 3 · definition of contact-sensitive packaging
- Art. 5(4), (5) and (6) · heavy metals, PFAS, demonstration in the technical documentation
- Art. 7 · minimum recycled content in plastic packaging
- Art. 16 · information obligations of suppliers
- Art. 25 and Annex V · restrictions on the use of certain packaging formats
- Annexes VII and VIII · technical documentation and EU declaration of conformity
Official text: http://data.europa.eu/eli/reg/2025/40/oj