Regulatory & Policy August 12, 2026
Regulation (EU) 2025/40 applies from today in all 27 member states. It is a regulation, not a directive, so it binds directly with no national law needed first. Four things start now rather than later: the PFAS restriction on food-contact packaging, which sets three limits that all apply together, 25 ppb for any single PFAS and 250 ppb for the sum, both excluding polymeric PFAS, plus 50 ppm for total PFAS including polymeric; the Declaration of Conformity under Art. 39; the deadline for non-EU producers to appoint an authorized representative under Art. 45(3); and Germany's VerpackDG. Art. 67(5) is the one exception and waits until February 12, 2029.
What this means for you. The duty exists today, everywhere, whether or not the member state has named an enforcement authority. Thirteen still have not. What is NOT due today is most of the headline material: recyclability grades, recycled content minimums, the empty space cap and the reuse targets all sit at 2030 or later, and every one of those dates is a floor that moves later if the act it depends on is late. Nothing you print today needs a harmonized sorting label.
What to do. Confirm your Declaration of Conformity exists and is signed. If you are outside the EU, confirm your authorized representative is appointed in writing, per member state. If you use fluorinated food-contact materials, ask suppliers for total fluorine evidence now, because that duty is triggered on request above 50 mg/kg. Source: Regulation (EU) 2025/40, Art. 71, OJ L, 2025/40, 22.1.2025 [LOCKED].
This entry is part of the PPWR Atlas update log. The Atlas is re-checked against the Official Journal, Commission guidance, and each national PRO's published schedule, and everything that changes gets logged with its source. See the week of August 10, 2026 or the full update archive.