PPWR August 2026: Substance Requirements and What Has Changed in CDX

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation EU 2025/40) entered into force on 11 February 2025 and applies in all EU Member States from 12 August 2026. It replaces the previous Packaging and Packaging Waste Directive and introduces a more comprehensive and directly applicable set of requirements for packaging placed on the EU market. Unlike a directive, PPWR does not need to be transposed into national law. 

What has changed in CDX
The substance list for the PPWR is now available in CDX under the name "Packaging and Packaging Waste Regulation". The previous Directive remains available under the name "Packaging" until 12 August 2026, after which it will be deactivated.

Substances covered in the current CDX list
PPWR maintains the restriction on heavy metals that was already in place under the previous Directive. The following substances are included in the CDX substance list, with a combined concentration limit of 100 mg/kg for all four substances together:

• Lead compounds
• Chromium (VI) compounds
• Mercury compounds
• Cadmium compounds

For most companies, this requirement is not new. The same four heavy metals were restricted under the previous Directive at the same combined threshold. The transition to the new regulatory list in CDX reflects the change in the legal instrument, not a change in the substance limits themselves.

Substances not included: PFAS and BPA
PPWR introduces a restriction on PFAS (per- and polyfluoroalkyl substances) in food contact packaging under Article 5(5). In addition, a ban on BPA (Bisphenol A) in food contact packaging materials applies under a separate regulation, Regulation (EU) 2024/3190, which has been in force since 20 January 2025.
Both restrictions apply exclusively to packaging that comes into direct contact with food. They have not been included in the current CDX substance list. If your products include food contact packaging and you need these substances added to your compliance scope, please contact us and we will extend the substance list accordingly.

Declaration of Conformity
PPWR introduces a new obligation that was not part of the previous Directive: from 12 August 2026, packaging placed on the EU market must be accompanied by a Declaration of Conformity (DoC). This document must confirm that the packaging meets the applicable PPWR requirements, including the substance restrictions listed above. The DoC must be kept available for market surveillance authorities and updated whenever the packaging design or composition changes. Compliance data managed in CDX can support the preparation of this declaration by providing the substance concentration data needed to confirm compliance with the heavy metal limits.

Substances of concern: what to expect next
PPWR introduces a broader requirement under Article 5 to minimise the presence of substances of concern in packaging. At this stage, no specific numerical thresholds have been defined beyond the four heavy metals listed above. By 31 December 2026, the European Commission is required to publish a report that may identify additional substances and could lead to new substance limits. We will update the CDX substance list if new requirements are introduced.

What you should do now

• If you currently use the "Packaging" list in CDX, transition to the "Packaging and Packaging Waste Regulation" list before 12 August 2026
• If your products include food contact packaging, contact us to discuss whether PFAS and BPA restrictions need to be added to your compliance scope
• Monitor updates to the CDX regulatory list in the second half of 2026 following the expected Commission report on substances of concern

Source: Regulation (EU) 2025/40; Regulation (EU) 2024/3190; ECHA