International Packaging GroupQuality and compliance

Quality is a document you can produce on request

For a food manufacturer, packaging quality is not measured in promises. It is measured by what can be put in front of an auditor, a customs officer and a buyer. This page sets out exactly which documents travel with a shipment, who holds which certificate, and how material performance is measured.

Food-contact safety

Every material intended for direct food contact is supplied with the manufacturer’s declaration of compliance. The declaration states which food types the material is suitable for, at what temperature and contact time it has been tested, and which migration testing has been carried out. The declaration is issued by the manufacturer; we pass it to the buyer with the shipment.

The regulatory framework

Regulation (EC) No 1935/2004: The general requirements for all materials and articles intended to come into contact with food.
Regulation (EU) No 10/2011: The specific requirements for plastic materials – the authorised-substances list and the migration limits.
Regulation (EC) No 2023/2006: Good manufacturing practice (GMP) for the production of food-contact materials.

These regulations apply to the material and to the manufacturer that makes it. The declarations of conformity are issued by the manufacturer, and we are responsible for every shipment travelling with a valid one.

ASTM D3985Oxygen transmission rate (OTR)

Regulation (EU) 2025/40

PPWR: dates, limits and duties

The Packaging and Packaging Waste Regulation starts to apply on 12 August 2026. It replaces the 1994 directive with a directly applicable regulation, so the requirements are identical in every member state and there is no national transposition to wait for. Below: the dates, the threshold values, and who carries which duty.

This page is general information, not legal advice. The dates and threshold values are given as they stand in the adopted text of Regulation (EU) 2025/40, published in the Official Journal of the European Union on 22 January 2025. Parts of how it applies depend on delegated and implementing acts that have not yet been adopted. For the compliance of a specific packaging item, consult your own lawyer or your national competent authority. Checked against the Official Journal text on 2026-07-29.

Instrument: (EU) 2025/40
Published: OJ L, 2025-01-22
Entered into force: 2025-02-11
Applies from: 2026-08-12

Full title: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC.

The calendar of obligations

Applies from
2026-08-12
- PFAS limits for food-contact packagingArt. 5(5)
- Lead, cadmium, mercury and hexavalent chromium, sum no higher than 100 mg/kgArt. 5
- Conformity assessment, technical documentation and EU declaration of conformityAnnexes VII, VIII
- Duties of manufacturers, importers and distributorsArt. 15, 18, 19
From
2028-08-12
- Harmonised material composition labelling on the packagingConditional date: 12 August 2028 or 24 months after the implementing acts under Article 12(6) or (7) enter into force, whichever is the later.Art. 12
- Labelling of packaging waste collection receptaclesA duty on Member States rather than on economic operators: Article 13(1) requires Member States to ensure the labels are affixed, by 12 August 2028 or 30 months after the Article 13(2) implementing acts, whichever is the later. It is listed because it changes what the collection bins look like, not because it puts a duty on a food producer.Art. 13
From
2030-01-01
- Recyclability: grade C at minimum; anything below it cannot be placed on the marketConditional date: 1 January 2030 or 24 months after the Article 6(4) delegated acts enter into force, whichever is the later. Those acts are due by 1 January 2028 and are not adopted yet, so this date can still move.Art. 6
- Minimum recycled content in plastic packagingConditional date: 1 January 2030 or three years after the Article 7(8) implementing act enters into force, whichever is the later. The 2040 figures carry no such condition.Art. 7
- Packaging weight and volume reduced to the minimum its function requiresArt. 10
- Empty space ratio in grouped, transport and e-commerce packaging no higher than 50 %Conditional date: 1 January 2030 or three years after the Article 24(2) implementing acts enter into force, whichever is the later.Art. 24
- Certain single-use plastic formats prohibitedArt. 25, Annex V
- At least 40 % of transport packaging used within a re-use systemBinding from 1 January 2030, with two exemptions that matter here: Article 29(4) takes flexible transport packaging in direct contact with food or feed, and cardboard boxes, outside the re-use targets altogether.Art. 29
From
2035-01-01
- Recyclability also assessed on actual recycling at scaleArt. 6
From
2038-01-01
- Recyclability: grade B at minimumArt. 6
From
2040-01-01
- Higher recycled content requirementsArt. 7
- Aim to use at least 70 % of transport packaging within a re-use systemArticle 29(1) says economic operators “shall endeavour to use” 70 %, where the 2030 row says “shall ensure”. It is a best-efforts target rather than an obligation, and the Commission reviews the 2040 targets by 1 January 2034 and may propose amending them.Art. 29

Three things a dated register cannot say in a date and a title, so they are said under the rows that need them: several of these dates are conditional and apply from the date shown or a fixed period after the relevant delegated or implementing act enters into force, whichever is the later; one 2040 target is an endeavour rather than an obligation; and one duty falls on Member States rather than on economic operators. A row with no qualifier under it is a flat obligation on a fixed date. This is not the full list: it is what matters to a food producer.

Threshold values

The numbers that decide the material

Three sets of requirements that change a specification directly: the recyclability grade, the recycled content, and the PFAS limits for food contact.

Recyclability performance grades

Packaging may be placed on the market only if its recyclability reaches grade C at minimum. That takes effect on 1 January 2030 or 24 months after the Article 6(4) delegated acts enter into force, whichever is the later, so the date itself is conditional: the criteria a grade is measured against do not exist yet. The grade follows from how the packaging unit is designed for recycling, which makes it a material decision to take now rather than in 2029. The grade B requirement from 1 January 2038 carries no such condition.

Recyclability performance grades under Annex II to Regulation (EU) 2025/40

Recyclability performance grades under Annex II to Regulation (EU) 2025/40
Grade	Recyclability%	From 2030-01-01 at the earliest	From 2038-01-01
A	≥ 95	Permitted	Permitted
B	≥ 80	Permitted	Permitted
C	≥ 70	Permitted	No longer sufficient
Below C	< 70	Cannot be placed on the market	Cannot be placed on the market

An “A to E” scale is sometimes quoted in the trade press; it does not exist in the Regulation, which defines grades A, B and C only and treats everything below C as technically non-recyclable. The detailed design-for-recycling criteria for each material are to be set by the Commission in delegated acts, and until those are published nobody can certify the grade of a specific structure. From 2035 the assessment adds actual recycling at scale to the design criteria. Article 6(11) puts some packaging outside these requirements entirely, including contact-sensitive packaging for infant formula, baby food and food for special medical purposes, and packaging used to transport dangerous goods.

Recycled content in plastic packaging

The requirement applies to any plastic part of packaging, not only to packaging that is wholly plastic, so a plastic component of a board pack counts; a part representing less than 5 % of the weight of the whole unit does not. It is calculated from post-consumer plastic waste, as an average per calendar year at each manufacturing plant. The 2030 column takes effect on 1 January 2030 or three years after the Article 7(8) implementing act enters into force, whichever is the later; the 2040 column is a fixed date.

Minimum recycled content under Article 7 of Regulation (EU) 2025/40

Minimum recycled content under Article 7 of Regulation (EU) 2025/40
Packaging category	From 2030-01-01 at the earliest%	From 2040-01-01%
Contact-sensitive plastic packaging with PET as the major component, except single-use plastic beverage bottles	30	50
Contact-sensitive plastic packaging made from plastics other than PET, except single-use plastic beverage bottles	10	25
Single-use plastic beverage bottles	30	65
Other plastic packaging	35	65

“Contact-sensitive packaging” covers food packaging, so for a food producer it is the first two rows that matter – with one exception that changes the number. Single-use plastic beverage bottles are carved out of both of those rows by Article 7(1)(a) and (b) and take the third row instead: 30 % in 2030 and 65 % in 2040, not 50 %. Further exemptions apply and the targets can be reviewed if food-grade recycled plastic proves scarce. Recycled plastic intended for food contact must in addition be produced under Regulation (EU) 2022/1616: a suitable recycling technology, with the process entered in the Union register.

PFAS in food-contact packaging

From 12 August 2026 food-contact packaging cannot be placed on the market where PFAS concentrations reach or exceed the values below, to the extent that placing it on the market is not already prohibited under another Union act. The limits are concentration limits: Article 5(5) sets no threshold for intentional addition and makes no exception for PFAS that arrive by another route, so on the face of the text contamination in raw materials, coatings and inks is in scope.

PFAS limits under Article 5(5) of Regulation (EU) 2025/40, applying from 2026-08-12

PFAS limits under Article 5(5) of Regulation (EU) 2025/40, applying from 2026-08-12
Measurement	Limit	Equivalent
Any individual PFAS (targeted analysis, polymeric PFAS excluded)	25 µg/kg	25 ppb
Sum of PFAS (targeted analysis, polymeric PFAS excluded)	250 µg/kg	250 ppb
PFAS total (polymeric PFAS included)	50 mg/kg	50 ppm

The practical consequence is blunt: fluorinated grease and moisture barriers on paper and board food service items are finished on the European market. When you ask for documentation, insist on being told which of the three values was tested, and by what method.

National rules ran ahead in places: Denmark banned PFAS in paper and board intended for food contact from 1 July 2020, and France left food packaging out of its 2025 PFAS law precisely because this Regulation now covers it. Separately from packaging law, ECHA is preparing a universal PFAS restriction under REACH: the RAC opinion was adopted on 3 March 2026, consultation on the draft SEAC opinion closed on 25 May 2026, and the scientific evaluation is intended to conclude by the end of 2026. No final decision exists yet, so for packaging it is Article 5(5) that governs today.

Roles and questions

Who is responsible, and what to ask

Below: how the Regulation allocates duties along the supply chain, and the questions worth putting to a supplier now.

Who carries which duty

The Regulation allocates duties by role in the supply chain, not by company size. Settle which role each party holds before the order: it decides who performs the conformity assessment and who signs the declaration. Note that the producer of the Article 44 register is not the manufacturer of Article 15: the register is about extended producer responsibility, and follows whoever puts the packaged goods on a national market.

Art. 15 – manufacturer: Carries out the conformity assessment, prepares the technical documentation, issues the EU declaration of conformity, ensures the labelling and states its own particulars.
Art. 16 – supplier: A supplier of packaging or packaging material must hand over all the information and documents the manufacturer needs to demonstrate conformity: material composition, recycled content, substances used and recyclability data.
Art. 17 – authorised representative: A manufacturer may appoint an authorised representative by written mandate to keep the EU declaration of conformity and the technical documentation at the authorities' disposal and to deal with them on non-compliance. Drawing up the technical documentation and the Article 15(1) obligations cannot be delegated to it. This is the article to ask about when the manufacturer sits outside the Union: it decides who can actually produce the file.
Art. 18 – importer: Verifies that the manufacturer completed the conformity assessment and prepared the declaration, states its name and address, keeps the declaration on file and produces documentation for the authorities.
Art. 19 – distributor: Before making packaging available, checks the labelling, the manufacturer and importer particulars and the entry in the producer register; does not make it available where there is reason to believe it does not conform; and keeps storage and transport conditions from prejudicing conformity.
Art. 21 – when the role changes: An importer or distributor that places packaging on the market under its own name or trademark, or modifies it in a way that can affect conformity, takes on the full obligations of a manufacturer.
Art. 44 – producer register: A different sense of the word producer: the party that first makes packaging or packaged goods available on a member state's market, which for packaged food is usually the food producer and not the packaging plant. Registration is per member state, and each state has 18 months from the entry into force of the Article 44(14) implementing act, due 12 February 2026, to establish its register – so the operative deadlines are national and mostly fall in 2027 rather than on 12 August 2026.

MB Packology Solutions works as a packaging supplier and distributor alongside leading European manufacturers: we check their documentation and pass it to you with the shipment. The conformity assessment and the EU declaration of conformity come from the manufacturer, and our part is that every shipment arrives with a valid document. If you place the packaging on the market under your own brand, Article 21 may put the manufacturer’s obligations on you, which is worth establishing before the first order.

What to ask your packaging supplier now

Seven questions a serious supplier should answer in writing in 2026. Some of them have no settled answer yet, and that too should be said plainly rather than talked around.

01 / 07
Which role does each party hold under the Regulation?
Who is the manufacturer for this specific item, who the importer, who the distributor. And separately: does printing your brand on it move the obligations to you under Article 21?
02 / 07
Can you supply the EU declaration of conformity and the technical documentation for this item?
The declaration and the technical file follow Annexes VIII and VII to the Regulation. Agree how many days it takes to produce them and who keeps them on file.
03 / 07
Has the food-contact packaging been tested against the three PFAS limits?
Ask which of the Article 5(5) values was tested, by what method, and when. A total fluorine screen is a reasonable first pass but it does not answer the question about individual substances.
04 / 07
What is the recyclability grade outlook for this structure?
From 2030 anything below grade C cannot be placed on the market. Until the Commission publishes the design-for-recycling criteria, the honest answer is a reasoned expectation with its reasoning attached, not a grade certificate: nobody issues one yet.
05 / 07
What is the recycled content today, and how will the 2030 requirement be met?
For food packaging it also matters whether the recycled plastic comes from a recycling process permitted under Regulation (EU) 2022/1616; if it does not, it is unsuitable for food contact whatever the percentage.
06 / 07
Does any part of my packaging fall under the format bans?
Annex V prohibits, among others, single-use plastic grouped packaging and single-use plastic packaging for fresh fruit and vegetables below 1.5 kg from 2030. The range is worth reviewing now.
07 / 07
Who reviews the specification when the outstanding acts are adopted, and by when?
Much of the detail only becomes concrete with the delegated and implementing acts. Agree who tracks their publication and how quickly your specification is reviewed once they land.

How material performance is measured

A figure on a technical datasheet only means something once you know the method behind it. Below are the standards against which the properties of the films we supply are measured. These are test-method standards, not company certifications: they define the measurement procedure, they do not confer a quality mark.

01 / 05
ISO 4593
Film thickness
Determination of thickness by mechanical scanning. Thickness consistency across the web governs forming stability and seal quality.
02 / 05
ISO 4592
Roll length and width
Determination of length and width. Accurate width is what allows the web to track correctly through the machine guides.
03 / 05
ISO 8295
Coefficient of friction
Determination of friction between film surfaces. Too much friction and the web drags; too little and the roll telescopes. It bears directly on line speed.
04 / 05
ASTM D3985
Oxygen transmission rate (OTR)
Oxygen transmission measured with a coulometric sensor. This is the primary figure behind any judgement about the shelf life a given barrier structure can actually deliver.
05 / 05
ASTM F1249
Water vapour transmission rate (WVTR)
Water vapour transmission measured with an infrared sensor. It determines whether the product dries out inside the pack, and whether the pack fogs from the inside.

The values themselves are given on the manufacturer’s technical datasheet for each individual structure. We supply the datasheet together with the quotation.

Standards and schemes

A certified manufacturer network

We select manufacturers that hold recognised certification, and we check that it is current. The certificates are held by the manufacturers, and that matters for your audit: the certificate number we provide always points to the plant where the material was made.

What our manufacturers work to

FSC
Forest Stewardship Council
Responsible forestry certification for paper and board fibre. Held by the corrugated manufacturer.
PEFC
Programme for the Endorsement of Forest Certification
The alternative forest-certification scheme, recognised by many European retail groups.
ISO 9001
Quality management systems
The quality management-system standard at the production sites. Specific certificate numbers and validity are provided on request.
EU 10/2011
Regulation (EU) No 10/2011
The specific requirements for plastic materials intended for food contact – the authorised-substances list and the migration limits.
BRCGS
Global Standard for Packaging Materials
A retail-recognised safety standard for packaging materials. Which manufacturers hold it is verified and stated on request.
HACCP
Hazard Analysis and Critical Control Points
The food-safety risk-management principle applied at the production sites. The scope applied at each plant is confirmed on request.

The certificates and schemes belong to the manufacturers. We verify that they are current and supply them with the shipment whenever your quality department or your audit requires them.

Traceability

Batch traceability

Every roll and every item carries the manufacturer’s lot number. If a problem appears in your production, that number leads back to a specific manufacturing batch, not to a shipment in general.

01 / 04
Lot number on every roll and packing unit
Every roll and every item carries the manufacturer’s lot number, applied at the plant.
02 / 04
The same numbers on the packing list, line by line
The same numbers are carried across to our packing list, so the shipping document matches what is physically on the roll.
03 / 04
Country of origin and manufacturer stated for each item
Country of origin and manufacturer are stated for each item individually, not for the consignment as a whole.
04 / 04
A route back to the manufacturer on a named batch
Where it is needed we go back to the manufacturer against a named production run, which produces an answer rather than a general explanation.

When a material fails on the line

Report the lot number and what happened: leaking seals, uneven forming, web breaks, adhesive failure. With the lot number we can isolate the remaining material from the same batch in your store and in ours, go back to the manufacturer against a named production run, and get an answer rather than a general explanation. A complaint without a lot number takes considerably longer, which is why roll labels are worth keeping until the product’s shelf life has expired.

Documentation

Documentation with every shipment

The standard document set that travels with every shipment. Additional documents are prepared where the buyer or customs requires them.

01 / 04
Packing list with lot detail
Every item, every roll, every lot number, the weight and the number of packing units. Not a summary line – the full detail, so it can be checked against the physical consignment.
02 / 04
Quality certificates
Manufacturer-issued quality or analysis certificates for each item supplied.
03 / 04
Declarations of compliance
Food-contact declarations of compliance for materials in direct contact with the product.
04 / 04
Export and customs documents
Invoice with correct HS codes, country of origin, manufacturer and export VAT treatment. Consignments outside the European Union are prepared so that customs can clear them without coming back with questions.

Need documentation for an audit?

Declarations of compliance, quality certificates, copies of manufacturer certification and technical datasheets are provided on request – including before a first order, if your quality department needs to assess the material in advance.

Documentation

Packing list with lot detail
Quality certificates
Declarations of compliance
Export and customs documents
Technical datasheets

Request documentation

Quality is a document you can produce on request

Food-contact safety

The regulatory framework

PPWR: dates, limits and duties

The calendar of obligations

The numbers that decide the material

Recyclability performance grades

Recycled content in plastic packaging

PFAS in food-contact packaging

Who is responsible, and what to ask

Who carries which duty

What to ask your packaging supplier now

Which role does each party hold under the Regulation?

Can you supply the EU declaration of conformity and the technical documentation for this item?

Has the food-contact packaging been tested against the three PFAS limits?

What is the recyclability grade outlook for this structure?

What is the recycled content today, and how will the 2030 requirement be met?

Does any part of my packaging fall under the format bans?

Who reviews the specification when the outstanding acts are adopted, and by when?

How material performance is measured

Film thickness

Roll length and width

Coefficient of friction

Oxygen transmission rate (OTR)

Water vapour transmission rate (WVTR)

A certified manufacturer network

What our manufacturers work to

FSC

PEFC

ISO 9001

EU 10/2011

BRCGS

HACCP

Batch traceability

Lot number on every roll and packing unit

The same numbers on the packing list, line by line

Country of origin and manufacturer stated for each item

A route back to the manufacturer on a named batch

When a material fails on the line

Documentation with every shipment

Packing list with lot detail

Quality certificates

Declarations of compliance

Export and customs documents

Need documentation for an audit?