PPWR checklist for food producers: check the suitability of your packaging

The PPWR checklist for food manufacturers should begin with a simple question: does the packaging still protect the food whilst meeting the new requirements regarding recyclability, substances of concern, recycled content, labelling and documentation? In the food industry, PPWR cannot be implemented simply by switching to a „more environmentally friendly” material. The packaging must continue to ensure product safety, shelf life, barrier properties and compliance with regulations on materials intended to come into contact with food.

The PPWR, or Regulation (EU) 2025/40, entered into force on 11 February 2025 and is, in principle, to apply from 12 August 2026. The European Commission states that it covers all packaging and packaging waste, regardless of material or origin, and sets out requirements for the production, composition, reuse and recovery of packaging.

For food manufacturers, this means one thing: barrier films, trays, MAP containers, lids, sachets, laminates, cartons, labels and transport packaging should be assessed not only for food safety, but also for recyclability and compliance with the PPWR.

PPWR in the food industry – why is this a more complex issue than in many other sectors?

The food industry is in a unique position. Packaging is not merely a marketing tool or a logistical safeguard. It often determines product safety, shelf life, and protection against oxygen, moisture, light, loss of flavour, substance migration, microbiological contamination and food waste.

Therefore, PPWR in the agri-food sector must be implemented with greater caution than in industries where the packaging does not come into direct contact with the sensitive product.

Materials intended to come into contact with food must also comply with EU requirements for food contact materials. The European Commission states that all food contact materials and articles must comply with Regulation (EC) No 1935/2004, and their constituents must not migrate into food in a way that endangers human health, alters the composition of the food, or impairs its taste or smell.

The most important rule for food producers: packaging that complies with the PPWR must also be safe for food. Recyclability cannot take precedence over product safety.

Which food packaging must be included in the PPWR checklist?

It is worth including all packaging used by the company in production, packaging, storage, transport and sales in the PPWR checklist. In the food industry, the following require particular attention:

– barrier films,
– vacuum-packing films,
– MAP films,
– PET, PP, PS, paper and multi-material trays,
– lids and sealing films,
– doypack bags and sachets,
– thermoformed packaging,
– containers for ready meals,
– mugs and buckets,
– bottles and caps,
– cardboard boxes with barrier layers,
– labels and sleeves,
– spacers, inserts and absorbers,
– bulk cartons,
– stretch film,
– transport and e-commerce packaging.

It is not enough to analyse the packaging visible to the consumer. PPWR also covers collective, transport and dispatch packaging, and EKOPRO points out that the analysis should cover not only unit packaging but also collective, transport and dispatch packaging.

Food contact compliance and PPWR compliance – two different assessments

Food manufacturers should distinguish between two types of compliance.

The first is compliance with regulations on materials intended to come into contact with food. This covers migration, chemical safety, odour, taste, composition, conditions of use, GMP and documentation from suppliers.

The second is compliance with the PPWR. This covers recyclability, design for recycling, substances of concern, recycled content, labelling, minimisation of packaging, technical documentation and any obligations regarding reuse.

These two areas can reinforce each other, but are sometimes at odds. For example, multi-layer barrier film protects food well and reduces food waste, but can be difficult to recycle. Conversely, a simpler single-material film may improve recyclability, but requires testing to ensure it still protects the product.

In the food industry, poor implementation of the PPWR can lead to increased food waste. Therefore, any change to packaging should be tested jointly by the quality, production, technology and compliance departments.

PPWR checklist for food producers

The list below can be used as a working tool for the quality, procurement, production, R&D and environmental protection departments.

1. Identification of the packaging

[ ] Does the packaging have a code, name and supplier assigned to it?
[ ] Is it known which product or group of products it applies to?
[ ] Is it known whether this is individual, bulk, transport or dispatch packaging?
[ ] Has it been specified whether the packaging comes into direct contact with food?
[ ] Have all the components been identified: tray, film, lid, label, adhesive, absorber, sleeve, print, coating?
[ ] Is it known which EU markets the product in this packaging is destined for?

2. Material and composition

[ ] Is the main material used for the packaging known?
[ ] Is the composition of each layer in the barrier film or laminate known?
[ ] Is it known whether the packaging is made of a single material or a combination of materials?
[ ] Is the mass of the entire packaging unit known?
[ ] Are the masses of the individual components known?
[ ] Has the supplier provided an up-to-date bill of materials?
[ ] Does the packaging contain coatings, varnishes, adhesives or additives that affect recycling?

If the packaging has multiple layers, coatings or components, it is worth carrying out a separate analysis multi-material packaging, as their recyclability depends not only on the predominant material, but also on the layers, laminates, adhesives, colourants and the feasibility of separating the different fractions.

3. Food safety

[ ] Does the packaging have a declaration of conformity for food contact?
[ ] Have the conditions of use been specified: temperature, contact time, type of food, freezing, pasteurisation, microwave treatment?
[ ] Are migration test results available, if required?
[ ] Does the change in material affect the taste, smell or appearance of the product?
[ ] Does the packaging compromise the microbiological safety of the product?
[ ] Does the packaging retain its barrier function throughout its shelf life?
[ ] Has R&D or Quality approved the packaging for this specific product?

This part of the checklist is critical. Food manufacturers should not replace barrier packaging with a simpler material without carrying out tests for stability, migration and safety.

4. Recyclability

[ ] Is the packaging designed with recycling in mind?
[ ] Does the predominant material have a viable sorting and recycling stream?
[ ] Do the label, adhesive, dye or sleeve interfere with the sorting process?
[ ] Can the tray, cling film and lid be disposed of in the correct waste stream?
[ ] Can the components be separated manually or using technical means?
[ ] Does the packaging contain any layers that prevent it from being recycled into a valuable secondary raw material?
[ ] Does the company have a recyclability assessment or a report from its supplier?

The European Commission states that the PPWR is intended to ensure that all packaging on the EU market is recyclable in an economically viable manner by 2030.

5. Barrier films

[ ] Is the film made of a single material or is it multi-layered?
[ ] Is the composition of each layer known?
[ ] Is the barrier necessary for the safety and durability of the product?
[ ] Is there an alternative that is more recyclable?
[ ] Won’t changing the film shorten the use-by date?
[ ] Is the film suitable for heat-sealing on the current production line?
[ ] Does the supplier have any information on the recyclability of the film?
[ ] Does the film contain any coatings, additives or adhesives that require further assessment?
[ ] Is the plastic-wrapped packaging correctly labelled for recycling?

Barrier films are one of the most challenging areas of PPWR in the food industry. They protect the product, but are often made of complex materials. Their assessment should take into account food technology, safety, recyclability and the operation of the packaging line.

6. Trays and containers

[ ] Is the tray made of PET, PP, PS, paper, pulp, aluminium or a composite material?
[ ] Does the tray have a barrier layer?
[ ] Is the tray black or dark in colour, which might make sorting more difficult?
[ ] Is the lid compatible with the material of the tray?
[ ] Does the absorber, pad or label contaminate the recycling stream?
[ ] Does the tray retain its rigidity and leak-tightness after the material has been changed?
[ ] Is the packaging suitable for MAP, freezing, reheating or pasteurisation, where applicable?
[ ] Is it possible to reduce the weight of the tray without increasing product wastage?

In the case of food trays, it is crucial to strike a balance between product protection and design for recycling. Switching too quickly to a „paper tray” may not solve the problem if the barrier or coating hinders recycling.

7. PFAS and substances of concern

[ ] Does the packaging come into contact with food?
[ ] Does the packaging contain grease-resistant, water-repellent or fluorinated coatings?
[ ] Has the supplier confirmed that PFAS levels do not exceed the PPWR limits?
[ ] Are there any test results or documents confirming compliance?
[ ] Does the documentation also cover adhesives, coatings, varnishes and barrier papers?
[ ] Does the packaging comply with the limits for heavy metals?
[ ] Does the company have a procedure for screening new suppliers for problematic substances?

The PPWR introduces restrictions on PFAS in food-contact packaging. In its implementing documents, the Commission has set the following thresholds: 25 ppb for any PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis, and 50 ppm for PFAS, including polymeric PFAS; the restriction applies from 12 August 2026.

This is particularly important for grease-resistant paper and trays, fast-food packaging, sachets, barrier coatings and materials that come into contact with moist or greasy food.

8. Recycled material in plastic packaging

[ ] Does the packaging contain plastic?
[ ] Does the plastic component account for a significant proportion of the packaging’s weight?
[ ] Is the packaging in direct contact with food?
[ ] Is it made of PET or another type of plastic?
[ ] Does the supplier declare the proportion of PCR, i.e. post-consumer recycled material?
[ ] Is the recycled material approved for use in contact with food?
[ ] Is the proportion of recycled material documented?
[ ] Does the use of recycled material affect the safety, smell, taste or shelf life of the product?

For plastic packaging, the PPWR sets out minimum recycled content levels from 2030. Industry sources describing Article 7 of the PPWR indicate, amongst other things: 30% for PET food-contact packaging, 10% for food-contact packaging made from plastics other than PET, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging.

In the food industry, however, recycled material must not be treated as a mere substitute for virgin raw material. Food-contact packaging must continue to meet food safety requirements.

9. Compostability and biodegradable packaging

[ ] Is the packaging labelled as organic, biodegradable or compostable?
[ ] Does the company hold a certificate or proof of compostability?
[ ] Is the packaging suitable for industrial or home composting?
[ ] Does the local waste collection scheme accept this type of material?
[ ] Does the messaging not suggest that the packaging can be discarded in the environment?
[ ] Does compostability interfere with the recycling of other waste streams?
[ ] Does the packaging fall within a category for which the PPWR sets out specific compostability requirements?

The PPWR provides for a limited scope of mandatory compostability for selected formats, such as permeable tea, coffee or other beverage bags, certain single-serve items and stickers on fruit and vegetables; industry studies also indicate the possibility of the Commission or Member States further extending these requirements under specific conditions.

„Bio” packaging is not automatically compliant with the PPWR. Its function, certification, end-of-life management and impact on recycling must be checked.

10. Markings and labels

[ ] Does the label contain correct information about the material?
[ ] Do the sorting instructions correspond to the actual contents of the packaging?
[ ] Isn’t the labelling on multi-material packaging a bit too general?
[ ] Do recycling symbols mislead consumers?
[ ] Does the label obscure the material in a way that makes sorting difficult?
[ ] Does the sleeve, print or dye make it difficult to identify the packaging at the sorting centre?
[ ] Is the company making space for future harmonised PPWR labelling?
[ ] Are the environmental claims supported by the documentation?

The European Commission points out that the new rules are intended to simplify the labelling and sorting of packaging, so that consumers know what the packaging is made of, where to dispose of it and how to return it for reuse.

11. Minimising packaging

[ ] Is the weight of the packaging justified on the grounds of product protection?
[ ] Isn’t the packaging too large for the portion size?
[ ] Is a barrier, spacer, absorber or insert technically necessary?
[ ] Is it possible to reduce the thickness of the film or the weight of the tray without increasing food wastage?
[ ] Does the outer packaging contain any excessive empty space?
[ ] Has the company compared the number of complaints and product losses with the weight of the packaging?
[ ] Are decisions regarding minimisation documented?

In the food industry, minimising packaging weight must not simply involve blindly reducing the size of the packaging. Packaging that is too flimsy can lead to increased damage, a shorter shelf life and greater food waste. Therefore, any reduction in weight should be tested in relation to both the product and its transport.

12. Documentation and data from suppliers

[ ] Does the company have an up-to-date safety data sheet for each package?
[ ] Has the supplier provided the bill of materials?
[ ] Are declarations of conformity for food contact available?
[ ] Is there any information available on the mass and composition of the components?
[ ] Is there any information available about recycled material?
[ ] Is there any data available on PFAS and substances of concern?
[ ] Is a recyclability assessment available?
[ ] Are the documents linked to a specific package number or SKU?
[ ] Does the company have a procedure for updating its documentation following a change to the material, supplier or label?

A lack of documentation can be just as dangerous as non-compliant packaging. A food manufacturer must be able to demonstrate why a particular type of packaging is safe, fit for purpose and compliant with the requirements of the PPWR.

Interactive PPWR checklist for a food business

The list below can be used as a simplified tool for an initial assessment. The more „no” answers there are, the greater the need for an audit.

Review question	Yes	Not	To be checked
Do we know the full list of materials used in the packaging?	[ ]	[ ]	[ ]
Does the packaging have a valid food contact declaration?	[ ]	[ ]	[ ]
Does the packaging meet the barrier requirements for the product?	[ ]	[ ]	[ ]
Has the packaging been assessed for recyclability?	[ ]	[ ]	[ ]
Has the supplier confirmed that PFAS levels do not exceed the limits?	[ ]	[ ]	[ ]
Do we know whether the packaging contains PCR recycled material?	[ ]	[ ]	[ ]
Does the packaging bear the correct waste sorting labels?	[ ]	[ ]	[ ]
Do labels, stickers or sleeves interfere with the sorting process?	[ ]	[ ]	[ ]
Is it possible to reduce the weight of the packaging without increasing food wastage?	[ ]	[ ]	[ ]
Is the information on the packaging consistent with the BDO and EPR?	[ ]	[ ]	[ ]
Has the export packaging been checked to ensure it complies with local EU requirements?	[ ]	[ ]	[ ]
Does every change to the packaging trigger the PPWR assessment procedure?	[ ]	[ ]	[ ]

How should the checklist results be interpreted?

If the majority of the answers are „yes”, the company is likely to have a solid foundation for the further implementation of PPWR. This does not mean automatic compliance, but it does show that the data and procedures are under control.

If „to be checked” is the most common response, the biggest problem is a lack of knowledge. This is a typical situation in companies that have a wide variety of packaging, multiple suppliers and data scattered across procurement, quality, production and compliance.

If there are many „no” answers, the company should treat packaging as a high-risk area. First, documentation should be gathered, and then an assessment of recyclability and safety should be carried out.

Typical risks in the food industry

The most common problems faced by food manufacturers are not a lack of willingness to implement the PPWR, but the conflict between product protection and recyclability.

Risk 1: The barrier film works, but is difficult to recycle

Many types of film used for meat, cheese, fish, ready meals, bread and frozen foods are based on multi-layer structures. They protect the product, but can be difficult to recycle.

Solution: check whether there is a single-material alternative with similar barrier properties and carry out product durability tests.

Risk 2: the tray looks eco-friendly, but has a difficult-to-remove coating

A paper or pulp tray may seem more environmentally friendly, but if it contains a hard-to-recycle coating, adhesive or barrier layer, recycling it can be problematic.

Solution: assess the entire unit, not just the outer material.

Risk 3: the packaging comes into contact with fat and may contain PFAS

Grease-resistant packaging, barrier papers, trays and coatings for finished products should be specifically tested for PFAS.

Solution: require suppliers to provide documentation and test results for contact packaging.

Risk 4: The recycled material is not authorised for contact with food

The requirements for recycled content in plastics do not mean that any PCR material can be used in food-contact packaging.

Solution: check not only the percentage of PCR, but also its source, authorisation and impact on food safety.

Risk 5: a change in packaging leads to more food waste

Reducing the weight or barrier properties too quickly may shorten the product’s shelf life and increase wastage.

Solution: Test every change on the actual product, under real-world storage and transport conditions.

How can a food business implement the PPWR checklist?

A checklist should be part of the process, not a one-off document. In practice, it is worth incorporating it into the packaging approval procedure.

1. Assign responsibility

The checklist should not be the sole responsibility of the environmental protection department. In the food industry, the quality, technology, R&D, procurement, production, marketing, warehousing and compliance departments must also be involved.

2. Start with high-risk packaging

First, check the barrier films, trays, laminates, coated packaging, grease-resistant packaging, plastic packaging and export products.

3. Collect documents from suppliers

The supplier should provide the specification, a food contact declaration, and details regarding mass, composition, recycled content, PFAS, substances of concern and recyclability.

4. Link the checklist to the PPWR audit

If a company has a large number of packages, a checklist alone is not enough. It is worth carrying out PPWR audit, which enables packaging to be assessed in terms of design, composition, recyclability, labelling and compliance with legal requirements. EKOPRO describes the PPWR audit as a comprehensive assessment of a company’s readiness for the new requirements.

5. Establish a procedure for making changes

Any change to the film, tray, adhesive, colouring agent, supplier, label or sales market should trigger a reassessment of the PPWR and food contact compliance.

6. Link the PPWR to the BDO and the EPR

Data on weight, materials and sales markets are required not only for PPWR, but also to meet packaging obligations in Poland and other EU countries. When selling abroad, it is worth combining the checklist with compliance with packaging obligations in EU markets, and for sales to Germany, also from LUCID audit.

When should a food manufacturer commission an audit?

It is particularly worth commissioning an audit if the company:

– uses barrier films or laminates,
– uses trays made of plastic, coated paper or composite materials,
– packages fatty, moist, frozen or MAP products,
– has a large number of SKUs and many packaging suppliers,
– exports products to the EU,
– there is no complete data on the weight of the packages,
– there is no documentation regarding PFAS, recycled content or recyclability,
– is planning a redesign of the packaging,
– promotes environmental messages on labels,
– has an out-of-order BDO or EPR.

In such cases environmental audit and a PPWR audit can minimise the risk of incorrect material changes, costly retrospective testing or problems with B2B customers.

The most common mistakes made by food manufacturers in relation to PPWR

The first mistake is to treat PPWR as merely a switch to more environmentally friendly packaging. When it comes to food, safety, shelf life and protective function must be maintained.

The second mistake is to assess only the tray or only the film. The packaging functions as a system: tray, film, lid, label, adhesive, absorber and print.

The third mistake is failing to take PFAS into account in paper, coatings and grease-resistant materials.

The fourth mistake is declaring a recycled material without checking whether it is suitable for contact with food.

The fifth mistake is changing the barrier properties without carrying out product durability tests.

The sixth mistake is a lack of data from suppliers. Without documentation, a company is unable to demonstrate compliance.

The seventh mistake is separating PPWR from BDO, EPR and exports. The same packaging affects several liability schemes.

FAQ - Frequently asked questions

Does the PPWR apply to food producers?

Yes. The PPWR covers all packaging and packaging waste, regardless of material or origin, so it also applies to food producers who use cling film, trays, containers, cartons, labels, bulk packaging and transport packaging.

Does food packaging have to be recyclable?

Yes, the PPWR stipulates that all packaging on the EU market must be recyclable in an economically viable manner by 2030. In the food industry, however, recyclability must be balanced against food safety and product shelf-life requirements.

Will barrier film be banned?

Not every barrier film will be banned. The problem may lie in its low recyclability, complex composition or lack of documentation. The company should check whether there is an alternative with better recyclability, but this must not compromise the safety and durability of the product.

Does the PPWR restrict PFAS in food packaging?

Yes. The PPWR introduces limits on PFAS in food contact packaging. The Commission specifies thresholds of 25 ppb, 250 ppb and 50 ppm, with the date of application being 12 August 2026.

Can recycled material be used in food packaging?

It is possible, but only if the material meets the requirements for food contact and is properly documented. The PPWR sets out minimum levels of recycled content for plastic packaging from 2030, but in the food industry, the safety of using PCR must also be verified.

How do you start implementing the PPWR checklist in a food business?

It is best to start with a list of food-contact packaging, barrier films, trays and multi-material packaging. Next, you need to gather data from suppliers and check for food contact suitability, PFAS, recyclability, recycled content, labelling and compliance with BDO and EPR.

Download the full compliance analysis for your packaging

The PPWR checklist for food manufacturers enables you to quickly identify which barrier films, trays, containers, labels and transport packaging require a more detailed assessment. However, it is not a substitute for a full audit, particularly where a company uses multi-material packaging, contact packaging or grease-resistant materials, or exports products to EU markets.

Download the full analysis of compliance in practice — order PPWR audit, check environmental audit or find out a professional range of services for businesses. You can also go to the tab Contact Eko-Pro and describe their films, trays, products and sales markets.