Food supplement packaging: what the PPWR changes for your brand

Why the PPWR directly concerns your brand

Regulation (EU) 2025/40 on packaging and packaging waste gradually replaces the former directive. It has applied since 12 August 2026. Unlike a directive, it applies directly in every Member State. For food supplements, it covers every format: jars, bottles, pouches, sticks, blisters, cartons and shipping boxes.

The key point lies in the definition of manufacturer. The guidance published by the Commission on 10 June 2026 states that a person who has packaging or a packaged product designed or manufactured under its own name or trademark is the manufacturer. The reason given: that person has the decisive power over its suppliers and can therefore set the characteristics of the packaging. In private label, the brand therefore bears legal responsibility for compliance.

Obligation 1: PFAS limits

Since 12 August 2026, packaging intended to come into contact with food can no longer be placed on the market if it exceeds any of these thresholds:

• 25 ppb for any individual PFAS measured by targeted analysis (excluding polymers);
• 250 ppb for the sum of PFAS measured by targeted analysis;
• 50 ppm for total PFAS, including polymeric PFAS.

The Commission guidance recommends a stepwise approach: measure total fluorine first. Below 50 mg/kg, compliance is indicated. Above that, further analysis is needed. Inks, varnishes and adhesives on the packaging must also be taken into account.

Obligation 2: the EU declaration of conformity

Every packaging must be covered by an EU declaration of conformity, drawn up on the basis of technical documentation. The manufacturer within the meaning of the PPWR is solely responsible for it, even when a third party drafts it. Packaging and material suppliers must provide the information needed. Documentation must be kept for 5 years for single-use packaging and 10 years for reusable packaging.

What about packaging already in stock?

The Commission guidance is clear: food-contact packaging placed on the market before 12 August 2026 can remain on sale, with no withdrawal required. However, any packaging placed on the market after that date must meet the PFAS limits. For a finished product, the right reflex is to check packaging compliance for every new production run.

Timeline of the next steps

On 9 September 2026, the European federation EHPM called for a pragmatic implementation for food supplements. It points out that stability studies often take 24 to 36 months, which makes packaging changes slow to validate, and asks in particular for a temporary derogation until 2035 on recyclability where no validated alternative exists.

Our PPWR checklist for a food supplement brand

• list all your SKUs and every packaging component (jar, cap, seal, pouch, carton);
• ask each supplier for PFAS information and the data needed for the declaration of conformity;
• have an EU declaration of conformity drawn up and archived for each packaging;
• build recyclability and packaging volume into the specification of every new product;
• plan label redesigns for harmonised labelling;
• schedule stability testing before any change of material.