The new European Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) marks a significant change in the European regulatory framework and is expected to bring substantial changes to the way businesses design, place on the market, use and manage their packaging.
The new provisions cover a wide range of requirements and obligations, including recyclability, reusability, the reduction of unnecessary packaging, the use of recycled materials, labelling, extended producer responsibility and the submission of relevant data.
Given the scope and complexity of these changes, the transition to the new regulatory framework will take place gradually and will require businesses affected by the new requirements to be informed and prepared in a timely manner. In this context, Green Dot Cyprus will continue to support its members by providing ongoing information and guidance on the new requirements and the next steps for their implementation.
Below, in collaboration with Mr Charalambos Theopemptou and drawing on his specialised knowledge and expertise in environmental and regulatory matters, we present the four most important changes taking effect in 2026, as well as two additional changes expected to apply in 2027 and 2028.
What changes in 2026
1. Ban on PFAS in food-contact packaging
As of 12 August 2026, packaging that comes into contact with food may not be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) above the specified limits (Article 5(5) of the Regulation).
The three limits set by the Regulation are: 25 ppb for any individual PFAS, 250 ppb for the sum of PFAS, and 50 ppm for the total PFAS, including polymeric PFAS.
According to the European Commission’s guidance document (C(2026) 2151, 30.3.2026), there is no transitional period for the sell-through of existing stocks.
Anything placed on the market from 12 August 2026 onwards must comply with the Regulation. Packaging that was placed on the market before this date may remain on the market and be sold. However, anyone importing or filling packaging after 12 August may not rely on the fact that it was “old stock”.
2. All packaging must be recyclable
From the same date, the general requirement under Article 6(1) applies, stating that all packaging placed on the market must be recyclable.
Until the detailed delegated acts on design for recycling are adopted (expected by 1 January 2028), compliance will be assessed based on the essential requirements of the previous Directive and the relevant European standard.
Although the requirement applies from 2026, the stricter technical criteria and performance grades will be introduced gradually through to 2030.
3. Common European labelling
Mandatory labelling indicating the material composition of packaging is expected to apply from 12 August 2028, or 24 months after the European Commission adopts the implementing act establishing harmonised packaging and waste-bin labels (Article 12).
During 2026, we will see what the new labels will look like, which in the coming years will be harmonised across Europe.
Here you can find the steps for creating the new packaging label.
4. Deposit Return System
2026 is a critical year because the Regulation requires, from 1 January 2029, a separate collection rate of 90% for single-use plastic beverage bottles of up to 3 litres and metal beverage containers of up to 3 litres through an operational Deposit Return System (DRS), whereby consumers pay a small deposit and receive it back when they return the bottle or container (Article 50).
What changes in 2027–2028
From 12 February 2027, consumers will have the legal right to use their own reusable containers (e.g. reusable cups, thermos flasks or food containers) when purchasing food or beverages for takeaway. Food service businesses will be required to fill the customer’s personal reusable container without charging any additional fee.
From 12 February 2028, businesses selling beverages and ready-prepared food for immediate consumption (e.g. cafés, fast-food restaurants and restaurants) will be required to offer customers a reusable packaging alternative, such as a reusable cup or container.
What businesses need to do
Businesses, particularly those operating in the food and food-service sectors, should request written confirmation from their suppliers that food-contact packaging they receive after August 2026 complies with the PFAS limits, and should plan their stock levels accordingly.
Green Dot Cyprus will continue to closely monitor developments concerning the implementation of Regulation (EU) 2025/40 (PPWR) and will keep its members informed in a timely manner of any new requirements or changes that may affect their obligations.
A further update on the specific provisions of the Regulation and the next steps for its implementation will follow shortly.
Green Dot (Cyprus) Public Co Ltd
