PPWR: What Packaging Buyers Need to Know

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, has applied since 12 August 2026. It replaces Directive 94/62/EC, applies directly in every member state and covers all packaging regardless of material (Art. 2(1)). A tin is in scope exactly as a pouch is.

Who is the manufacturer? Almost certainly you

PPWR's "manufacturer" is not the factory. Art. 3(1)(13)(a): whoever has packaging designed or manufactured under its own name or trademark is the manufacturer. Commission guidance adds that there is only ever one per supply chain, normally the filler, often the brand owner. Unbranded packaging turns on who orders it and sets the design.

For a brand-printed tin, that is you. Masaş is the supplier (Art. 3(1)(16)), and our duty is Art. 16: give you what you need to demonstrate conformity, including what feeds the Annex VII technical file, in a language you understand. Art. 16(2) adds the food-contact documentation.

You wear a second hat. Buying from outside the EU makes you the importer. Art. 18(2): before the goods go on the market, check that the manufacturer did the Art. 38 conformity assessment, that the Annex VII file exists and that the documents travel with them. Art. 18(3) puts your name and address on the pack, and the August 2026 Commission FAQ extends this to unbranded imports.

The Article 21 trap

An importer or distributor that places packaging on the market under its own name or trademark, or modifies it, becomes the manufacturer (Art. 21). Put your logo on a generic tin and you take on the whole Art. 15 set.

Where it flips to us

Where we place plain, unprinted tins on the EU market under our own name, we are the manufacturer and carry Art. 15: the Art. 38 assessment (Annex VII, Module A), the technical file kept five years, the Art. 39 declaration of conformity, our address on the pack, documents to an authority within ten days. EPR stays with the EU-side operator; we cannot register it for you.

What applies right now

Heavy metals, Article 5(4)

The sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg, counting substances in packaging or packaging components: lids, gaskets, inks, lacquers, solder. There is no derogation for metal. Only glass (Decision 2001/171/EC) and plastic crates and pallets (Decision 2009/292/EC) survive, and Art. 5(8) lets the Commission amend only those two.

PFAS, Article 5(5)

Three limits for food-contact packaging: 25 ppb for a single PFAS and 250 ppb for the sum, both by targeted analysis (polymeric PFAS excluded, precursors degraded where applicable), and 50 ppm including polymeric PFAS. No transitional period and no stock-exhaustion window, though packaging already on the market may stay.

Guidance sets a screening sequence: measure total fluorine first, and below 50 mg/kg the sample can be considered compliant. Above it, the substance supplier must on request say whether that fluorine is PFAS or non-PFAS. In a tin it sits in the interior lacquer and exterior varnish, not the steel, which decides who you ask.

There is no harmonised EU test method for this yet: the UK Food and Drink Federation told its members exactly that in June 2026. And Art. 5(5) sets limits, not a ban, so "PFAS-free" is not a claim we make or one you should accept.

The timeline

• By 1 Jan 2028: the Commission must adopt the delegated act defining recyclability criteria and grades (Art. 6(4)).
• 12 Aug 2028, conditional: harmonised material and sorting labels (Art. 12(1)), or 24 months after the implementing acts enter into force, whichever is later. Those acts do not exist.
• 12 Aug 2028: Decision 97/129/EC repealed (Art. 70(2)); the old "FE 40" abbreviations may no longer be used.
• 1 Jan 2030: minimisation in full (Art. 10, Annex IV; see gift tins and PPWR minimisation); grades become a market-access condition, below C barred (Art. 6, Annex II); recycled content starts, plastic only (Art. 7). A "recycled at scale" condition follows in 2035, and the floor rises to grade B in 2038.

Packaging must already be recyclable in principle (Art. 6(1)). The grades are A at 95%, B at 80% and C at 70% or above, assessed per packaging unit across all components (Art. 6(9)); below C is not considered recyclable. Nobody can quote a grade before the 2028 delegated act: the criteria and the method do not exist yet. Anyone quoting one, us included, is guessing.

Recycled content: metal is out

Art. 7 is titled "Minimum recycled content in plastic packaging", and every operative paragraph is limited to any plastic part. No percentage applies to metal, steel, tinplate or aluminium anywhere in PPWR. The Commission's FAQ puts a metallic cap on a glass bottle "outside the scope of the recycled content requirements".

The catch: Art. 7 bites on any plastic part. A window, gasket, handle, shrink sleeve or moulded inner tray is in scope from 2030 unless it is under 5% of the unit's total weight (Art. 7(5)(b)). That is arithmetic on your bill of materials. They also count in the whole-unit recyclability grade: "the steel is recyclable" is not "this packaging is recyclable".

What to do next

Decide per pack who the manufacturer is and write it down. Open the Annex VII file now, not when an authority asks. Ask suppliers in writing for their Art. 16 information; for tins, ask about total fluorine on lacquer and varnish. Refuse "PFAS-free", "grade A" and "PPWR-certified": there is no CE marking (recital 109) and no certification scheme. And model EPR by weight: a 250 g tin pays far more per unit than a 12 g pouch, and eco-modulation will not close that gap. The counterweight is real but bounded: steel is a mono-material collected as its own stream, and 84% of steel packaging placed on the EU market was recycled in 2024 (Steel for Packaging Europe, EU harmonised method). That is a recycling rate, not a grade, and not a reason to expect PPWR to favour metal.

We hand over the supplier side: component information for your Annex VII file, the food-contact documentation under Art. 16(2), and straight answers about the lacquer. Not your conformity assessment, declaration of conformity, EPR registration or grade. That line is drawn in what your tin supplier can and cannot give you under PPWR, and the food-contact side in food-safe tin packaging. Tell us the markets and the product and we will say what documentation comes with it: request a quote.

Frequently asked questions

Who is the PPWR manufacturer of our tins?

For a brand-printed tin, you are. Art. 3(1)(13)(a) points at whoever has packaging made under its own name or trademark. Your tin maker is the supplier (Art. 16); you are also the importer (Art. 18).

Does PPWR require recycled content in metal packaging?

No. Art. 7 covers plastic parts only; no percentage applies to steel, tinplate or aluminium. Art. 7(15) requires a review of non-plastic materials by 12 February 2032: a review clause, not an obligation.

Can a supplier tell us our tin is grade A recyclable?

No, and neither can we. The criteria, the weighting and the method come from a delegated act due by 1 January 2028 (Art. 6(4)), so any grade quoted today is a guess.

Are tin lacquers PFAS-free?

Not a claim to make or accept. Art. 5(5) sets limits, not a ban: 25 ppb for a single PFAS, 250 ppb for the sum, 50 ppm including polymeric PFAS. Say a material complies, with test evidence.

What do we have to act on right now?

The heavy metals sum (Art. 5(4)), the PFAS limits (Art. 5(5)), the Art. 38 conformity assessment with its Annex VII file and Art. 39 declaration, and the claims rules (Arts. 12(8), 14).