Recycled Content and PFAS Limits in Plastic Parts: A 2026 Compliance Guide

Key takeaways

• PPWR regulates packaging, not plastic parts. If your part is a product rather than packaging, Regulation (EU) 2025/40 does not apply to it. Read Section 1 before anything else.
• A part is in scope in one of three ways: it is packaging, it is a component of a packaging unit, or it is packaging presented as a product.
• Since 12 August 2026, three obligations apply: the PFAS restriction in food-contact packaging, a general recyclability requirement, and a Declaration of Conformity for every packaging item placed on the EU market.
• The PFAS limits are 25 ppb (individual PFAS), 250 ppb (sum), 50 ppm (total fluorine) — and there is no transitional period for stock already manufactured, and no exemption for recycled material.
• Recycled content targets and Design for Recycling criteria start on 1 January 2030, not in 2026. The 2026 deadline is a paperwork and chemistry deadline, not a redesign deadline.
• The American clock runs separately. Five US states already mandate post-consumer recycled content in plastic packaging, and seven have packaging EPR laws.
• Your customer's Declaration of Conformity depends on data you have to supply. That is now a purchasing criterion, whether or not a regulator ever asks.

1. Scope first: does PPWR apply to your part?

Most articles about PPWR and "plastic parts" skip this question. It is the only question that matters at the start.

PPWR — Regulation (EU) 2025/40 on packaging and packaging waste — applies to packaging placed on the EU market. It replaced the Packaging and Packaging Waste Directive 94/62/EC, which was repealed on 12 August 2026. It is a regulation, not a directive, so it applies directly in all Member States without national transposition.

A precision-molded housing for a router is a product. PPWR does not apply to it. A molded clamshell holding that router on a shelf is packaging. PPWR applies to it in full.

There are three routes into scope, and a molded part can take any of them:

Route 2 is the one that catches manufacturers off guard. A polypropylene closure is a small percentage of a bottle's weight, but if it is a different polymer from the body, it can pull the whole packaging unit's recyclability grade down when design-for-recycling grading begins in 2030.

Micro-enterprises are subject to lighter rules under the PPWR, so the obligations below do not scale identically for every supplier.

2. What changed on 12 August 2026

The regulation entered into force in February 2025 and applies on a phased basis. Three operational obligations began on 12 August 2026:

1. The PFAS restriction in food-contact packaging (Article 5(5))
2. A general recyclability requirement (Article 6(1)) — assessed against the existing standard EN 13430:2004, which is a softer test than the design-for-recycling criteria coming later
3. The EU Declaration of Conformity (Article 11) — documented evidence that each packaging item meets PPWR requirements, backed by a technical file

Also active from that date: identification of the manufacturer and, where applicable, the importer on the packaging (name, registered trade name or trademark, postal address); EPR registration in each Member State where packaging is first made available; and a functioning collection, reconditioning and redistribution system for reusable packaging.

What did not start on 12 August 2026. Recycled content targets, Design for Recycling criteria, single-use plastic format bans, reuse and refill targets, and packaging minimisation rules all begin on 1 January 2030. Harmonised labelling applies from 12 August 2028.

Treating August 2026 as the finish line misallocates the effort. The date that decides whether a packaging format stays on the EU market is 1 January 2030.

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