Key dates at a glance

1. 20 July 2026 — what does the EU BPA ban actually cover?

Under (EU) 2024/3190, the EU has set a default limit of detection of 1 µg/kg for BPA migration in food contact materials and repealed the previous specific migration limit (SML) of 0.05 mg/kg. The transitional rules were clarified by (EU) 2026/250, in application since 23 February 2026.

• Single-use FCM containing BPA may not be placed on the EU market for the first time as of 20 July 2026.
• Reusable articles benefit from a longer transition, ending either on 20 July 2027 or 20 January 2029 depending on the category.
• Certain specific packaging types may be placed on the market until 20 January 2028.

The compliance declaration may be drawn up either on the intermediate material or on the finished article, not both.

What exporters should do: replace any BPA-containing formulation, obtain a migration report at the default LoD of 1 µg/kg, and review production dates of in-transit and in-stock batches to determine whether the article is still covered by the transition rule.

2. 12 August 2026 — what does PPWR (EU) 2025/40 require for food-contact packaging?

PPWR applies from 12 August 2026. For food-contact packaging, the most concrete immediate obligation is the PFAS restriction:

• 25 ppb for any single PFAS (non-polymeric);
• 250 ppb for the sum of all PFAS.

This restriction applies to food-contact packaging only. Medical-device packaging is not within the mandatory scope. Member States have notified enforcement authorities under Article 40(3) — the Netherlands ILENT is one example.

The PPWR labelling implementing acts (Articles 12(6), 12(7) and 13(2)) were statutorily due by 12 August 2026; their publication is now overdue and the industry expects them in Q4 2026. When adopted, the labelling obligations apply on the later of (i) 12 August 2028 or (ii) 24 months after the implementing act enters into force.

The recycled-content methodology under PPWR Article 7(8) is due by 31 December 2026; the Commission has not yet started work on it publicly. Pallet wrap and strapping bands were exempted from the 100 % re-use requirement by (EU) 2026/429, in force since 26 May 2026.

3. 16 September 2026 — what does the (EU) 2025/351 deadline mean?

(EU) 2025/351 (in force since 16 March 2025; the so-called "Quality Amendment") simultaneously amends the Plastics Regulation, the Recycled Plastics Regulation and the GMP Regulation. It introduces new purity requirements for starting substances and for non-intentionally added substances (NIAS), and raises purity requirements for additives and polymer-production aids.

Plastic FCM produced before 16 March 2025 and compliant with the old rules may still be placed on the EU market until 16 September 2026; stocks may continue to be sold after that date until exhausted.

From 16 September 2026 onwards, all new shipments must be produced under the new rules and must be covered by an updated DoC. Exporters should verify production dates of in-transit and in-stock batches before issuing any new shipment.

4. PET bottle recycled content — which regulation applies?

The Commission adopted Implementing Decision C(2026) 4381 on 30 June 2026 (press release IP/26/1467), establishing the calculation, verification and reporting rules for recycled plastic content in single-use PET beverage bottles.

Its legal basis is the Single-Use Plastics Directive (SUPD), Regulation (EU) 2019/904, Article 7a — not PPWR. The substantive targets — at least 25 % recycled content in PET bottles from 2025 and at least 30 % in all single-use beverage bottles from 2030 — sit in SUPD.

Practical features of the new rules:

• Recycled-content calculation is performed on the total plastic weight of the bottle (including cap, lid, label and sleeve); only the plastic fraction counts.
• Outputs from chemical recycling may be attributed through mass-balance accounting; mechanical recycling follows a simpler self-declaration path.
• Plastic recycled outside the EU/EEA is treated on a three-tier system:
  • Tier 1: plastic recycled in the EU/EEA — counted unconditionally;
  • Tier 2: plastic recycled in OECD countries — counted from 21 November 2027, subject to a Commission equivalence assessment;
  • Tier 3: plastic recycled in non-OECD countries (including China) — counted only if a bilateral arrangement is in place that meets EU standards.

Verification: mechanical recycling relies on self-declaration; chemical recycling requires on-site third-party audits and annual re-verification.

These rules run in parallel with the PPWR recycled-content targets under Article 7(1). Exporters should maintain two parallel accounting ledgers so that compliance under either regime can be demonstrated on demand.

5. Two legislative tracks in flight for recycled plastics

The EU has two parallel regulatory tracks that touch the recycled-plastic supply chain. Both are worth tracking in the coming weeks.

5.1 Amendment to (EU) 2022/1616

Notified to the WTO on 15 April 2026 (G/SPS/N/EU/940); the comment period closed in mid-June 2026. Adoption is expected around 30 September 2026. The amendment introduces a new DoC requirement plus two new declaration categories, tightens document control, registration procedures and digital-platform management for recycled plastics (including imported recyclate), and rebuilds the EU registration system.

5.2 Draft end-of-waste criteria for plastic waste

Notified on 6 August 2026 (G/TBT/N/EU/1229) with a comment deadline of 20 September 2026. The draft establishes, under the framework of Directive 2008/98/EC, a Union-wide "end-of-waste" point for plastic waste, defining when a recycled thermoplastic polymer is no longer considered waste. The originally envisaged application date of 1 July 2026 has slipped. Once adopted, compliant recyclate will acquire "product" status, which feeds directly into the (EU) 2022/1616 supply chain.

6. What does RASFF say about the highest-risk items?

Between January and July 2026, the EU Rapid Alert System for Food and Feed (RASFF) recorded 78 FCM non-conformity notifications, of which 41 originated in China (including Hong Kong SAR, Macao SAR and Taiwan, China) — over 53 % of the total. China-origin notifications also accounted for 83.3 % of all border-rejection cases in the period.

The most frequently cited compliance failures (consistent with public monthly compilations) are:

• Bisphenol S (BPS) migration — recurrent in pizza boxes and similar paper/cardboard food-contact packaging notified by Germany and other Member States;
• Mineral oil (MOSH/MOAH) — contamination traced back to the packaging layer;
• Formaldehyde migration — typically from melamine articles used at elevated temperatures or under acidic conditions;
• Primary aromatic amines (PAAs) — released from polyamide moulded articles and certain adhesives.

These four are all interceptable by routine release testing. Exporters should incorporate them into factory release programmes and cross-check the test report against the supplier's own declaration.

7. Frequently asked questions

(1) Can BPA still be used in EU food-contact materials?

No. (EU) 2024/3190 sets a default limit of detection of 1 µg/kg for BPA migration; the previous 0.05 mg/kg SML is repealed. Single-use FCM containing BPA may not be placed on the EU market for the first time as of 20 July 2026.

(2) Does the PPWR PFAS restriction apply to all packaging?

No. It applies only to food-contact packaging, with limits of 25 ppb for any single (non-polymeric) PFAS and 250 ppb for the sum of PFAS. Medical-device packaging is outside the mandatory scope.

(3) Under PPWR or SUPD — which rules apply to PET recycled-content accounting today?

SUPD, Regulation (EU) 2019/904, Article 7a, as detailed in Implementing Decision C(2026) 4381. The PPWR methodology under Article 7(8) is still being developed and is statutorily due on 31 December 2026; the two systems run in parallel after 2030, and operators need separate accounts for each.

(4) What is the most common reason China-origin FCM shipments are notified on RASFF?

According to the January–July 2026 RASFF data, the most common reason is bisphenol S (BPS) migration, followed by mineral oil (MOSH/MOAH) contamination, formaldehyde migration and primary aromatic amine (PAA) release.

8. Why choose CIRS Testing for food-contact material testing

CIRS Testing is a third-party laboratory accredited by both the China Metrology Accreditation (CMA) and the China National Accreditation Service for Conformity Assessment (CNAS). Its laboratories exceed 10,000 m² and are equipped with LC-MS/MS, GC-MS and ICP instrumentation.

FCM testing covers Chinese GB 4806 series, EU (EU) 10/2011, German LFGB, U.S. FDA and Korean/Japanese standards. CIRS Testing routinely runs low-detection-limit projects — BPA at 1 µg/kg LoD, PFAS at the PPWR thresholds, mineral oil (MOSH/MOAH) and primary aromatic amines (PAAs).

Testing is paired with regulatory consulting support from the CIRS Group regulatory team. More than 30,000 enterprises have been served, including sellers on Amazon, TEMU and SHEIN.

About CIRS Testing

CIRS Testing, a wholly owned subsidiary of CIRS Group, is a regulatory service provider headquartered in Hangzhou, China. It helps manufacturers, brand owners and exporters bring chemistry-, consumer- and life-science-related products to global markets through accredited laboratory testing and regulatory consulting.

Note: This article is for informational purposes only and does not constitute legal advice. References to specific EU legal acts are provided for cross-checking only; readers should consult the Official Journal of the European Union and, where needed, qualified legal counsel before acting on any of the matters described.