EU rules on packaging and packaging waste from August 12

VASEP said the EU’s Packaging and Packaging Waste Regulation (PPWR - Regulation (EU) 2025/40) entered into legal force on February 11, 2025, and officially began to apply on August 12, 2026. The new regulation provides a common EU framework covering the entire life cycle of packaging, from design and material composition to resource use, collection, reuse and recycling of packaging waste.

The PPWR will be implemented in several phases. Therefore, the August 12, 2026 deadline does not mean that businesses must immediately replace all existing packaging with recyclable packaging or packaging containing recycled materials.

However, businesses should pay immediate attention to issues such as chemical restrictions, particularly per- and polyfluoroalkyl substances (PFAS), which are used for water-, oil- and moisture-resistance and to provide barrier properties in food-contact packaging. They should also assess the conformity and technical documentation of packaging. In some cases, businesses will also be subject to registration requirements and EPR.

Specifically, from August 12, 2026, food-contact packaging may not be placed on the EU market if PFAS levels meet or exceed the prescribed limits, including: 25 ppb for any individual PFAS identified through targeted analysis; 250 ppb for the total PFAS identified; and 50 ppm for total PFAS, including polymeric PFAS.

The European Commission said there is currently no fully harmonized method across the EU for testing PFAS in food packaging. In its June 2026 guidance, the EC sets out a step-by-step testing approach. Businesses may first test for total fluorine; if the level exceeds the threshold, further analysis will be required to identify PFAS.

Importantly, the PPWR does not provide for a general transition period to use up stocks of non-compliant PFAS-containing packaging. Food-contact packaging placed on the EU market after August 12, 2026 must comply with the PFAS limits, including packaging manufactured before that date. Packaging that was already placed on the EU market before August 12, 2026 may continue to circulate and does not have to be recalled.

VASEP recommends that, rather than replacing packaging across the board, Vietnamese seafood businesses should begin by compiling an inventory and developing a “packaging map” for all products exported to the EU.

For each stock-keeping unit (SKU), businesses should clearly identify the type of packaging, material composition, supplier, layers that come into direct contact with food, existing technical documentation and the packaging’s ability to meet PFAS requirements.

Businesses should work with packaging suppliers immediately to obtain evidence demonstrating compliance with chemical requirements applicable from August 12, 2026. At the same time, they should prioritize identifying multilayer packaging, packaging made from multiple materials, or packaging that is difficult to recycle, and develop transition plans ahead of the 2028–2030 deadlines.

When replacing packaging machinery, tray molds or entering into long-term packaging contracts from this point onward, businesses should also factor in PPWR requirements to avoid investing in solutions that meet current needs but have to be replaced again in a few years.

For Vietnamese seafood businesses, PPWR is not simply about “changing bags or trays.” It marks a shift from treating packaging as a material input to managing it as an integral part of compliance documentation and market-access capabilities in the EU.

“Businesses that prepare early will be better positioned to control transition costs and reduce risks as EU buyers raise their requirements in the coming years,” VASEP noted.