EU PPWR FAQs Updated August 2026 - Flipbook - Page 19
3) How will the PPWR deal with the addition of substances of concern (SoC) and the use
of recyclates?
The objective of the Regulation is the minimisation of the presence of SoC in packaging. This will
be done via the identification of substances of concern, as a first step, and their limitation, if they
are relevant for recycling, via the DfR criteria, to be adopted under Article 6(4) PPWR, or via the
update of REACH restrictions for substances that affect human health or the environment. The
identification of the relevant substances is on-going via a study lead by the Commission and the
European Chemicals Agency (ECHA).
4) How many substances could fall under the definition of substances of concern (SoC)?
There is no definite number or list of substances of concern (SoC) in packaging. The study, which
the Commission and ECHA are undertaking to comply with its implementation obligation
established in Article 5(2), will look into this issue and will provide a list of SoC on the basis of
the information currently available about packaging manufacturing and waste treatment. There are
several sources of information that can be consulted for each criterion listed in Article 2(27) of
Regulation (EU) 2024/1781 (ESPR) to identify Substances of Concern (e.g. the 8Candidate list of
Substances of very high concern for Authorisation9 managed by ECHA7; Annex VI of Regulation
(EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures8 could
be also used as a source for identifying SoCs.
5) How is the supplier of packaging obligated to comply with the data requirements of
substances of concern (SoC)?
Obligations of packaging suppliers are detailed in Article 16 PPWR. Accordingly, suppliers must
provide the manufacturer with all the information and documentation necessary for the
manufacturer to demonstrate the conformity of packaging and the packaging materials with this
Regulation, either in paper or in electronic format. Manufacturers need this information from
suppliers of packaging materials or converters in order to identify PFAS or other SoC present in
packaging and draft the declaration of conformity demonstrating compliance with Article 5 PPWR.
6) At which value are the concentration limits for SoC set?
The Regulation includes an obligation to minimise the SoC content in material and emissions. The
main driving principle is that human health and environment are protected, i.e. unacceptable
adverse effects should be avoided. The Regulation does not set a general concentration limit for
SoC. Nevertheless, specific concentration limits are established for certain substances (e.g. PFAS
and certain heavy metals).
More information and knowledge on SoC are expected to come from the on-going Commission
and ECHA-led study. But substances meeting the substances of concern (SoC) criteria can already
be identified by the manufacturer based on the existing definition of SoC. The SoC criteria refer
7
https://echa.europa.eu/candidate-list-table.
8
Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on
classification, labelling and packaging of substances and mixtures, amending and repealing Directives
67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (OJ L 353, 31.12.2008, pp. 1–1355).
16
