EU PPWR FAQs Updated August 2026 - Flipbook - Page 20
mainly to hazardous properties but also include, on a case-by-case basis, considerations related to
recycling and re-use.
The possibility to establish new concentration limits for SoC in packaging may result from the
evaluation to be carried out by the Commission by 2033, which will consider if the Regulation has
sufficiently contributed to minimising the presence and concentration of SoC in packaging.
Moreover, the Commission may adopt delegated acts in accordance with Article 6(4) to limit the
presence of SoC that negatively affect recycling.
7) What is the implementation date for Article 5(1) PPWR?
The Regulation and therefore the obligation to minimise substances of concern content will apply
from 12 August 2026. Already PPWD contained the obligation to minimise substances of concern
with regards to their presence in emissions, ash or leachate when packaging or its packaging waste
residues are incinerated or landfilled and has set specific concentration limits for four heavy metals
(lead, cadmium, mercury and hexavalent chromium).
8) How can manufacturers prove compliance with Article 5(1) regarding the obligation
to minimise SoC in packaging? NEW!
The general principle set out in Article 5(1) should be assessed in line with Annex C
(Minimisation of Dangerous Substances or Preparations and Demonstration of Conformity) of the
existing harmonised standard EN 13428_2004 Packaging - Requirements specific to manufacturing
and composition - Prevention by source reduction. This Annex describes the steps that have
to be taken by the economic operator responsible for placing a specific packaging on the market in
order to determine and demonstrate minimisation.
9) Is the harmonised standard EN 13428:2004 still applicable to ensure conformity with
the requirements as regards SoC? UPDATED!
The requirements concerning SoCs have been strengthened in the PPWR. Under the PPWR,
packaging must be manufactured so that the 8presence and concentration of substances of concern9,
both in the material itself and in emissions or waste outcomes, is minimised. It also explicitly ties
these requirements to effects on reuse, recycling and chemical safety, rather than merely end-oflife disposal. EN 13428:2004 focuses primarily on minimising dangerous substances in emissions
and disposal, not on the holistic lifecycle impacts, as required by Article 5 of the PPWR.
Furthermore, the standard does not reflect the expanded hazard scope of the PPWR, covering
SVHCs under REACH, CLP hazard classes and recyclability impacts.
Therefore, Annex C of the existing harmonised standard EN 13428:2004 9 related to the
9minimisation of dangerous substances or preparations and demonstration of conformity9 can no
longer create a presumption of conformity with the new rules concerning SoCs. However, until the
updated harmonised standard becomes available, the existing standard EN 13428:2004 can be used.
9
Harmonised standards published in Commission communication in the framework of the implementation of the
European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste
(OJ C 44 of 19 February 2005), EN 13428:2004 8Packaging 3 Requirements specific to manufacturing and
composition 3 Prevention by source reduction9.
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