PPWR Compliance Starts with Your Packaging

The EU Packaging and Packaging Waste Regulation has applied since 12 August 2026. We help coffee brands get the documents, the labelling and the material decisions right — and reserve the 2028 label in the same artwork revision, so you print once instead of twice.

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Obligations live since 12 Aug 2026

Pouches · Cartons · Drip bags · Capsules · Cups

BRCGS + ISO 22000:2018 certified plant

Four dates that decide your packaging timeline

20 July 2026

BPA transition ends
Single-use final food-contact articles containing BPA could be placed on the market until this date; specific categories until 20 Jan 2028 (Reg. (EU) 2024/3190, Art. 11).

12 August 2026

PPWR applies
Declaration of conformity, technical documentation, PFAS limits, heavy-metal limits and identification labelling (Reg. (EU) 2025/40, Art. 80).

12 February 2028

Compostable brew-in units
Permeable tea and coffee bags — drip bags and similar soft single-serve units — must be compatible with industrial composting (Art. 9(1) with Art. 3(1)(1)(f)).

2030 → 2038

Recyclability grades
From 1 Jan 2030 or 24 months after the delegated acts, whichever is later, packaging must reach grade A, B or C. From 2038, only A or B may be placed on the market (Art. 6(3)).

What the PPWR Changes

The PPWR — Regulation (EU) 2025/40 — replaced the 1994 Packaging and Packaging Waste Directive. Because it is a regulation rather than a directive, it applies directly and uniformly in every Member State: there is no national transposition to wait for, and no country-by-country variation to design around.
01 — It applies to your packaging, wherever it is made: packaging placed on the EU market falls within scope regardless of where it was produced. A coffee pouch printed in Asia and sold in Germany is in scope.
02 — Identity, documentation, materials: three layers move at once — who is responsible and how the pack identifies itself, what the technical file proves, and what the packaging is made of.
03 — Harmonised, not national: labelling under Article 12 is exhaustive and fully harmonised, so Member States may not impose additional national mandatory packaging labelling requirements.

Obligations Since 12 August 2026

Six items, all verifiable against the official text. Where a technical detail is still to be set by an implementing act, we say so rather than filling the gap with a guess.

Obligation	What it requires	Legal basis
Declaration of conformity	A written declaration per packaging type, kept with the technical documentation: 5 years for single-use packaging, 10 years for reusable packaging from the date it was placed on the market.	Annex VII, point 4
Identification and operator details	Type, batch or serial number or another identifying element; name or registered trade mark, postal address and electronic contact (may be provided via QR code or another data carrier). Information must be clear, understandable and legible.	Art. 15(5), (6), (7)
PFAS limits	Food-contact packaging must not contain PFAS at or above: 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, 50 ppm for PFAS including polymeric PFAS. If total fluorine exceeds 50 mg/kg, proof of the fluorine source must be provided on request.	Art. 5(5)
Heavy-metal limits	The sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg, demonstrated in the technical documentation.	Art. 5(4), 5(6)
Packaging minimisation	Packaging must be designed to minimise volume and weight while performing its function. For sales packaging, empty space must be reduced to the minimum necessary from 12 February 2028.	Art. 10(4)
EPR registration	Producers must register in the national register of producers; distributors must verify that registration before making packaging available.	Art. 44; Art. 20(2)(a)

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The Deadlines After 2026

The second wave is already scheduled. Two of these dates directly affect coffee packaging formats, not just the carton around them.

Date	Requirement	Why it matters for coffee
12 Feb 2028	Permeable tea, coffee and other beverage bags, and soft single-serve units, must be compatible with industrial composting; fruit and vegetable stickers too.	Drip bags and hanging-ear bags fall in this category. Non-permeable machine units (for example rigid capsules) are a separate category and are only required to be compostable where a Member State opts to require it.
12 Aug 2028	Harmonised label: material-composition pictograms, compostability information where relevant, and a digital identifier. Applies from 12 Aug 2028 or 24 months after the implementing acts, whichever is later.	Back-panel space on a pouch is finite. Reserving the label area during your next artwork revision avoids a second print change.
1 Jan 2030	Recyclability performance grades A (≥95%), B (≥80%) or C (≥70%) required to place packaging on the market, unless the delegated acts shift the date later. Plastic parts must meet minimum recycled content: 10% for non-PET contact-sensitive packaging, 30% PET contact-sensitive, 35% other plastic.	Multi-material laminated pouches are the structures under most pressure — the grade is assessed per packaging unit by predominant material.
1 Jan 2038	Only packaging in grades A or B may be placed on the market.	A structure that only reaches grade C has a defined end date. Material roadmaps should be built backwards from 2038.

Download your PPWR Data Pack

Select your packaging format and structure, and we generate the input data you need for your declaration of conformity — with the test evidence behind it. Four selections, one downloadable pack.
1 · Format — Pouch, carton, drip bag, capsule box, cup
2 · Structure — Mono-PE + AlOx, mono-PE + PCR, paper + water-based coating, PLA
3 · Specification — Size, layer build, valve, zipper, window
4 · Pack — Structure declaration, layer weights, material code, test references, batch rule

Generate my Data Pack

Labelling and Artwork Readiness

This is where compliance meets print. The information must fit the format, survive filling, and stay scannable — and the 2028 label space should be reserved in the same revision.

Printable area differs by format

Flat bottom pouches provide the largest clean back panel, making them suitable for a consolidated information block. This area can be used for product details, preparation instructions, compliance information, and branding elements.

To maintain a clean appearance, avoid placing important information on the base fold or bottom gusset, as these areas may not remain visible after filling.

Side gusset pouches offer flat front and back panels for primary branding and product communication. The gusset area can be used for supporting information, such as secondary details or additional instructions.

Important graphics or key information should not be placed across the gusset, as the panel shape changes after filling and may affect readability.

Folding cartons provide multiple printable panels, allowing information to be separated according to function. Different sides can be used for branding, product descriptions, ingredients, certifications, and usage instructions.

Avoid placing critical information across seams or score lines, as folding may affect the visual consistency and readability.

For drip bag packaging, the outer carton usually carries the required product information, while individual sachets focus on essential identification and presentation.

Because single sachets have limited printable space, avoid placing too much information directly on each unit. A clear hierarchy between the outer carton and inner sachets helps maintain an organized package design.

Capsule cartons provide dedicated space for product identification and compatibility information. The available panels allow brands to communicate capsule type, usage details, and product specifications clearly.

Avoid compressing too much information into one panel by reducing font size, as this can affect readability and the overall packaging experience.

Material identification code

Choose the code from the structure specification, never from the surface appearance. A pouch that looks like paper but contains a plastic or aluminium barrier is composite packaging and must be marked accordingly.

Reserve for 2028 in this revision

Three reservations cost almost nothing now and a full redesign later:

A defined block for the material-composition pictogram
A QR area on a flat, non-flexing part of the pack
A marking area for reusable packaging where relevant to your range.

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Materials Against the PPWR Direction

An honest comparison, including the structure that will come under pressure. Barrier performance figures are our tested values; recyclability grades remain subject to the Commission’s delegated acts.

Grades are expressed as A (≥95%), B (≥80%), C (≥70%); below 70% is treated as technically non-recyclable and placing on the market is restricted (Annex II, Table 3). Grade status must be assessed under the Commission’s delegated acts once adopted.

Structure	Barrier	Recycling route	Certification	Adapts to
Mono-PE + AlOx	High barrier; OTR < 5 cc/m²/day, WVTR ≤ 0.5 g/m²/24hrs	Single-material PE stream	Recyclability assessment available	2030 grade target, single-material direction
Mono-PE + PCR	Medium to high, application dependent	PE stream with recycled content	GRS / RCS with transaction certificate	Recycled-content requirements (10% non-PET contact-sensitive from 2030)
Paper + water-based coating	Medium; suited to shorter shelf life or inner barrier	Paper stream	FSC chain of custody	Paper-based sorting and consumer communication
PLA / compostable	Application dependent; verify shelf life	Industrial composting	Industrial composting	Drip bags and permeable single-serve units (12 Feb 2028)
Aluminium laminate (legacy)	Very high barrier	Composite material separation constraints	-	Under pressure from 2030 grading; migration path recommended

Five PPWR Issues Specific to Coffee Packaging

General compliance pages stop at the regulation. These are the points where the regulation meets the way coffee is actually packed, shipped and kept fresh.

Freshness versus single-material: valves and high-barrier layers protect aroma but complicate recyclability. Mono-material structures with AlOx coatings reconcile the two without giving up shelf life.

Empty space versus headspace: degassing needs room, while minimisation rules push the other way. Sales packaging must reduce empty space to the minimum necessary from 12 February 2028, and technical headspace has to be justified in the design file.

Drip bags have their own deadline: permeable coffee bags are named in the compostability provision. If drip or hanging-ear formats are in your range, 12 February 2028 is a product-development date, not a packaging date.

Multi-material gift sets: rigid boxes, trays, wraps and sachets in one unit mean several material codes and several disposal routes to communicate — a labelling problem before it is a recycling one.

Re-validating shelf life after a switch: replacing a barrier layer changes oxygen and moisture transmission. Shelf life should be re-tested with measured OTR and WVTR data, not assumed from the previous structure.

The artwork is the choke point: most coffee brands will meet the rules on materials and documents and still lose time in artwork, where identification data, material codes and 2028 space compete for the same panel.

Evidence, Not Claims

Statements about compliance are only useful if they can be handed to the next person in the chain. These are the documents we can supply, and what each one is for.

Document	What it supports	How it is verified
BRCGS certification	Food-contact manufacturing controls	Certificate number, verifiable with the certification body
ISO 22000:2018	Food safety management system	Certificate number and scope
PFAS test report	The 25 ppb / 250 ppb / 50 ppm limits under Art. 5(5)	Accredited laboratory report with method and result
Heavy-metal test report	The 100 mg/kg limit under Art. 5(4)	Report per structure and component
GRS / RCS with transaction certificate	Recycled content claims in the plastic part	Transaction certificate traceable to the batch
OTR / WVTR data	Shelf-life validation after a material switch	Measured per structure, stated conditions
FSC chain of custody	Fibre-based cartons and boxes	Certificate code

Request the Certification and Test Report Set →

12-Point Packaging Compliance Self-Check

A working checklist. Tick what you already have; anything unticked becomes the agenda for your next packaging conversation.

1 · Declaration of conformity exists for each packaging type

2 · Technical documentation is retrievable within 10 days of a request

3 · Batch or serial identification appears on the pack

4 · Operator name, postal address and electronic contact are printed or linked by QR

5 · Material identification code matches the real structure, not the surface

6 · PFAS declaration or test evidence is on file for food-contact layers

7 · Heavy-metal sum (Pb + Cd + Hg + Cr VI) addressed in the technical file

8 · EPR registration completed in each market where you place packaging

9 · Sales packaging empty space reviewed against the 12 Feb 2028 requirement

10 · Drip or permeable single-serve formats have a compostability path for 2028

11 · Artwork reserves space for the 2028 harmonised label

12 · Batch coding rule is recorded and reflected in the documentation

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How We Support You

PPWR Data Pack: structure declaration, layer weights, material code, batch rule and test references — the input data for your declaration of conformity.

Artwork audit: your print file checked panel by panel against the identification and labelling requirements, returned as a gap list.

Material switch and shelf-life validation: moving to mono-material or higher recycled content, with OTR and WVTR re-testing so the coffee keeps its window.

One-stop formats: pouches, cartons, drip bags, capsule boxes and cups from one manufacturing network, so the compliance logic stays consistent across your range.

Version and print planning: multi-SKU artwork sets with consistent identification data and 2028 reservations, using digital printing where short runs and frequent changes would otherwise be costly.

Regulatory watch: we track the implementing and delegated acts and update this page as they land, so you do not have to monitor the Official Journal yourself.

Book a 30-Minute Compliance Review →

What It Costs to Wait

Compliance spend is rarely the largest line. The expensive part is doing the same work twice.

Decision	One revision (recommended)	Two revisions
Artwork	2026 identification data and 2028 label space reserved together	Print change now, full redesign for the 2028 label
Proofing and approval	One approval cycle	Two cycles, two internal sign-offs
Print implementation	One setup — cylinder work avoided where digital printing suits the run	Second setup, second cylinder or plate cost where gravure applies
Inventory	Old stock runs down once	Second transition and write-off risk for packaging printed to the previous design
Material switching	Shelf life re-validated once, with measured OTR / WVTR	Re-test after each change

Get a Cost Estimate for Your Range →

FAQ — PPWR for Coffee Brands

What applies to my coffee packaging right now?

Since 12 August 2026: a declaration of conformity with technical documentation for each packaging type; identification elements and operator details on the pack; PFAS limits in food-contact packaging; the heavy-metal limit; and EPR registration in the markets where you place packaging.

Why do some sources say labelling only starts in 2028?

They are referring to the harmonised label under Article 12 — material-composition pictograms and the digital identifier — which applies from 12 August 2028 or 24 months after the implementing acts, whichever is later. That is an additional obligation, not the first one.

Is there a legal minimum font size for the label yet?

Not yet. The Commission will set technical specifications such as pictogram dimensions and font sizes in implementing acts. Any dimensional rule applied today is practical guidance to keep information legible and scannable after filling — not a statutory threshold.

How long must we keep the declaration of conformity?

Five years for single-use packaging and ten years for reusable packaging from the date the packaging was placed on the market, together with the technical documentation (Annex VII, point 4).

If we change the artwork, do we need a new declaration of conformity?

A print design change alone generally does not trigger a new declaration. A change of material or packaging format does, because the declaration refers to a specific packaging type. Artwork edits made for labelling should be logged against the existing declaration.

We are a non-EU brand. Whose details go on the packaging?

The manufacturer indicates its name or trade mark, postal address and, where available, electronic contact; importers place their own details on the packaging they place on the market. The allocation should be settled before the artwork is released.

What if we only sell in small volumes?

The obligations apply to packaging placed on the market, not to company size. Small ranges are, however, often easier to switch: digital printing keeps version changes affordable and avoids cylinder costs on low volumes.

What happens if our packaging does not comply?

Manufacturers must take corrective measures, withdraw or recall non-compliant packaging and inform the market surveillance authority. Member States apply penalties for infringements under Article 68. Importers may be required to hold the goods.

Regulatory Watch

18 September 2026. We log the changes that affect packaging decisions rather than every procedural step.

Date logged	Development	What it means for you
18 Sep 2026	PPWR obligations in force since 12 August 2026; no read-across from the previous directive for in-scope packaging	If the declaration, technical file or identification is not in place, it is an open item now — not a 2028 item
18 Sep 2026	Harmonised label pending implementing acts; Article 12 obligations date from 12 August 2028 or 24 months after those acts, whichever is later	Reserve label space in the current artwork revision rather than waiting for the specifications
18 Sep 2026	Delegated acts on design for recycling (due by 1 January 2028) will define grade criteria per packaging category	Material decisions made before those criteria exist carry more risk — build in flexibility
18 Sep 2026	Compostability standards (EN 13432 revision) under preparation following the Commission standardisation request	Drip-bag compostability should be planned with the standard in mind, not only current certificates

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Start with One Conversation

Bring a pouch, a carton or a print file. We will tell you which obligations apply to it, what evidence we can supply, and what has to change in the artwork — before the next print run.

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