PPWR Packaging Substances: ECHA Evidence Call + UK PRMA

🇪🇺 PPWR: ECHA Call for Evidence on Substances of Concern in Packaging (PFAS)

In 2025, the European Chemicals Agency (ECHA) ran a call for evidence to identify substances of concern (SoCs) used in packaging, feeding the report the European Commission must prepare under Article 5(2) of the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40).

The call for evidence gathered information on how packaging types and components are classified, and on the chemical properties and hazard profiles of the substances used in them.

It also looked at how those substances are treated under existing EU law — in particular CLP and REACH — and at hazardous chemicals such as PFAS in food-contact packaging. A stated aim is to align the substance requirements in the PPWR with REACH, the POPs Regulation and the rules on food-contact materials.

Status: Consultation closed on 28 October 2025. ECHA has since screened around 6,000 substances reported in packaging and identified around 700 as substances of concern in a draft list, which it put to stakeholders for feedback in August 2026. ECHA's final study report is due to the Commission by 21 September 2026; the Commission's own report under Article 5(2) PPWR is due by 31 December 2026. Being on the list does not by itself trigger a restriction.

Learn more here

📌 What This Means for Manufacturers

• Run a substance inventory across your packaging supply chain, starting with food-contact applications.
• Check your packaging substances against REACH, CLP and the POPs Regulation now, rather than waiting for a restriction to name them.
• Check whether the substances in your packaging appear on ECHA's draft list of around 700 substances of concern — that list will shape which restrictions come next.

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🇪🇺 Drinking Water Directive: EU Positive Substances Lists (DWD)

The recast Drinking Water Directive (Directive (EU) 2020/2184, Article 11) requires the starting substances, compositions and constituents used in materials and products that come into contact with drinking water to appear on one of four European positive lists.Those lists were established by Commission Implementing Decision (EU) 2024/367 of 23 January 2024 and cover:

- starting substances for organic materials

- compositions of metallic materials

- organic constituents of cementitious materials

- compositions of enamels, ceramic and other inorganic materials

This ensures that drinking water remains safe from source to tap. "Hafnium is absolutely safe," said Applia General Manager Paolo Falcioni, noting that the element has been used in enameled hot water tanks for over 100 years.

He also explained that if hafnium or zirconium were not mixed with the enamel, the glass would crack and the hot water would not stay hot.

Status: Adopted. The European positive lists apply from 31 December 2026 — from that date, materials and products in contact with drinking water placed on the EU market must use listed substances.

Learn more here

📌 What This Means for Manufacturers

• Cross-check every water-contact component — tanks, valves, pipes, coatings, enamels — against the four European positive lists well before 31 December 2026.
• Ask suppliers now for full material compositions and written confirmation that each starting substance is listed.
• Plan substitutions for anything unlisted, especially legacy or niche materials. Reformulation, re-testing and re-certification take longer than the remaining time allows.

🇬🇧 UK PRMA 2025: Online Product Safety & Marketplace Rules

The UK Product Regulation and Metrology Act 2025 (2025 c. 20) received Royal Assent on 21 July 2025. Most of its provisions took effect that day; section 11(1) and (3), which amend the Consumer Protection Act 1987 and the Weights and Measures Act 1985, come into force on a date to be appointed by the Secretary of State.

The Act gives the government powers to make product regulations for reducing or mitigating the risks products present, and for reducing their environmental impact.

It is worth being precise about scope: product safety rules in Great Britain and Northern Ireland still differ. Under the Windsor Framework, Northern Ireland continues to apply EU product law, and the Act does not change that on its own. If you sell into both, you are still managing two regimes.

The Act is a framework law. It gives ministers the power to make product safety and metrology regulations, and the substantive obligations — including those for online marketplaces — will be set out in secondary legislation. The government has said it intends to align key parts of the online marketplace regime with the EU General Product Safety Regulation (Regulation (EU) 2023/988).

Implementation sits with the Office for Product Safety and Standards (OPSS), building on its existing consumer-facing work, including the "Buy Safe, Be Safe" campaign and its guidance on lithium-ion battery safety.

Status: In force since 21 July 2025 as a framework. The duties that will matter most for products sold through online marketplaces are still to come, in secondary legislation.

Learn more here

📌 What This Means for Manufacturers

• Watch for the first PRMA consultations and statutory instruments, especially those covering online marketplaces and battery-powered products.
• Bring your UK marketplace processes up to GPSR standards now — responsible person details, traceability, warnings and instructions — so one process covers both markets.
• Give one person ownership of UK listing compliance: labelling, claims and the information each platform requires.

✅ Need help translating these changes into actionable tasks?

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Related reading: EU packaging EPR fees 2026: who pays, where, and how much.