PPWR Cocoa Packaging Guide: EU Rules for Cacao & Chocolate

A plain-language guide to Regulation (EU) 2025/40 for anyone shipping cacao beans, nibs, powder, butter, liquor or chocolate into the European Union.

By Leila Carvajal Erker, Founder, CocoaSupply · Last updated October 8, 2026 · 12 min read

What is the PPWR, and why does it matter for cocoa packaging?

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, is the EU law that replaced the 1994 Packaging Directive. It entered into force on 11 February 2025 and has applied since 12 August 2026. Because it is a regulation and not a directive, the same text applies directly in every Member State, to EU-made and imported packaging alike.^[1][2]

Most of what has been written about it targets consumer brands. Very little covers the cacao trade, where the packaging is a jute sack in a container rather than a box on a supermarket shelf. That gap is why we wrote this guide. PPWR cocoa packaging questions reach us from makers and importers almost every week now, and the answers are scattered across legal texts, Commission notices and law firm briefings.

The scope is wide on purpose. The regulation covers all packaging and packaging waste regardless of material or origin, whether industrial, retail or household.^[2] The legislators' reasoning is in the recitals: 40% of plastics and 50% of paper used in the EU goes into packaging, and packaging makes up 36% of municipal solid waste.^[1] For cocoa, that means the sack around your beans, the liner inside a powder bag, the carton around a block of butter and the wrapper on a finished bar are all in scope.

One thing to keep in mind as you read: the PPWR regulates the packaging, not the cocoa. Your food safety and labelling rules for the product itself have not changed. If you work with EU buyers, our guides to EUDR requirements for cocoa and the legal definition of chocolate in the EU and other markets cover the product side.

What PPWR requirements apply from August 2026?

Since 12 August 2026, three groups of obligations apply. There are limits on substances in packaging (heavy metals for all packaging, plus PFAS for food-contact packaging). There is a conformity assessment with technical documentation and an EU Declaration of Conformity. And the manufacturer and importer must be identified on the packaging or on an accompanying document.^[4][12]

Heavy metals

The combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging or its components may not exceed 100 mg/kg.^[1][12] This is not new. The same restriction applied for many years under the old directive.^[7] What is new is that compliance now has to be documented as part of the conformity assessment.

PFAS in food-contact packaging

PFAS are per- and polyfluoroalkyl substances, often called forever chemicals. Article 5(5) sets three limits for packaging that is in contact with food, or intended to be.^[1]

There is no harmonised EU test method yet. The Commission recommends a stepwise approach, starting with total fluorine and moving to targeted analysis when needed.^[8] If total fluorine comes back above 50 mg/kg, the manufacturer has to be able to show whether that fluorine comes from PFAS or from something else.^[1]

From a chemistry point of view, the cocoa formats to watch are the ones designed to hold back fat or moisture: grease-resistant papers for chocolate and coated kraft bags for powder or nibs. Fluorinated coatings were a common way to get that performance. Plain jute and uncoated paper are much lower risk, but low risk is not the same as documented, and documentation is what the regulation asks for.

Declaration of Conformity and technical documentation

A PPWR Declaration of Conformity is the manufacturer's signed statement that a packaging unit meets the requirements that apply to it. According to the Commission's August 2026 FAQ, one declaration covers the packaging unit as a whole, in the language of each Member State where it is supplied.^[3][5] The technical documentation behind it must be kept for five years for single-use packaging and ten years for reusable packaging, and it cannot be held only by the supplier.^[5] The conformity assessment can be carried out by a laboratory on the manufacturer's behalf, but the manufacturer has to compile the technical documentation itself, and its legal responsibility cannot be moved to another party by contract.^[5]

Who is the manufacturer under PPWR when cocoa is shipped from outside the EU?

The manufacturer is whoever puts its name or trademark on the packaging. For unbranded packaging, it is whoever orders and specifies it: the converter for generic, standard formats, and the buyer for custom-made ones. The EU importer then has to confirm that the manufacturer completed the conformity assessment, and add its own contact details.^[5]

The importer is the operator established in the EU that first places packaging from a third country on the EU market. Since 12 August 2026, the importer must make sure the non-EU manufacturer has carried out the conformity assessment, that the identification details are in place and that the required documents travel with the packaging. The importer must also add its own name, trade name or trademark, postal address and, where available, electronic contact details, on the packaging, in a QR code or on an accompanying document.^[5]

Three details matter for cocoa importers:

• A branch office cannot be the importer. It has no separate legal personality. A non-EU company with only a branch in the EU needs a subsidiary, or an authorised representative where the Member State requires one.^[10]
• The producer is a different role. The producer pays extended producer responsibility (EPR) fees for collection and recycling in the Member State where the packaging becomes waste. Only one producer exists per packaging unit, and it is not always the manufacturer.^[10]
• Goods in transit are not placed on the market. Cocoa that only passes through the EU on its way elsewhere, without release for free circulation, does not need PPWR compliance.^[5]

Here is how that plays out in practice. An exporter in Ecuador ships beans in plain jute sacks bought from a sack mill. The sacks are generic, so under the Commission's reading the sack mill is the PPWR manufacturer. If the same exporter has its logo printed on custom sacks, the exporter becomes the manufacturer. A shipping sticker alone does not change the role.^[5] One caution: stencilling the exporter's name on sacks is common in the cocoa trade, and the FAQ gives a name and a trademark equal weight. If that is your practice, talk to your importer about how they read it, because some national authorities still disagree with parts of the Commission's FAQ.^[5]

Are jute cocoa bags affected by PPWR?

Yes. Jute and sisal sacks are packaging, so once they are placed on the EU market the substance limits and documentation rules apply. They are also in direct contact with cocoa beans, which brings the PFAS limits into play. Some of the later rules are lighter for them, because textile packaging is listed among formats exempt from design-for-recycling criteria.^[6]

Transport packaging, except e-commerce packaging, is also exempt from the harmonised sorting labels that start in 2028.^[6] On the other hand, transport packaging imported from third countries counts toward the PPWR reuse targets from the moment of import, and the user of the transport packaging is responsible for meeting them.^[6] How those targets will treat single-trip bean sacks is one of the points we are still watching. Our guide to the best packaging materials for cocoa and cocoa products explains why jute remains the standard for beans in the first place.

Table based on Regulation (EU) 2025/40 and the Commission's 2026 guidance as reported by Packaging Europe and Cattwyk.^[1][5][6] Stretch wrap counts as packaging when sold on the roll, even though it is cut at the point of use.^[5]

When do PPWR recyclability and labelling requirements apply?

Mostly from 2028 onward. Harmonised sorting labels apply from 12 August 2028, reusable packaging labels from 12 February 2029, and the design-for-recycling, recycled content, minimisation and 50% empty-space rules from 2030. Several of these still depend on delegated or implementing acts that the Commission has not yet finalised.^[4][6][12]

This is why we push back gently when someone calls the PPWR "the new recycling rule". The recycling parts are real, but they are three to four years away. What changed in August 2026 is chemistry and paperwork.

Can existing packaging stock still be sold after August 2026?

Yes. Packaging placed on the EU market before 12 August 2026 may stay there even if it does not comply. Packaging produced before that date but not yet placed on the market does not need to be destroyed or relabelled, and the required identification details can travel on an accompanying document.^[5][12]

For packaging made after 12 August 2026, an accompanying document is only acceptable where marking the packaging itself is not possible. Identification can work at the level of type, model or batch, as long as it links back to the technical documentation and the Declaration of Conformity.^[5]

Enforcement is starting softly. The Commission has said the obligations that apply from 12 August 2026 should not disrupt trade flows, supply chains or consumer access to goods.^[7] Under Article 62, a Member State that finds non-compliance must first require the operator to correct it, and only if the problem persists can it prohibit, recall or withdraw the packaging. The FAQ is not binding, though, and national authorities may be stricter.^[5]

What is settled law and what is still pending?

The dates, the substance limits, the definitions of manufacturer and importer and the duty to issue a Declaration of Conformity are settled in the regulation itself. How to test for PFAS, how to grade recyclability, how to calculate empty space and how each Member State handles EPR are still being worked out in guidance, implementing acts and national law.^[1][3][8]

Settled in Regulation (EU) 2025/40

• Application date of 12 August 2026 and the later dates for labelling and 2030 requirements.^[1]
• PFAS limits for food-contact packaging and the 100 mg/kg heavy metals limit.^[1]
• The roles of manufacturer, importer, distributor and producer, and the obligation to carry out a conformity assessment.^[1][2]

Still pending or open to interpretation

• A harmonised EU method for PFAS testing in food-contact packaging.^[8]
• The delegated act on design-for-recycling criteria and the implementing acts on labels and empty space.^[6]
• National implementing laws and EPR rules. Germany, for example, published a draft packaging implementation act in November 2025, and other Member States are adopting their own supplementary legislation.^[5][9]
• The Commission's guidance and FAQ are non-binding. The Commission published a first FAQ in March 2026, a Guidance Document in June 2026 and an updated FAQ on 3 August 2026.^[3][9]

Last reviewed: October 8, 2026. We will update this page as implementing acts and national rules are adopted.

What documents should cocoa buyers request from packaging suppliers?

Ask for the EU Declaration of Conformity for each packaging unit, PFAS test results or a total fluorine result for anything that touches the product, a heavy metals statement, and the manufacturer identification that links the packaging batch to those documents. If you import, add your own contact details to the packaging or accompanying document.^[5][8]

• EU Declaration of Conformity for each packaging unit, in the language of the Member State where you supply it.^[5]
• PFAS evidence for every food-contact layer: total fluorine results under the Commission's stepwise approach, or targeted analysis with a limit of quantification below 25 ppb.^[1][8]
• Heavy metals statement confirming the 100 mg/kg combined limit.^[1]
• Manufacturer identification by type, model or batch that links to the technical documentation.^[5]
• Your existing food-contact compliance documents. The PPWR adds to the EU food-contact materials rules. It does not replace them.

Good packaging also protects quality. Our guide on how to store cacao beans properly covers moisture and storage once the sacks arrive.

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