A figure of roughly 700 chemicals has been circulating as the PPWR’s draft list of substances of concern. The Commission’s own August 2026 FAQ says something different and important: there is no definite number or list. What exists is an ongoing ECHA-led study, and a delegated-act power the Commission can use once it concludes.
What Happened
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, obliges economic operators to minimise substances of concern in packaging and empowers the Commission to restrict them by delegated act. The second edition of the Commission’s official PPWR Frequently Asked Questions, published by DG Environment Unit B.1 in August 2026, addresses the question directly and states that there is no definite number or list of substances of concern in packaging. What is under way is a Commission-funded study led by the European Chemicals Agency to identify substances of concern relevant to packaging, drawing on manufacturing and waste-treatment information. ECHA has separately opened a call for evidence on substances in packaging and packaging waste. Note on sourcing: ECHA’s own consultation pages could not be retrieved for this issue — see the verification note below — so the consultation’s dates and entry count are not stated here.
What’s New
- The Commission’s official position, in the August 2026 FAQ: there is no definite number or list of substances of concern in packaging.
- An ECHA-led, Commission-funded study is identifying packaging-relevant substances of concern using manufacturing and waste-treatment information.
- Substance of concern is defined by cross-reference to Article 2(27) of the Ecodesign for Sustainable Products Regulation: substances meeting REACH Article 57 criteria, substances in specified CLP hazard classes, regulated persistent organic pollutants, and substances that negatively affect the reuse and recycling of materials.
- The list, once developed, will inform future regulatory decisions, and the Commission may adopt delegated acts restricting substances of concern that affect reuse and recycling.
- The PPWR substances-of-concern work is distinct from the REACH Candidate List of SVHCs, which ECHA maintains separately.
- Verification note: ECHA’s call-for-evidence and PPWR activity pages returned HTTP 403 to every automated request while this issue was prepared, so the consultation dates, the structure of the list and the reported figure of approximately 700 entries are not confirmed here and are deliberately not reproduced. The official page is linked below for manual checking.
Key Dates & Timeline
PPWR enters into force
First edition of the Commission PPWR FAQ
PPWR general application date
Second edition of the Commission PPWR FAQ confirms no definite SoC list exists
ECHA-led study to identify packaging-relevant substances of concern
Commission delegated acts may restrict substances of concern affecting reuse and recycling
Affected Industries
Packaging · All manufacturing · Light duty vehicles · Heavy duty vehicles · Electrical and electronic equipment · Chemicals · Plastics and polymers
Who Is Affected
Packaging manufacturers and suppliers; importers, distributors and fillers; any economic operator placing packaged goods on the EU market; restricted-substances and packaging-engineering functions.
Standards / Products in Scope
Substances present in packaging and packaging waste placed on the EU market, assessed against the Article 2(27) ESPR definition of substances of concern.
Prohibitions, Restrictions & Requirements
No restriction is in force. The PPWR requires minimisation of substances of concern and gives the Commission a delegated-act power to restrict those affecting reuse and recycling; that power has not yet been exercised for a specific list.
What Companies Should Do
- Do not plan against a fixed list of approximately 700 substances — the Commission says no such list exists. Plan against the Article 2(27) definition instead, which is stable and already screenable.
- Screen your packaging portfolio against REACH Article 57 criteria, the specified CLP hazard classes and the POPs Regulation now; that captures most of what any eventual list will contain.
- Treat substances that impair recyclability — certain inks, adhesives, barrier coatings and additives — as the second screening axis, since that is the category the delegated-act power targets directly.
- Watch the ECHA call for evidence for substances in packaging and packaging waste, and respond if your packaging relies on a substance likely to be captured.
This is a case where the circulating number is more precise than the underlying reality. There is no adopted list, and treating a reported figure as a compliance target invites wasted reformulation. The definition, on the other hand, is already law — screening against it is the work that will still be useful when the list does arrive.
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