⚠ Compliance Alert · EU · PPWR

EU Sets Final Deadlines for Lead Crystal Packaging Under the PPWR: Production Ends 2028, Sales End 2029

On 28 October 2026, the European Commission published Commission Delegated Decision (EU) 2026/1948, amending Decision 2001/171/EC under the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR). It gives crystal glass packaging a temporary, conditional exemption from the PPWR heavy metal limit of 100 mg/kg. Lead-containing crystal packaging may be manufactured until 31 December 2028 and sold until 31 December 2029. After that, it must meet the same limits as all other EU packaging.

Why This Can’t Wait

The old Packaging Directive 94/62/EC exempted lead crystal, but the PPWR did not keep that exemption. The new grace period is not automatic: it applies only if packaging is treated, permanently marked, returnable free of charge and recycled in a documented closed loop. Brands and suppliers that miss these conditions, or still hold leaded stock after 31 December 2029, risk non-compliant products on the EU market.

Compliance Timeline — Mark These Dates

  • 29 October 2026 (In force): Delegated Decision (EU) 2026/1948 enters into force.
  • 31 December 2028 (Production deadline): Last day to manufacture crystal glass packaging containing lead, whether intentionally added or left over from past production. Only lead-free packaging may be produced after this date.
  • 31 December 2029 (Market deadline): Grace period ends. Packaging made before end-2028 may be finished, filled, labelled, distributed and sold only until this date. The standard 100 mg/kg limit then applies.

What’s Allowed During the Grace Period

✅ Allowed until 31 Dec 2029

  • FinishingCutting, engraving or decorating packaging made before end-2028
  • Filling and labellingSpirits, fragrances and cosmetics
  • Distribution and salePlacing existing stock on the EU market

❌ Not allowed

  • Manufacturing leaded crystal packagingAfter 31 December 2028
  • Selling leaded crystal packagingAfter 31 December 2029
  • Relying on the exemption without meeting conditionsAt any time during the grace period

Mandatory Conditions for Using the Exemption

  • Minimise lead: add lead only where genuinely necessary and actively work towards fully lead-free production.
  • Surface treatment: apply dealkalisation or an equivalent process to reduce lead migration into the product.
  • Permanent marking: mark every piece with the manufacturer’s identity for traceability.
  • Consumer information: tell customers they can return empty packaging for free recycling.
  • Closed and controlled loop: send returned packaging back to the marked producer, directly or via retailers and distributors, for remelting in its own production.
  • Record keeping: document that the take-back system works and provide records to national authorities or the European Commission on request.

Who Is Affected

The update affects crystal glass manufacturers (mainly in France, Portugal, the Czech Republic and Slovenia), brand owners in luxury spirits, fragrances and cosmetics using crystal bottles, decanters or jars, fillers, distributors and retailers handling these products, and importers bringing them into the EU.

💬 Our Compliance Team’s Take

“This decision buys the crystal industry time, but not much, and it comes with real operational work. Marking, dealkalisation and a documented take-back loop all need to be in place now, not in 2029. Brands should be asking suppliers for their lead-free transition plan today.”

— APA Engineering Regulatory Compliance Desk

What Companies Should Do Now

  • Identify every product in your portfolio that uses crystal glass packaging
  • Confirm each crystal glass supplier’s lead-free transition plan and ability to meet the 31 December 2028 production cut-off
  • Verify that suppliers permanently mark each piece and apply dealkalisation or an equivalent treatment
  • Add free-return recycling information to packaging, labels or websites
  • Set up a documented take-back route to the original producer and keep evidence that it works
  • Plan inventory so no lead crystal packaging remains on sale in the EU after 31 December 2029

Key Questions Answered

Can lead crystal packaging still be sold in the EU?

Yes, until 31 December 2029, if it was manufactured by 31 December 2028 and all conditions of Decision (EU) 2026/1948 are met.

What is the PPWR heavy metal limit for packaging?

The combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg.

What is dealkalisation?

A surface treatment that forms a protective layer on the inside of the glass, reducing how much lead can migrate into the contents.

What happens after 31 December 2029?

The exemption ends. All crystal glass packaging on the EU market must meet the 100 mg/kg limit, which in practice means lead-free crystal.

🚨 Bottom Line

Lead crystal packaging is being phased out of the EU. Production must stop by the end of 2028 and remaining stock must be sold by the end of 2029. Until then, the exemption holds only for packaging that is treated, marked, returnable and tracked. Use this update as the trigger to audit your crystal glass supply chain and PPWR compliance plan this quarter.

Reference:

Commission Delegated Decision (EU) 2026/1948, Official Journal of the European Union, L series, 28 October 2026
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)
Related: PPWR Is Live: What It Means For Your Business (webinar)

 

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