EHPM Urges Pragmatic PPWR Implementation: Impact on Supplement Packaging Compliance

Brussels, Belgium — 05 June 2024

The European Health Product Manufacturers (EHPM) has released a position paper detailing critical industry concerns regarding the implementation of the European Union's Packaging and Packaging Waste Regulation (PPWR) for food supplements. While endorsing the regulation's objectives, EHPM stresses the necessity for a science-based, proportionate framework that accounts for the specific technical requirements of stability-critical supplement packaging.

Food supplements frequently require packaging that provides robust protection against moisture, oxygen, and light to maintain product quality, declared nutrient content, and safety throughout shelf life. EHPM highlights that medicinal products and medical devices benefit from regulatory flexibility concerning packaging, a consideration not extended to food supplements with comparable stability needs under current PPWR drafts.

Two primary implementation challenges confront the sector. Firstly, PFAS restrictions and associated Declaration of Conformity obligations become applicable from 12 August 2026. Despite European Commission guidance, significant practical uncertainties persist concerning compliance verification, technical documentation, analytical methodologies, and the treatment of existing packaging stocks. This ambiguity creates supply chain risk and potential for non-compliance fines.

Secondly, the timeline for recyclability and recycled-content requirements poses substantial difficulties. 'Design-for-Recycling' criteria are expected by 2028, yet real-time stability studies for food supplements typically demand 24 to 36 months. This timeline conflict leaves insufficient time for manufacturers to validate new packaging materials. Additionally, suitable food-contact recycled materials remain limited or unavailable for several polymer streams critical to the supplement sector.

Industry evidence, including surveys by be-sup in Belgium (2025) and EHPM across Europe (2026), indicates high industry awareness and investment in alternative packaging solutions. However, these surveys confirm that validation work is ongoing, stability studies are largely incomplete, and fully validated alternatives, particularly for high-barrier formats such as blisters, are not yet commercially available. This underscores the disconnect between regulatory deadlines and technological readiness.

What this means for United Kingdom

While the UK is no longer bound by EU regulations, the PPWR's impact will be felt indirectly. UK manufacturers exporting to the EU must comply with these new packaging standards, necessitating investment in parallel packaging lines or universal reformulation for key export lines. Procurement leads will face increased MOQs and longer lead times for EU-compliant materials. Brand owners supplying the EU market must budget for significant reformulation costs, potential delays to product launches, and the risk of market withdrawal if compliance is not met. Companies that proactively identify and validate compliant, sustainable packaging solutions early may gain a competitive advantage in the EU market, provided they align with proposed derogations for specific formats.

EHPM is advocating for several measures, including a temporary, time-limited derogation until 2035 for recyclability requirements where validated alternatives are unavailable. They also call for a harmonised, risk-based approach to PFAS limits with clear legal and technical guidance, and an adapted approach to recycled-content requirements for contact-sensitive food supplement packaging where authorised materials are currently non-existent. These measures are crucial to ensure product quality, safety, and supply continuity.

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