Are PE bags PPWR-compliant?
Yes, if the manufacturer declares conformity and complies with the substance limits: heavy metals no more than 100 mg/kg in total and, for food contact, PFAS below the limits in Art. 5(5). Mono-PE has good prerequisites for recyclability; the binding classification follows the delegated acts from 2030.
As of: 16.10.2026 · Reviewed by: Editorial team Elke Plastic GmbH · Information provided without guarantee, not legal advice.
What “PPWR-compliant” means for a bag
The PPWR (Regulation (EU) 2025/40) entered into force on 11.02.2025 and has applied since 12.08.2026. A PE bag counts as compliant if three things come together:
- Evidence: The manufacturer has issued an EU declaration of conformity and keeps the technical documentation.
- Substances: The sum of lead, cadmium, mercury and hexavalent chromium is no more than 100 mg/kg. For food contact, the PFAS limits also apply.
- Later stages: Labelling (at the earliest from 12.08.2028) as well as recyclability and recycled content (from 2030) will follow and depend on acts of the European Commission.
What applies today and what comes later
| Requirement | From when | Applies to PE bags? | Evidence |
|---|---|---|---|
| Declaration of conformity and technical documentation | 12.08.2026 | Yes, by the manufacturer | Data sheet per item |
| Heavy metals: sum no more than 100 mg/kg | 12.08.2026 | Yes | Test report / data sheet |
| PFAS limits for food contact (25 ng/g individual, 250 ng/g sum, 50 mg/kg total fluorine) | 12.08.2026 | Yes, if food contact | Test report / data sheet |
| Harmonised labelling for material and disposal | at the earliest 12.08.2028 | Yes, later | Labelling on the packaging |
| Recyclability: classification into performance grades | at the earliest 2030 | Yes, later | Classification under delegated acts |
| Recycled content for plastic packaging | from 2030 | Depending on the type of packaging | Manufacturer's statement |
Details on the limits: PFAS and heavy metals. Details on the grades: Recyclability A to C.
Mono-PE or composite: why the material matters
A bag made of a single material, for example pure polyethylene (mono-PE), has good prerequisites for mechanical recycling. Multilayer composites such as PET / aluminium / LDPE are considered difficult to recycle in the standard sorting process. For both, the binding classification is the one under the European Commission's delegated acts, not the material designation alone.
More in the guide Mono-material or composite and on the alternatives to aluminium composite.
Bag types at a glance
| Bag type | Material | Where you can see the classification |
|---|---|---|
| Flat bag | LDPE / PP / OPP / rLDPE | PPWR traffic light and data sheet on the product · Flat Bags |
| Ziplock bag | LDPE / PP / rLDPE | PPWR traffic light and data sheet · Ziplock Bags |
| Stand-up pouch | varies by item, for example OPP, aluminium composite or mono-PE | PPWR traffic light and data sheet · Stand-up pouches |
| Tubular film | LDPE / rLDPE | PPWR traffic light and data sheet · Tubular film |
| Coffee bag | varies by version | PPWR traffic light and data sheet · Coffee Bags |
How to check a bag in three steps
- Look at the PPWR traffic light: Green means the requirements currently in force are met. Yellow means compliant today, but an upcoming stage, such as 2030, is not yet met. Red means not compliant at present.
- Open the data sheet: You will find the declaration of conformity and the evidence in the data sheet archive.
- Check your suppliers: As a distributor or importer, use the PPWR checklist.
All items with a green traffic light: PPWR-compliant packaging.
Frequently asked questions
Is LDPE recyclable within the meaning of the PPWR?
Pure polyethylene (mono-PE, also LDPE) has good prerequisites for mechanical recycling. The binding classification into performance grades A to C is set by the European Commission in delegated acts and will become relevant at the earliest from 2030.
As a distributor, do I need a data sheet for every bag?
Distributors and importers must check that their suppliers have the declaration of conformity and technical documentation, and keep the documents available. At Elke Plastic, you will find the evidence for each item in the data sheet archive.
Should zip bags be assessed differently from simple flat bags?
The closure can affect the material and therefore the classification. What matters is the declaration of conformity and data sheet of the item in question, not the shape of the bag.
What does the PPWR traffic light on the product mean?
Green: the requirements currently in force are met. Yellow: compliant today, but an upcoming stage, such as 2030, is not yet met. Red: not compliant at present; we recommend an alternative.
