PPWR 12 August 2026: EU Canned Packaging Compliance Roadmap (CBAM 2026, BPA Ban 2025)

European metal food can manufacturers are facing a major compliance overhaul. From 2026 onward three new EU rules will apply: the Packaging and Packaging Waste Regulation (PPWR) effective 12 August 2026 [8], the Carbon Border Adjustment Mechanism (CBAM) fully in force from Jan 2026 [5], and a Commission regulation banning bisphenol A (BPA) in food-contact materials from 20 January 2025 [3]. This guide explains each mandate and outlines a quarterly compliance calendar for metal packers – focusing on regulatory requirements, procurement criteria, implementation steps and an action checklist.

European metal packaging underpins a market worth roughly US$41 billion in 2025 [19]. With this scale comes responsibility: metal packaging is prized for circularity (EU recycling rates are ~75% for aluminium cans and ~82–83% for steel packaging)[15][16] but must now meet tougher rules. PPWR demands new design, labelling and waste targets; CBAM assigns a carbon price to imported steel/aluminium; and the BPA ban forces can-coating reformulations. We cover what to monitor each quarter of 2026 to stay compliant, summarised in industry terms for owners, procurement and compliance teams.

Executive Summary

EU rules are changing for metal cans. The new PPWR (Regulation EU 2025/40) applies from 12 August 2026 [8] and mandates recyclable design, weight limits, reusability and extended producer responsibility (EPR)費. EU CBAM 2023/956 requires carbon payments on imported steel/aluminium starting Jan 2026 [5] [4], so carbon counting and reporting is needed. An EU regulation (2024/3190) banning BPA in food-contact materials took effect 20 Jan 2025 [3] – canned food linings must switch to BPA-free polymers and document compliance. Alongside these, market trends (like the push to 100% recycled cans) and cost factors (carbon pricing, scrap shortages) matter. This guide gives a solution overview, lays out supplier selection criteria, provides a quarterly implementation roadmap for 2026, and finishes with an action checklist. In short, start planning now: the first PPWR deadline is mid-2026, and CBAM and BPA rules already apply.

Regulatory Landscape: PPWR, CBAM and BPA Restrictions

Packaging and Packaging Waste Regulation (PPWR EU 2025/40) – This new regulation, replacing the old Packaging Directive, enters into force Jan 2025 and applies from 12 Aug 2026 [8]. It covers all packaging (all materials, including metal cans) [22]. Key requirements: packaging must be sustainably designed (minimized weight and volume, no harmful substances) and fully recyclable [7] [10]. From 2026 on, EU authorities will enforce that packaging is “designed for material recycling and able to be collected, sorted and recycled at scale” [7] (performance grades start 2030). Producers must bear full extended producer responsibility (EPR) costs (collection, sorting and recycling fees) and use modulated fees to incentivize eco-design [6]. Notably, by 2030 only reusable or recycled solutions may remain marketable. For metal canmakers this means ensuring every can design meets PPWR’s recyclability, labelling and hazardous-material criteria well before Aug ’26.

Carbon Border Adjustment Mechanism (CBAM) – From 1 Jan 2026 the EU will charge importers of emissions-intensive materials (steel, aluminium, cement, etc.) for the CO₂ embedded in those imports [5] [4]. In practice, EU can producers purchasing imported aluminium or steel must record and report the upstream carbon footprint and purchase CBAM certificates to cover that CO₂. CBAM is a response to EU Emissions Trading System (ETS): it levels the playing field by making carbon-intensive imports as costly as EU-made steel/alum (subject to ETS). For metal packaging, CBAM means supply chain carbon accounting: each quarter importers must file emissions reports, and from 2026 they will pay CBAM fees on reported emissions [5]. The EU Commission has clarified that indirect emissions from electricity for metals will not be subject to CBAM, but direct process emissions will [5]. In late 2025 the Commission even expanded CBAM to some metal-intensive finished goods (machinery, containing heavy steel/alum) [24], highlighting that any steel/alum usage will soon carry carbon costs.

BPA and Other Bisphenols Restriction – Effective 20 Jan 2025, Commission Regulation (EU) 2024/3190 prohibits BPA and certain hazardous bisphenols in most food-contact materials (FCMs) [3]. Historically, BPA was widely used as a monomer in epoxy resin can liners. Under the new law, BPA (CAS 80-05-7) cannot be used in coatings, adhesives, inks, plastics, etc., for packaging (with only narrow exemptions for very large containers) [20]. Moreover, any FCM made with alternate bisphenols must contain no residual BPA [23]. Food can producers and coating suppliers must therefore have replaced BPA-based coatings by Jan 2025 or obtained rare authorizations. The regulation also requires strict documentation: any FCM product must be accompanied by a Declaration of Compliance (DoC) listing all bisphenols used as monomers [2]. In short, metal canlines must be proven BPA-free and fully documented. Non-compliant shipments may not enter the EU market.

Industry Context and Market Trends

European can producers benefit from a large and growing market. According to Mordor Intelligence, the EU metal packaging market (steel + aluminium cans and bulk containers) was about US$40.97 billion in 2025 [19], growing ~2.8% annually. Beverage and food can demand is strong, especially as consumers favor convenient, shelf-stable packaged foods. Globally, metal packaging is expanding (projected 3–4% CAGR) [17]. Cans are valued for durability and consumer appeal, and surveys show European consumers consider metal a sustainable choice versus plastic [18] [17].

Crucially, metal packaging leads in recyclability – a cornerstone for PPWR’s circular economy goals. The EU boasts the highest recycling rates in the world: steel cans “really recycled” (sorted & processed) reached 82% of market in 2023 [16], and aluminium beverage cans are similarly high circa 75–80%[15]. In 2022 alone, about 580,000 tonnes of used aluminium cans were collected for recycling in Europe [12], saving 5.4 megatonnes of CO₂. However, collection efficiencies vary by country and Deposit Return Schemes (DRS) are expanding, which companies should monitor. These trends show metal’s recyclability advantage, but PPWR will require even stricter controls on contaminants and design (e.g., no additional coatings/laminates that impede recycling).

Cost factors are also shifting. Carbon pricing affects metal supply as much as demand. EU scrap shortages have driven prices up, causing about 15% of domestic recycling capacity to idle [14]. In November 2025 the EU announced plans to restrict aluminium scrap exports by 2026 to preserve a critical raw material in Europe [1]. (40% of the bloc’s aluminium currently comes from recycled scrap.)[13]. Metal packers should anticipate both higher prices for primary aluminium and incentives for sourcing post-consumer scrap. Likewise, CBAM will add a new cost component to any imported aluminium or steel. Every tonne of imported steel will now carry a carbon price reflecting upstream emissions [5], so procurement budgets must adjust. On the upside, domestic low-carbon steel/aluminium producers may gain market share due to CBAM, and increased scrap availability in EU (via export limits) will help keep domestic recycling competitive.

Selection Criteria for Packaging and Suppliers

Metal-packaging buyers and production planners should use clear criteria to select materials and vendors under these new constraints. Table 2 lists key factors for evaluation.

Table 2: Key criteria for selecting packaging materials and suppliers under new EU rules.

In practice, a procurement RFQ should explicitly request information on PPWR/CBAM/BPA compliance. Ask suppliers for technical data sheets and compliance declarations (e.g., FCM compliance for can lacquers). Score bids on these compliance factors equally with price. For example, if two steel suppliers have similar costs but one uses EU-sourced low-carbon steel (and the other relies on high-CBM imports), the former is strategically preferable.

Implementation Roadmap: 2026 Quarterly Tasks

Building compliance into quarterly milestones helps avoid last-minute rushes. The timeline below lays out suggested activities per quarter. Adapt to your company’s fiscal year if needed. (Note: some BPreg tasks begin late 2025 due to early BPA ban, but primary focus here is 2026.)

Q4 2025 – Q1 2026: Laying the Groundwork
– BPA Compliance: Ensure all new and existing can coatings are BPA-free. Verify any remaining stock of epoxy (BPA-based) coatings will be used or replaced before 20 Jan 2025 [3]. Update DoC templates to list all bisphenols or alternatives. Reach out to testing labs for any final migration tests or notifications under the new BPA rules.
– CBAM Registration & Data Setup: If your company imports metal, register as a CBAM declarant with customs in advance of Jan 2026. Set up data collection for Scope 3 emissions of your metal inputs (consult suppliers for emission factors). Ensure accounting software can track relevant imports and GHG data monthly.
– PPWR Design Review – Part 1: Audit current packaging lineup. For each can design, check material composition, weight, and volume. Identify opportunities to remove unnecessary flanges, layers, or non-metal attachments (the regulation forbids packaging that “increases perceived volume”)[10]. Plan trials of lighter-gauge cans or alternative closures.
– Supplier Engagement: Inform all key material suppliers (steel mills, can-makers, lacquers) about PPWR/CBAM/BPA deadlines. Request their compliance plans. Include clauses in supplier contracts requiring notification of any regulatory changes. Begin discussions with recycling partners and EPR organizations (some national programs require data updates by Q1 2026).
– Training and Monitoring Setup: Educate procurement, R&D and quality teams on upcoming requirements. Define internal responsibilities for each regulation (e.g. designate a PPWR compliance officer). Implement a tracking spreadsheet or software to record deadlines, submitted data and communications.

Q2 2026: Intensifying Compliance Activities
– Finalize Packaging Redesigns: Based on audits, implement changes to meet PPWR sustainability rules. This may involve testing new 금 lacquer materials or can geometries. Confirm any proposed reusable packaging pilots (if relevant) comply with safety and hygiene standards.
– Update Labels and Documentation: Prepare new packaging labels with required information (e.g. recycling symbols, material ID) as per PPWR urnuss. Check embargoes: from 12 Aug 2026 all packaging on EU market must meet PPWR label rules. Also ensure new DoC forms and material declarations are ready under the BPA regulation c List any monomers used in coatings [2].
– CBAM Reporting: If operating under the CBAM transitional phase (reporting only) in 2025, finalize any outstanding monthly reports. For Q2 2026, prepare to start buying CBAM certificates. Hold importer invoices until CBAM requirements are clear, then procure certificates as needed. Evaluate how CBAM costs will affect product pricing.
– Quality Assurance: Conduct initial recyclability tests if doing major redesigns. Work with recycling partners to simulate sorting and processing of redesigned cans (especially if adding polymers or adhesives). Document compliance with “no harmful substance” rules – send samples for lab analysis if in doubt.
– Recycled Content Sourcing: Firm up contracts for supplying recycled steel/aluminium. If not already using scrap alloy, increase blended content (premium scrap has lower embodied carbon too). Align with 2021 EU Roadmap to 100% recycled beverage cans (launched by industry) [12] – it may boost requirements on suppliers by 2026.
– Carbon Strategy: Decide on strategy to handle CBAM costs. Options: absorb in margin, surcharge to customers, or invest in low-carbon metal (e.g. sourcing from producers using scrap more). Factor these costs into budgeting cycles.

Q3 2026: Final Compliance Push
– PPWR Go-Live (12 Aug 2026): By mid-August, ensure all packaging designs, labels and documentation fully comply or transition out of EU. Products not meeting PPWR standards should be phased out. Complete any regulatory filings (some Member States may require product notifications). Verify EPR scheme participation is paid up and data reports owe (annual contributions).
– CBAM Payments: Now that 2026 is underway, importers must settle CBAM dues. Finalize the first CBAM returns and certificates purchase for Q1 (Jan–Mar 2026) emissions. This must be done by October 2026. Maintain records of emissions factors and import volumes; reconcile with customs guidance.
– Post-Launch Audits: Perform spot audits of packaging across SKUs to confirm compliance. Check packaging in warehouses and distribution to avoid accidentally shipping non-compliant stock. Communicate with logistics partners to halt any non-PPWR-labeled items from EU distribution.
– Regulatory Updates: Monitor any EU guidance clarifications on PPWR (especially on recyclability grades to come in 2030) and on CBAM (1 Oct 2025 likely saw some adjustments). Ensure changes are incorporated into policies. Brief executives/national sales teams on any sustained impacts (e.g. pricing changes).

Q4 2026: Review and Adjust
– Compliance Review: Review compliance records for 2026. Did we meet all PPWR design, labeling and EPR obligations by Aug? Did CBAM reporting/payments occur on schedule? Document any instances of non-compliance or near-misses to improve 2027 processes.
– Optimize for 2027+: Based on Q4 review, adjust sourcing or production. For example, if CBAM costs were higher than expected, consider re-negotiating supplier terms or increasing recycled content further. If PPWR labeling was confusing, update designs early for 2027 batches.
– Distributor and Customer Communication: Show customers and regulators that you have complied. Issue updated compliance statements or DoCs as needed. Leverage sustainability achievements (e.g. high recycling rate of steel/alu) as part of marketing or CSR reports.
– Preparation for Future Targets: Start planning for upcoming pan-European targets: PPWR requires reporting on recycled content and reuse by 2030, so consider piloting reuse (e.g. refillable steel/canister systems) if relevant. Stay aware of any 2029/2030 interim PPWR deadlines (like broader reuse obligations)[11].

Key Takeaways

• PPWR (EU 2025/40) applies from 12 August 2026 [8]. All can packaging must be recyclable-by-design, minimize harmful constituents, and meet new labelling/EPR rules [7] [6]. Start redesigning cans now for PPWR compliance.
• CBAM (EU 2023/956) introduces carbon costs on imported steel/aluminium from Jan 2026 [5] [4]. Set up carbon accounting with suppliers and budget for CBAM certificates in 2026 budgets.
• BPA Restrictions (EU 2024/3190) took effect 20 Jan 2025 [3]. Ensure any epoxy can liners are BPA-free and document all bisphenols used. Use the required Declaration of Compliance form listing monomers [2].
• Supplier & Material Evaluation: Choose packaging suppliers with strong compliance credentials, high recycled-content materials, and transparent reporting. Consider long-term contracts to lock in low-carbon, recycled sources given scrap shortages [1] and rising prices.
• Quarterly Checklist: Break down compliance work by quarter (as above) to stay on track. Early actions (redesigns, registrations) in 2025–Q1 2026 are critical. Use tables and documentation to track tasks.
• Call to Action: We recommend engaging experts now to audit your packaging and supply chain. Start a pilot project or request a full evaluation of your packaging portfolio to ensure you meet PPWR, CBAM and BPA requirements on time.

Implementing these steps will position your business ahead of the curve. Request a proposal or initiate a compliance pilot today to navigate PPWR 2026 and related EU rules seamlessly.

References

[1] Aluminium Scrap Exports: EU’s New Regulations Coming – Fastmarkets – https://www.fastmarkets.com/insights/eu-moves-to-restrict-aluminium-scrap-exports/#:~:text=Trade%20Commissioner%20Maro%C5%A1%20%C5%A0ef%C4%8Dovi%C4%8D%20confirmed,%E2%80%9D
[2] EU Regulates BPA and other Bisphenols in Certain Food Contact Materials | SGS Austria – https://www.sgs.com/en-at/news/2025/01/safeguards-00525-eu-regulates-bpa-and-other-bisphenols-in-certain-food-contact-materials#:~:text=Article%208%20%E2%80%98Declaration%20of%20compliance,and%20supporting%20documentation%E2%80%99
[3] EU Regulates BPA and other Bisphenols in Certain Food Contact Materials | SGS Austria – https://www.sgs.com/en-at/news/2025/01/safeguards-00525-eu-regulates-bpa-and-other-bisphenols-in-certain-food-contact-materials#:~:text=The%20European%20Union%20,force%20on%20January%2020%2C%202025
[4] EU CBAM set for 2026, industry seeks clarity-Yieh Corp Steel News – https://www.yieh.com/en/News/eu-cbam-set-for-2026-industry-seeks-clarity/156534#:~:text=CBAM%20aims%20to%20prevent%20carbon,sectors%2C%20including%20steel%20and%20aluminum
[5] Press corner | European Commission – https://taxation-customs.ec.europa.eu/news/commission-strengthens-carbon-border-adjustment-mechanism-2025-12-17_en#:~:text=The%20EU%27s%20Carbon%20Border%20Adjustment,aluminium%2C%20cement%2C%20electricity%2C%20and%20steel
[6] eur-lex.europa.eu – https://eur-lex.europa.eu/summary/EN/LEGISSUM%3A4806724?celex=OJ%3AL_202500040#:~:text=Obligations
[7] eur-lex.europa.eu – https://eur-lex.europa.eu/summary/EN/LEGISSUM%3A4806724?celex=OJ%3AL_202500040#:~:text=,obligations%20on%20recyclability%20from%202038
[8] eur-lex.europa.eu – https://eur-lex.europa.eu/eli/reg/2025/40/oj#:~:text=This%20Regulation%20shall%20enter%20into,Journal%20of%20the%20European%20Union
[9] EU Regulates BPA and other Bisphenols in Certain Food Contact Materials | SGS Austria – https://www.sgs.com/en-at/news/2025/01/safeguards-00525-eu-regulates-bpa-and-other-bisphenols-in-certain-food-contact-materials#:~:text=,for%20specific%20applications%E2%80%99
[10] eur-lex.europa.eu – https://eur-lex.europa.eu/summary/EN/LEGISSUM%3A4806724?celex=OJ%3AL_202500040#:~:text=,refilling%20without%20compromising%20product%20quality
[11] eur-lex.europa.eu – https://eur-lex.europa.eu/summary/EN/LEGISSUM%3A4806724?celex=OJ%3AL_202500040#:~:text=2035.%20,obligations%20on%20recyclability%20from%202038
[12] Press Release: Record Number of Used Aluminium Beverage Cans Recycled as Industry Drives Toward 100% Circularity by 2050 – European Aluminium – https://european-aluminium.eu/news_events/press-release-record-number-of-used-aluminium-beverage-cans-recycled-as-industry-drives-toward-100-circularity-by-2050/#:~:text=European%20Aluminium%20and%20Metal%20Packaging,circularity%20by%202050
[13] Aluminium Scrap Exports: EU’s New Regulations Coming – Fastmarkets – https://www.fastmarkets.com/insights/eu-moves-to-restrict-aluminium-scrap-exports/#:~:text=How%20much%20aluminium%20scrap%20does,the%20EU%20currently%20export
[14] Aluminium Scrap Exports: EU’s New Regulations Coming – Fastmarkets – https://www.fastmarkets.com/insights/eu-moves-to-restrict-aluminium-scrap-exports/#:~:text=,weak%20demand%20and%20job%20risks
[15] Europe Metal Packaging Market Size & Growth to 2030 – https://www.mordorintelligence.com/market-analysis/metal-packaging/europe#:~:text=The%20recyclability%20benefit%20offered%20by,and%20steel%20packaging%20around%2083
[16] Steel packaging achieves highest EU recycling rate on record – https://www.packagingnews.co.uk/news/materials/metal/steel-packaging-achieves-highest-eu-recycling-rate-on-record-09-06-2025#:~:text=Independently%20verified%20and%20calculated%20using,rather%20than%20just%20being%20collected
[17] Global Metal Packaging Market Expands at 3.4% CAGR, Fueled – https://www.globenewswire.com/news-release/2025/02/27/3033969/0/en/Global-Metal-Packaging-Market-Expands-at-3-4-CAGR-Fueled-by-Demand-for-Durable-and-Recyclable-Solutions-Future-Market-Insights-Inc.html#:~:text=,share%20by%202035
[18] Consumers choose metal packaging to support sustainability and cost-of-living – The Metal Packager – https://metalpackager.com/2022/10/consumers-choose-metal-packaging-to-support-sustainability-and-cost-of-living/#:~:text=living%20,latest%20information%20on%20consumer%20priorities
[19] Europe Metal Packaging Market Size & Growth to 2030 – https://www.mordorintelligence.com/market-analysis/metal-packaging/europe#:~:text=The%20Europe%20Metal%20Packaging%20Market,15%20Billion%20by%202030
[20] EU Regulates BPA and other Bisphenols in Certain Food Contact Materials | SGS Austria – https://www.sgs.com/en-at/news/2025/01/safeguards-00525-eu-regulates-bpa-and-other-bisphenols-in-certain-food-contact-materials#:~:text=%E2%80%98Prohibition%20of%20the%20use%20of,BPA%E2%80%99
[21] EU Regulates BPA and other Bisphenols in Certain Food Contact Materials | SGS Austria – https://www.sgs.com/en-at/news/2025/01/safeguards-00525-eu-regulates-bpa-and-other-bisphenols-in-certain-food-contact-materials#:~:text=,Varnishes%20and%20coatings
[22] eur-lex.europa.eu – https://eur-lex.europa.eu/summary/EN/LEGISSUM%3A4806724?celex=OJ%3AL_202500040#:~:text=,meaning%20that%20it%20must%20be
[23] EU Regulates BPA and other Bisphenols in Certain Food Contact Materials | SGS Austria – https://www.sgs.com/en-at/news/2025/01/safeguards-00525-eu-regulates-bpa-and-other-bisphenols-in-certain-food-contact-materials#:~:text=%E2%80%98Prohibition%20on%20the%20presence%20of,in%20their%20manufacture%E2%80%99
[24] Press corner | European Commission – https://taxation-customs.ec.europa.eu/news/commission-strengthens-carbon-border-adjustment-mechanism-2025-12-17_en#:~:text=To%20combat%20this%2C%20the%20Commission,are%20reduced%20rather%20than%20relocated