PPWR and FIBC Big Bags: What the EU Packaging Regulation Means for Bulk Bag Buyers

The EU’s new Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, or PPWR for short — entered into force on 11 February 2025 and has applied directly since 12 August 2026.

Replacing the old Packaging Directive (94/62/EC), the regulation covers almost all packaging placed on the EU market. Big bags (FIBCs), as industrial transport packaging, are within its scope.

This article summarises how the PPWR affects you as a buyer of big bags, which documents you should request from your supplier, and which obligations will follow in the coming years.

1. Are big bags covered by the PPWR?

Yes. The PPWR also covers transport packaging used to carry and protect goods.

Article 29, which sets the reuse targets, lists among the formats it covers pallets, plastic crates and drums as well as intermediate bulk containers (IBCs) and flexible formats. Big bags are flexible IBCs.

2. What has applied since 12 August 2026

Heavy metal limit (Article 5)

The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium in packaging and packaging components must not exceed 100 mg/kg.

This rule applies to all packaging, whatever the material.

PFAS limits for food-contact packaging (Article 5)

Packaging intended to come into contact with food must not contain PFAS (“forever chemicals”) above the following limits:

• 25 ppb for any single PFAS
• 250 ppb for the sum of PFAS measured by targeted analysis
• 50 ppm for total PFAS (including polymeric PFAS)

If you use food-grade big bags, these limits concern you directly.

EU Declaration of Conformity and technical documentation (Articles 38-39)

The packaging manufacturer must carry out a conformity assessment showing that the packaging meets the requirements of Articles 5 to 12 of the PPWR, draw up the technical documentation and issue an EU Declaration of Conformity.

3. If you source big bags from outside the EU

The PPWR separates the roles clearly:

• The manufacturer outside the EU (for example a big bag manufacturer in Turkey) carries out the conformity assessment, draws up the technical documentation, and issues and signs the EU Declaration of Conformity.
• The importer (the company bringing the big bag into the EU, often the buyer itself) must verify before placing the packaging on the market that the manufacturer has completed these steps, keep a copy of the declaration and present it to the market surveillance authorities on request.

The importer does not issue its own declaration, but it does carry the responsibility for verification.

You should therefore request the following from a supplier outside the EU:

• An EU Declaration of Conformity issued under the PPWR
• Test reports for heavy metals (and for PFAS in the case of food-contact products)
• Labelling with a batch or serial number and the manufacturer’s contact details for traceability

At Karaca Ambalaj, we supply the EU Declaration of Conformity issued under the PPWR, the heavy metal test report and, for food-contact products, the PFAS test report with every shipment.

4. What follows in the coming years

Recycled content (Article 7) — from 2030

Mandatory minimum percentages of recycled content are coming for plastic packaging.

For the “other plastic packaging” category, which includes big bags, the target is 35% in 2030 and 65% in 2040. For contact-sensitive plastic packaging made of materials other than PET — such as food-contact packaging — the percentages are lower: 10% in 2030 and 25% in 2040.

The percentages are calculated on recycled plastic recovered from post-consumer waste, as an average per manufacturing plant and year.

Recyclability (Article 6) — from 2030

From 2030, all packaging placed on the market must be designed for recycling.

Big bags made from a single polymer (polypropylene) have an advantage here; however, the material compatibility of components such as liners, coatings and printing will become more important.

Reuse targets (Article 29) — from 2030

For companies using transport packaging such as pallets, plastic crates, drums, IBCs and flexible formats, a 40% reuse target applies from 2030. For transport between sites of the same company group, or between companies within the same EU member state, the target rises to 100%.

The regulation exempts certain packaging from these targets. Two exemptions matter for big bag buyers:

• Packaging used for the transport of dangerous goods (for example UN certified big bags)
• Flexible-format transport packaging in direct contact with food and feed

Big bags carrying food ingredients therefore fall outside the reuse targets, while demand for multi-trip (SF 6:1) big bags is expected to grow for non-food products. We recommend confirming with your compliance adviser which case applies to your own use.

Labelling (Article 12)

Harmonised labels showing the material composition of packaging will become mandatory. This obligation applies from 12 August 2028, or 24 months after the relevant Commission implementing act enters into force, whichever is later.

5. Checklist for purchasing teams

1. Does your big bag supplier provide a PPWR Declaration of Conformity?
2. Is the heavy metal (≤ 100 mg/kg) test report up to date?
3. Has a PFAS test been carried out for food-contact products? Is a declaration of compliance with (EC) 1935/2004 and (EU) 10/2011 available?
4. Does the product label carry a batch or serial number and the manufacturer’s details?
5. Does your supplier have a roadmap for recycled content and multi-trip (SF 6:1) products for the 2030 targets?

6. At Karaca Ambalaj

Karaca Ambalaj has been manufacturing big bags since 1998 in its BRC IoP AA and ISO 9001 certified facility in Turkey, and exports 98% of its production, mostly to Europe.

Our big bags are made of polypropylene fabric and are available as single-trip (SF 5:1) and multi-trip (SF 6:1) versions. For our food-grade products, a declaration of compliance with (EC) 1935/2004 and (EU) 10/2011 is available to our customers.

We supply the PPWR Declaration of Conformity and the heavy metal / PFAS test reports with every shipment.

Contact us about your order and the documents.

Related articles: Choosing Big Bags for Food Manufacturers · Food-Grade FIBC: The EU Declaration of Compliance Explained

This article is for general information only and does not constitute legal advice. The binding text is the current version of Regulation (EU) 2025/40 as published on EUR-Lex.