ECHA Seeks Stakeholder Feedback on Draft List of 700 Candidate Substances of Concern (SoCs) under PPWR; Comments Due August 24, 2026

Companies that manufacture packaging or packaging materials for the European Union market should take note of an important and time-sensitive opportunity to engage with regulators. The European Chemicals Agency (ECHA) is currently soliciting stakeholder feedback on a draft list of approximately 700 candidate substances of concern (SoCs) in packaging under the EU Packaging and Packaging Waste Regulation (PPWR). Comments on the draft SoC list are due to ECHA by August 24, 2026.

Background: PPWR Substance of Concern Requirements

The PPWR (Regulation (EU) 2025/40) entered into force on February 11, 2025, and will generally apply across the EU beginning August 12, 2026. Notably, Article 5 of the PPWR requires that packaging be manufactured so that the presence and concentration of so-called substances of concern (SoCs), as defined in Article 2(27) of the Eco-design for Sustainable Products Regulation (Regulation (EU) 2024/1781), are minimized. Except for certain heavy metals and per- and polyfluoroalkyl substances (PFAS), no defined list of SoCs presently exists for the purpose of complying with the PPWR. Under Article 5(2) of the PPWR, the European Commission and ECHA are required, by December 31, 2026, to publish a report on substances of concern in packaging and packaging components, which may indicate whether such substances could (1) impact chemical safety or (2) negatively affect the re-use or recycling of packaging materials. The drawing up of this list is also significant for labelling purposes as substances of concern in packaging placed on the EU market will also have to be identified digitally on packaging labels in the future.

ECHA Circulates Draft List of Candidate SoCs

On July 16, 2026, ECHA’s PPWR Team sent a letter to various packaging stakeholders that had previously provided feedback to ECHA on the PPWR Call for Evidence on SoCs or otherwise expressed interest in ECHA’s PPWR activities. The letter invites stakeholder feedback on a draft list of approximately 700 candidate SoCs in packaging and/or packaging waste.  

The list of 700 candidate SoCs is a subset of a much larger list of approximately 6,000 substances that ECHA had initially developed based on a range of sources, including REACH registration data, regulatory lists, substance lists from relevant projects and industry, scientific literature, and reports from non-governmental organizations (NGOs). ECHA compared the 6,000-substance list against packaging substance information provided by stakeholders and other sources (online and literature) and reduced the list to 2,500 substances. The shorter list of 700 candidate SoCs followed screening and validation of the 2,500 substances against the dual SoC criteria (i.e., potential chemical safety risk or potential to negatively impact the re-use or recycling of packaging materials).

ECHA’s letter to stakeholders notes that the identification of a substance as an SoC or its presence on the preliminary candidate list for REACH restrictions does not automatically lead to regulatory obligations. However, the current exercise may lead to a more thorough assessment of hazard, exposure, emission, and risk, potentially prompting future regulatory action or substance restrictions under the PPWR framework.

What Information Is ECHA Requesting?

At this time, ECHA is not seeking input on whether these substances are expected to present a chemical safety risk or have the potential to negatively affect recycling. Rather, ECHA is merely seeking information to validate a substance’s use or presence in packaging, its intended technical purpose, and the likely packaging format in which the substance may be found. Specifically, ECHA’s letter to stakeholders requests the following:

• Whether the substance is currently used in packaging applications;
• Whether the substance is intentionally added (IAS) or present unintentionally (NIAS);
• The packaging material, type, or format in which the substance is used; and
• The substance’s technical function.

Key Takeaways

As mentioned above, ECHA’s findings will serve as a basis for the preparation of the EC’s report that will be transmitted to the European Parliament and Council of the EU, which could lead to future legislative measures. Companies should thus evaluate whether substances relevant to their products, materials, or supply chains appear on the candidate list and consider providing feedback to ECHA. Submissions may be sent directly to ECHA’s PPWR team at restriction-PPWR@echa.europa.eu by August 24, 2026.  

If you have any questions or need assistance, please contact Rachida Semail (semail@khlaw.com) or Hazel O’Keeffe (okeeffe@khlaw.com), or your existing contact at Keller and Heckman LLP.

We will continue to monitor PPWR developments and their potential impacts. For further analysis of the PPWR, please refer to the following article, EU’s Packaging and Packaging Waste Regulation: Impact on American Companies | PackagingLaw.com.