Short Answer: Yes.
Many suppliers use outdated "non-intentional use" statements from 2024/25. As of August 12, 2026, the EU requires specific proof of Total Fluorine thresholds (<50ppm).

The strict PFAS restriction applying from 12 August 2026 under the EU PPWR is focused primarily on food-contact packaging. However, PFAS is increasingly being treated as a “substance of concern” within wider packaging regulation and recyclability frameworks. Continued use of PFAS in packaging materials could negatively affect future recyclability assessments and may lead to higher modulated EPR compliance costs as EU packaging rules tighten..

TrailZero doesn't just take suppliers word for it; we verify that their technical documentation meets the 2026 standard required for your Technical File. If they can't provide it, we help you find a supplier who can.

The Short Answer:
For Food-Contact (PFAS): Likely No.
For Empty Space (Air):Yes, for now.

The 2026 rules use the legal term "Placing on the Market." , meaning the first time a product is made available on the EU market.

1. PFAS in Food Packaging: The European Commission guidance indicates there is no general transitional period after 12 August 2026. In practice, packaging that has not yet been placed on the market before that date may no longer be legally marketable, even if manufactured earlier. Stock remaining in a warehouse is generally not considered “placed on the market” unless it has already entered commercial distribution.

2. Empty Space (The 50% Rule): The specific 50% empty-space cap for grouped, transport, and e-commerce packaging does not become fully applicable until 1 January 2030. This means existing packaging inventory can generally continue to be used before that date. However, broader packaging minimisation obligations apply earlier under the PPWR from August 2026, meaning excessively oversized packaging could still face regulatory scrutiny under general waste prevention and packaging reduction principles
   
   
   TrailZero Advice: Don't get caught with unusable stock. We recommend a pre-August audit of all high-volume food-contact SKUs. If they contain PFAS, you need to clear that inventory before August 12th.

The Short Answer: Yes. Under the PPWR provisions relating to excessive packaging (commonly referenced as Article 21 in industry guidance)

If you import packaged products into Ireland from outside the EU (including from the UK, USA, or China), you are generally considered the “Producer” for packaging compliance purposes. This means you may be responsible for ensuring imported packaging complies with future EU packaging minimisation and empty-space requirements under the PPWR, including the 50% empty-space limit applying to certain packaging formats from 2030. Because many overseas suppliers are not directly focused on EU packaging compliance requirements, importers may need to review packaging specifications more closely.

TrailZero acts as your local verification partner, using photogrammetry scanning to create the compliance data your suppliers failed to provide.

The Short Answer: More than you think.

Under the PPWR, packaging design must comply with general minimisation requirements from August 2026, meaning unnecessary or excessive packaging may be subject to regulatory scrutiny. The specific 50% maximum empty-space limit for grouped, transport and e-commerce packaging is expected to apply from 2030. Void fill materials such as bubble wrap or air cushions are considered part of packaging design and may contribute to the overall assessment of packaging efficiency and empty-space use under future measurement methodologies.

TrailZero’s measurement methodology, including photogrammetry 3D scanning, calculates this true ratio so you can adjust your box size and help avoid any potential penalties. Furthermore, the PFAS restriction is a hard stop in 2026. TrailZero can audit both simultaneously so you only have to fix your supply chain once.

The Short Answer: We provide the "Verified Evidence" that makes your reports credible.

VSME is the standard you use to tell your bank and big customers that your business is "Green." However, a report is only as good as its data.

• For PFAS: We provide technical PFAS compliance assessments and documentation support to help demonstrate alignment with applicable EU packaging restrictions and internal ESG reporting requirements. This helps strengthen the supporting evidence base for your VSME disclosures and reduces the risk of inconsistent sustainability reporting.

• For PPWR: Our packaging efficiency analysis identifies material usage and void space reduction opportunities, providing practical data that can support the environmental section of your VSME sustainability reporting and wider cost and waste reduction initiatives

TrailZero's Value: We take the technical hard math from the PPWR mandates and turn it into the clear metrics you need for your VSME corporate reporting.

Short Answer: Yes
You may not be legally required to publish an ESG report, but if your customers are large companies, they almost certainly are. That means they're asking their suppliers, including you, for ESG data. It's not about regulation. It's about keeping your contracts.

Short Answer: Yes
This is actually the most common situation. We'll gather what you have, document what you don't, and build a data collection process so you're in a much stronger position for future requests. Starting from zero is fine

Short Answer: No.
While food and drink is a strong focus given the ESG pressure from retail buyers, we also work with companies in manufacturing, construction, professional services, and facilities management. If your customers are asking for ESG information, we can help regardless of sector.

A one-off engagement handles a specific, immediate need; completing a questionnaire, producing a report, or building a tender pack.

A retainer is for businesses that receive ESG requests regularly and want those handled on an ongoing basis, maintenance and update of their data, or repeat verification services without per-job cost or effort.

Short Answer: No.

And any consultant who does should be treated with caution. What we guarantee is an accurate, well-evidenced, professionally completed submission that gives you the strongest possible position. The outcome always rests with the buyer or funder.