PPWR & Metal Packaging Printers and Can Makers: Aluminium, Tinplate, Internal Lacquers, BPA-NI and Lithographic Print
PPWR & Metal Packaging Printers and Can Makers: Aluminium, Tinplate, Internal Lacquers, BPA-NI and Lithographic Print
Two-piece aluminium beverage cans, three-piece steel food cans, aerosol containers, closures, promotional tins and tinplate-lithographed general-line packaging sit inside a filière that — on paper — already complies with most of Regulation (EU) 2025/40. Metal is a permanent material, recycled at 78.5% (steel) and 76% (aluminium) across Europe, and already lands in Annex II grade A for most constructions. Yet the August 12, 2026 deadline still bites hard on can makers, tinplate printers and two-piece aluminium body-makers — because the problem is almost never the metal. It is the decoration, the internal lacquer, the external varnish, the closure compound and the promotional overprint, plus the Article 39 Declaration of Conformity that has to be issued for every SKU.
Articles 5 (restricted substances), 6 (recyclability grading), 7 (recycled content), 10 (minimisation), 12 (Digital Product Passport), 29/30 (reuse and refill), and 39 (DoC) all land on the metal decorator-converter stack. This is the can maker and tinplate printer's playbook for the four months left before the core deadline.
Why Metal Still Needs a Full PPWR Dossier
Metal packaging is fully in-scope for PPWR. Every two-piece aluminium can, three-piece tinplate can, twist-off lug cap, crown cork, aerosol and cosmetic tin needs an Annex II recyclability grade and a signed Declaration of Conformity like any plastic or fibre pack. The grading mechanics are favourable — metal separates cleanly in magnetic and eddy-current sorting, survives pyrolysis and smelting and re-enters primary production without loss. What the regulation cares about is the full material declaration: coat weights, lacquer chemistry, pigments, heavy-metal residuals, closure compounds and recycled-content documentation under mass balance.
EN 13430 and the APEAL / Metal Packaging Europe recyclability-by-design protocols give the methodology. The operator-side obstacle is evidence. A tinplate lithographer that has been printing general-line packaging for decades with the same ink house rarely holds a full digital material declaration in a format a Declaration of Conformity tool can consume.
The Metal Converter Obligation Stack
| Obligation | PPWR Article | Deadline | What the Can Maker / Tinplate Printer Must Do |
|---|---|---|---|
| Heavy-metal limit (Pb + Hg + Cd + Cr(VI) < 100 mg/kg) | Article 5 & Annex V | In force (Jan 1, 2026) | Purge cadmium-pigmented oranges/reds, lead-chromate yellows, mercury biocides; request Annex V compliance letters from every ink and varnish supplier |
| BPA ban in food-contact internal lacquers | Reg (EU) 2024/3190 (convergent with PPWR Article 5) | January 20, 2026 manufacture / July 20, 2026 place-on-market | Migrate three-piece food cans and two-piece beverage ends to BPA-NI (polyester, acrylic, oleoresin, non-epoxy) interior coatings; archive food-contact supplier declarations |
| PFAS ban in food-contact packaging | Article 5 & Annex V | August 12, 2026 | Eliminate fluorinated slip agents in exterior varnishes, PFAS-based release coatings on DWI can-bodymaker tooling transfer, fluoro-surfactant levelling aids in coil coatings |
| Recyclability grade A–E per construction | Article 6 & Annex II | August 12, 2026 | Validate each two-piece can, three-piece can, aerosol and closure reference against EN 13430 and the MPE/APEAL design protocols; D/E banned from January 1, 2030 |
| Recycled content in aluminium & steel | Article 7 | January 1, 2030 / 2040 | Document post-consumer recycled (PCR) content per unit — typical UBC-to-rolling-mill loops for aluminium, BOF/EAF steel share for tinplate; mass-balance certificate per coil |
| Minimisation (volume & weight) | Article 10 & Annex IV | August 12, 2026 | Document can-wall thickness reduction, end-diameter standardisation (202, 206), light-weighting rationale; remove ullage, double-seam and flange over-engineering |
| Declaration of Conformity per packaging unit | Article 39 & Annex VIII | August 12, 2026 | Issue DoC per SKU with substrate, temper, coat weight, lacquer chemistry, printing inks, varnish, closure compound, end compound, recycled-content evidence |
| Harmonised material code & sorting pictogram | Article 12 | August 12, 2028 | Apply harmonised codes (ALU for aluminium, FE for ferrous), sorting pictogram and Digital Product Passport QR per Commission Implementing Regulation |
| Beverage reuse targets | Articles 29 & 30 | January 1, 2030 / 2040 | Refillable-glass growth displaces some aluminium share in HORECA; MPE challenge is showing net-circularity parity via deposit-return system (DRS) and UBC closed loops |
Internal Lacquers: The BPA-NI Migration That Is Now Table Stakes
Commission Regulation (EU) 2024/3190, adopted December 2024, bans bisphenol A and its salts in food-contact materials, with the critical date of January 20, 2026 for manufacture and July 20, 2026 for placing on the market. This is not PPWR itself, but it converges directly with Article 5 of Regulation (EU) 2025/40 — intentionally-added substances of concern are in scope. For a can maker, this means every legacy BPA-based epoxy-phenolic interior coating, used across most food-can and beverage-end constructions for the last fifty years, has to be replaced. Validated alternative chemistries include:
- Polyester / acrylic-polyester interior coatings — the workhorse for beverage ends and two-piece aluminium bodies
- Oleoresin (natural resin) coatings for certain food cans and pet-food cans
- Non-BPA epoxy (BPA-NI) bisphenol-alternative epoxy chemistries — typically polyester-epoxy hybrids with BPA-free crosslinkers
- Non-epoxy thermoset coatings qualified under the EuPIA food-contact framework
Switching coatings is not a drop-in exercise. It alters the curing profile on the interior coater oven, the flavour-shelf performance for carbonated soft drinks and beer, the corrosion behaviour of acidic foods like tomato, the scuff resistance on the bodymaker and even the can-end flexibility under retort. Every SKU has to be re-qualified for shelf-life, and every supplier declaration has to be archived in the DoC file for the converter.
External Decoration: What Drags a Grade A Metal Pack Down
Metal on its own is a near-automatic grade A under Annex II. The decoration stack can still push a construction into grade B, C or — rarely, but possibly — lower, especially for two-piece cosmetic tins, promotional novelty cans or heavily shrink-sleeved aluminium bottles. The operator-side grade-killers are:
| Component | Grade Impact | What the Converter Must Do |
|---|---|---|
| Full-body PVC or PET-G shrink sleeves on aluminium bottles/cans | Non-metallic weight >5% can disqualify from the aluminium stream; PVC specifically fails RecyClass and MPE protocols | Migrate to direct-print decoration (digital inkjet can print — Ball, Tonejet, Koenig & Bauer MetalCan) or to PO-based perforated sleeves with clean tear-off |
| Cold-foil, hot-stamp and metallic effect overprint varnish | Low impact on metal (metal separates in smelting), but Annex V heavy-metal limit applies to the ink film | Document the pigment system; prefer simulated metallic inks over cold-foil where coverage is low |
| UV-curable exterior varnishes with non-cured monomer residues | Food-contact migration risk through the base of two-piece cans; Article 5 and EuPIA guidance | Switch to low-migration LED-UV exterior varnish (hubergroup MGA, INX EvoLED, Siegwerk Sicura Nutriflex) with full migration dossier per EuPIA |
| Over-laquer retort compatibility for food cans | Cracking in retort triggers corrosion, product contamination and end-of-life disputes | Requalify over-laquers after any ink / varnish change; book retort panels per SKU |
| Closure compounds (crown corks, ROPP, aerosol valves) | PVC plastisol compound used in many crown corks — low share but flagged under Article 5 restricted substances trajectory | Migrate to PVC-free thermoplastic compounds; document per closure SKU |
Tinplate Lithography: The Ink and Varnish Dossier
Coil-coated tinplate and aluminium arrive at the general-line plant already primed; the lithographer prints typically 6–8 colours of UV-offset or conventional offset inks plus an over-print varnish and a size-coat. The full PPWR dossier for a single tinplate biscuit-tin SKU has to reconcile the coil-coater's primer spec, the litho plant's ink spec per colour station, the varnish spec and the internal lacquer spec — each with its own heavy-metal declaration, its own PFAS declaration, its own BPA declaration and its own food-contact migration dossier under EuPIA and Regulation (EC) 1935/2004. The commercial signal for decorators: automating this chain of supplier declarations into one structured DoC data export is now a tender criterion on every private-label food programme in the EU.
Recycled Content in Metal: The Mass-Balance Evidence Problem
Article 7 sets recycled-content targets that land in 2030 and 2040. For plastics the targets are explicit and category-specific. For metals the picture is different: aluminium and steel are recycled infinitely without loss, and the European primary-to-secondary ratio already delivers high post-consumer recycled (PCR) share in most coils. But the PPWR dossier still demands evidence. That evidence has to come from the rolling mill or the electric-arc furnace operator as a mass-balance certificate per coil batch, aligned to ISO 22095 chain-of-custody or ResponsibleSteel / ASI (Aluminium Stewardship Initiative) equivalent. Can makers and tinplate printers that can publish a machine-readable recycled-content attribute per SKU — not a PDF certificate for a whole year's tonnage — will pass brand-owner due diligence. Those that cannot will find themselves renegotiating with their rolling mills in 2028 and 2029 under time pressure.
Action Plan for Can Makers, Tinplate Printers and Metal Decorators
- Audit every active SKU against Annex II — segment two-piece, three-piece, aerosols, closures and promotional tins into A/B (safe), C (borderline), D/E (action required before January 2030). Grade C typically reflects a shrink-sleeve, heavy decoration or closure-compound issue, not the metal itself.
- Close out the BPA transition before July 20, 2026 — list every interior lacquer SKU, confirm BPA-NI qualification per food type, archive shelf-life data, require supplier Annex I declarations under Regulation (EU) 2024/3190.
- Eliminate PFAS across the coatings chain — Article 5 plus the August 12, 2026 food-contact deadline covers slip agents, levelling additives and release coatings; pull declarations down to the molecule level.
- Refresh exterior varnish for low-migration compliance — qualify LED-UV low-migration systems and archive EuPIA migration dossiers per colour station.
- Substitute PVC plastisol in crowns and closures — migrate crown corks and twist-off lug compounds to PVC-free thermoplastic compounds.
- Pull mass-balance recycled-content evidence — require ASI, ResponsibleSteel or ISO 22095 chain-of-custody certification per coil delivery.
- Deliver a structured DoC / DPP data export per SKU — substrate, temper, gauge, lacquer chemistry, coat weight, inks, varnish, closure compound, recycled content, pictogram, material code.
How PPWR Connect Helps Metal Packaging Printers and Can Makers
Metal packaging is where PPWR Articles 5, 6, 7, 10, 12 and 39 all converge on a single can, closure or tin — and where the can maker's choice of substrate, temper, internal lacquer, exterior varnish, ink system, closure compound and recycled-content evidence determines whether the SKU lands cleanly in grade A or gets stuck in a C-borderline disputed dossier. PPWR Connect gives metal decorators, three-piece food-can plants, two-piece beverage body-makers, aerosol fillers and tinplate lithographers a single platform to inventory every active construction, run automated Annex II grading on the full substrate + lacquer + ink + varnish + closure stack, intake APEAL / MPE / RecyClass evaluation reports, track BPA-NI and PFAS elimination, manage mass-balance recycled-content certificates per coil, and produce audit-ready Declarations of Conformity per market. Decorators use the same platform to publish machine-readable component specifications back to their brand-owner customers — turning PPWR compliance from a reporting burden into a tender-winning differentiator. With the August 12, 2026 deadline less than four months away and the BPA cut-off even sooner, the can makers and tinplate printers that lock down structured data collection and coatings migration now are the ones that will hold their job book into 2030.