When packaging compliance comes up, the conversation usually starts with the fine. It is concrete, it has a number, and it makes a good headline. Since the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) started to apply on 12 August 2026, that number gets quoted more than ever.
The fine is real, and nobody should ignore it. But for most food manufacturers, it is rarely the biggest cost of a packaging non-conformity (NC). The larger costs are quieter: rework on the line, shipments on hold, retailer complaints, delisting risk and a lower score at the next audit.
The recall data tells a different story. In the UK, the US and Australia, a label or pack that does not match what is inside is one of the most common reasons food is taken off the shelf at all. Those recalls rarely start with a fine. They start with a customer complaint, a held pallet or a fault at a packaging supplier.
This article walks through each of those costs, explains why they are so easy to underestimate, and shows what changes when you catch packaging gaps early instead of at the audit.
Key takeaways
- The fine is rarely the biggest cost. Rework, blocked shipments, retailer complaints, delisting risk and a lower audit score usually cost a food manufacturer more than the penalty itself.
- Packaging and labelling errors are a leading cause of food recalls. In FDA data, labelling errors caused 71% of major food allergen recalls with a known root cause. In Australia, packaging errors were the top root cause of undeclared allergen recalls.
- There is no single EU-wide PPWR fine. Each member state sets its own penalties, and many PPWR obligations phase in after 12 August 2026.
- The real cost is easy to underestimate. It lands in different teams, budgets and weeks, so nobody adds it up.
- The earlier you find a gap, the cheaper it is. Found in a document review, it costs an update. Found by an auditor, it costs a score. Found by a consumer, it can cost a recall.
What is a packaging non-conformity?
A packaging non-conformity (NC) is any gap between what your packaging should be and what it actually is, or between what it is and what you can prove. In food manufacturing, it rarely looks dramatic. Typical examples:
- A label that does not match the approved specification: a missing allergen, an outdated ingredient list, the wrong date code or lot format.
- Packaging material from a supplier without a current food-contact declaration of compliance on file.
- A changed film, tray or closure that went into production before the specification and risk assessment were updated.
- Packaging-related foreign body risks, such as brittle plastics or loose components, without a documented control.
- Missing or incomplete evidence for packaging obligations under the PPWR that already apply to your products.
Some of these are product safety issues. Others are documentation gaps. Both count. An auditor raises an NC when the evidence is missing, even if the packaging itself is fine.
Regulators see the same mix. In 2024, the EU’s Alert and Cooperation Network received 257 notifications about food contact materials. Half concerned chemicals migrating from the material into food, such as primary aromatic amines, phthalates and formaldehyde. The documentation cases included missing declarations of compliance (European Commission, ACN annual report 2024).
How common are packaging non-conformities?
Common enough to be one of the main reasons food is recalled. A label or pack that does not match the product is the most direct way a packaging gap reaches the consumer, and recall data from three regulators shows how often it happens.
United Kingdom. Allergens caused 57.6% of the 1,036 food recalls issued by the Food Standards Agency and Food Standards Scotland between 2016 and 2021. The most common reason, at 40.0%, was a priority allergen missing from the ingredient list (Yue et al., Food Control, 2023).
Australia. Undeclared allergens were the most common reason for a food recall every year from 2017 to 2022, at 38% to 50% of all recalls. When the regulator traced the root causes, packaging errors came first, at 48%, such as product packed in the wrong packaging or an incorrect ingredient list (FSANZ recall statistics).
United States. An FDA analysis of 1,415 major food allergen recalls between fiscal years 2013 and 2019 found that labelling-associated errors caused 71.1% of those with a known root cause, 914 of 1,286 (Sharma, Ma and Luccioli, Journal of Food Protection, 2023).
The pattern has not faded. We analysed the FDA’s public recall database for 2021 to 2025: of 2,402 food recall events, 37% named an undeclared allergen in the reason for recall, and 42% of those were Class I, the FDA’s most serious category, where the product could cause serious harm (openFDA; method in the sources below).
A label that does not match the pack is not a paperwork detail. It is one of the most common ways food safety fails in practice, and many of these recalls started as a packaging or labelling gap that nobody caught in time.
How much is the PPWR fine?
There is no single EU-wide figure. The PPWR applies from 12 August 2026, but many of its obligations phase in over the coming years, and each member state sets its own penalties. So the honest answer to "what is the fine?" depends on which obligation, which country and which date. That uncertainty is one more reason not to build your packaging risk picture around the fine alone.
The five hidden costs of a packaging non-conformity
The fine is one line on the bill. Here is what usually sits around it.
1. Rework on the line
When a packaging issue is found after production, the product does not disappear. It has to be relabelled, over-stickered, repacked or written off. That means stopped lines, extra labour hours, wasted packaging material and sometimes wasted product. It also means planning disruption: the slot used for rework is a slot not used for the next order.
2. Blocked shipments
Product with an open packaging question is typically put on hold until someone can confirm it is compliant. Stock sits in the warehouse, delivery windows are missed, and customer service spends its time explaining delays. If the issue is found after dispatch, the cost grows: returns, withdrawals and, in the worst case, a recall.
A case from the European Commission’s 2024 report shows how far one packaging fault can travel. In November 2024, a German food company found small copper strands in a batch of 10 kg packing buckets during its own inspections. The buckets held six batches of mayonnaise. The company started a recall straight away, but the product had already reached markets in six member states (European Commission, ACN annual report 2024).
The cause turned out to be the buckets themselves. In their production, an earth cable had become brittle from constant movement and bending, and strands fell into the buckets during automatic stacking. Other manufacturers using the same buckets reported the same contamination. At 0.16 mm across, the wires were too thin for metal detectors to find. The food company’s own controls could not see the problem. Only controls at the packaging supplier could.
3. Retailer complaints
Retailers and brand owners notice packaging errors quickly, and each complaint needs a response. That usually means a root cause analysis, a corrective action plan and evidence that the fix works. The QA team carries this work on top of its normal workload, and the commercial team carries the conversation.
Retailers react quickly, but they are rarely the first to find the problem. In FSANZ’s data, a customer complaint was the most common way an undeclared allergen recall began, in 102 of 232 recalls between 2017 and 2022. Complaints from distributors or retailers started only 8 (FSANZ recall statistics).
4. Delisting risk
One complaint rarely ends a listing. A pattern of complaints, or a slow and unconvincing response, can. Retailers track supplier performance, and repeated packaging issues weaken your position in every future negotiation. This cost never appears on an invoice, but it can be the largest one on the list.
5. A lower audit score
Packaging and labelling are core topics in GFSI-benchmarked standards such as BRCGS, IFS Food and FSSC 22000. A packaging NC affects your audit outcome directly, and the effect lasts. Depending on the standard and the severity, a lower grade or score can mean an earlier re-audit, more scrutiny from customers who review your certificate, and a harder conversation at the next tender. The certificate travels further than the fine does.
Why is the true cost so easy to underestimate?
The fine is easy to see because it arrives as one invoice, handled by one team, in one week, and then it is done. The other costs work differently.
| What gets quoted | What actually happens |
|---|---|
| The fine | Rework, blocked shipments, complaints, delisting risk and a lower audit score |
| One invoice | Costs spread across labour, logistics, customer service and commercial |
| One team | Production, QA, logistics, sales and procurement each carry a part |
| One week | Effects run until the next audit and beyond |
| Done | The NC stays open until the root cause is fixed and verified |
Each team sees its own piece, in its own spreadsheet, at its own time. Production logs the rework hours. Logistics tracks the held pallets. Sales handles the retailer. QA prepares the corrective action and the audit evidence. Nobody adds it up, so the organisation remembers the fine and forgets the rest.
That is also why the same packaging issue can return. When the cost is fragmented, so is the learning. The CAPA gets closed in one place while the cause sits untouched in another.
How to catch packaging gaps before they become a bill
Every cost above grows with time. A gap found during a document review costs an update and a signature. The same gap found on the line costs rework. Found by a retailer, it costs a complaint. Found by an auditor, it costs a score. The cheapest moment to fix a packaging NC is before it is one.
The root-cause data points to the same moment. In FSANZ’s analysis, packaging errors (48%) and supplier verification issues (22%) together explain 70% of undeclared allergen recalls. Both are gaps a document review is designed to catch: a label checked against the approved specification, and a supplier specification checked for allergens before the ingredient is used.
In practice, catching gaps early comes down to a few habits:
- Keep packaging specifications and supplier declarations in one place, with expiry dates that someone actually sees before they lapse.
- Link every packaging change to a review. A new film or label layout should trigger an updated specification and risk assessment before first production.
- Treat each NC as a cost chain, not a single event. Record the rework, holds and complaints against the same root cause, so the full impact is visible.
- Close CAPAs with evidence, not just a status change. Verify that the fix holds, so the issue does not return at the next audit.
- Review continuously, not three weeks before the audit. Audit readiness is a state you maintain, not a sprint you run.
For a week-by-week plan to close packaging documentation gaps, see our six-week packaging documentation checklist.
Frequently asked questions
What is a packaging non-conformity in food manufacturing?
A packaging non-conformity is a gap between what your packaging should be and what it actually is, or between what it is and what you can prove. Common examples are a label that does not match the approved specification, a packaging material without a current food-contact declaration of compliance, and a packaging change made before the specification and risk assessment were updated.
How often do labelling and packaging errors cause food recalls?
Often. Undeclared allergens are among the most common reasons for food recalls in the UK, the US and Australia, and most trace back to a label or packaging error. In FDA data for fiscal years 2013 to 2019, labelling-associated errors caused 71.1% of major food allergen recalls with a known root cause. In Australia, packaging errors were the top root cause of undeclared allergen recalls from 2017 to 2022, at 48%.
What are the penalties for not complying with the PPWR?
The PPWR does not set one EU-wide fine. Each member state sets its own penalties, which must be effective, proportionate and dissuasive. The amount depends on the obligation, the country and the date that obligation starts to apply.
Does a packaging non-conformity affect a BRCGS or IFS audit?
Yes. Packaging and labelling are core topics in BRCGS, IFS Food and FSSC 22000. A packaging non-conformity can lower your BRCGS grade or IFS Food score and, depending on the standard and severity, lead to an earlier re-audit and closer scrutiny from customers.
How can food manufacturers reduce the cost of packaging non-conformities?
Find gaps before an auditor, retailer or consumer does. Keep packaging specifications and supplier declarations in one place with visible expiry dates, review every packaging change before first production, record all costs of a non-conformity against one root cause, and close CAPAs with verified evidence.
How AuditQ helps
AuditQ is a shared compliance workspace for food safety teams. QA managers and auditors track evidence, risk and CAPAs together, across standards such as BRCGS, IFS Food, FSSC 22000 and GMP+. Packaging specifications, supplier documents and corrective actions sit in one place instead of scattered spreadsheets and email threads. Gaps become visible while they are still cheap to fix.
The fine will keep getting quoted. The rest of the bill is the part you can actually control.
Want to see where your packaging gaps are today? Get a free compliance check.
Sources
- European Parliament and Council. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). Official Journal of the European Union, 2025.
- European Commission, DG Health and Food Safety. Alert and Cooperation Network: 2024 Annual Report. Publications Office of the European Union, 2025.
- Food Standards Australia New Zealand. Undeclared allergen recall statistics, 2017–2022.
- Sharma, G. M., Ma, Y. and Luccioli, S. Recalls Associated with Food Allergens and Gluten in FDA-Regulated Foods from Fiscal Years 2013 to 2019. Journal of Food Protection, 86(4), 100069, 2023.
- Yue, S. R., Shrivastava, R., Campbell, K. and Walker, M. J. Food allergen recalls in the United Kingdom: a critical analysis of reported recalls from 2016 to 2021. Food Control, 144, 109375, 2023.
- U.S. Food and Drug Administration. openFDA food enforcement reports, accessed 7 October 2026.
About our FDA analysis: we downloaded every food recall record in the openFDA food enforcement database with a report date from 1 January 2021 to 31 December 2025 (8,014 product records), grouped them into 2,402 recall events by event ID, and counted the events whose stated reason for recall names an undeclared major food allergen. The classification is based on keywords in the reason text, so treat the figures as close estimates rather than exact counts.
