Just a few days before the PPWR Regulation begins to apply, the European Commission has published updated answers to the most frequently asked questions from practice. The second, significantly expanded edition spans 69 pages and addresses numerous uncertainties faced by manufacturers, importers, distributors, and packaging suppliers.
The new FAQs provide practical guidance on the obligations that will start to apply on 12 August 2026, as well as on requirements that will come into effect in the following years.
What do the new FAQs clarify?
The document covers 20 thematic areas, ranging from definitions and the identification of the responsible economic operator to substances of concern, recyclability, recycled content, packaging minimisation, labelling, reuse, extended producer responsibility, and deposit return systems.
Among the most important practical clarifications are:
- Packaging manufactured before 12 August 2026 does not have to be destroyed or repackaged. If it has not yet been placed on the market, the required identification and contact details may, under specified conditions, be provided in an accompanying document. Packaging placed on the market before that date may remain on the market.
- It is not necessary to mark every individual package with a unique number. For traceability purposes, identification of the packaging type or production batch may be sufficient. For packaging consisting of several components, the information may be provided on only one of those components.
- The packaging supplier must provide the manufacturer with the necessary supporting documentation. Suppliers of packaging and packaging materials may not refuse to provide the information and documentation required to demonstrate compliance with the PPWR. However, the overall legal responsibility remains with the manufacturer or importer.
- The declaration of conformity is assessed for the entire packaging unit. For packaging consisting, for example, of a bottle, cap, and label, a single conformity assessment and a single declaration covering all relevant components are sufficient.
- The obligations also apply to transport packaging. Pallets, films, straps, and other individual types of transport packaging must be assessed separately.
- The declaration of conformity must be available in the language required by the Member State in which the packaging is placed on or made available on the market.
- The new packaging minimisation requirements under Article 10 will apply from 1 January 2030. Until the end of 2029, the essential requirements of the original Packaging and Packaging Waste Directive will continue to apply.
Enforcement should not immediately disrupt trade
A completely new section of the FAQs deals with the enforcement of the rules immediately after 12 August 2026. The European Commission states that enforcement of the new obligations should not disrupt trade flows, supply chains, or the availability of products.
If a competent authority identifies non-compliance, the economic operator should first receive a request and be given an appropriate opportunity to take corrective action. A prohibition, withdrawal, or recall of packaging should only be considered if the identified non-compliance persists.
However, this does not mean that the obligations are postponed. Manufacturers, importers, and other affected economic operators must be able to demonstrate that they are addressing the new requirements, collecting the necessary documentation, and implementing corrective measures.
Important notice
The FAQs are an interpretative guidance document issued by the European Commission to support the uniform application of the PPWR. They do not constitute new legislation and do not replace the text of Regulation (EU) 2025/40 itself.
The full English version of the document is available on the European Commission's website.
NATUR-PACK will analyse the European Commission's new answers in detail and will continue to keep manufacturers informed about their practical implications.
You can view the full European Commission document by clicking HERE.
