EU Updates PPWR FAQ with Key Clarifications for All Manufacturers and Importers
The FAQ serves as the European Commission's official interpretation of the Packaging and Packaging Waste Regulation (PPWR). It explains how the rules should be understood and applied in practice, and the updated version includes several changes compared with the first FAQ published in March 2026.
Several of the updates introduce stricter requirements for extended producer responsibility (EPR), documentation, packaging design, and labelling.
Among other things, this means that companies that previously considered themselves to be outside the scope of extended producer responsibility may now be covered by the rules. Emballageretur therefore recommends that all members review the new interpretations and assess how they may affect their business.
Read the updated FAQ: Packaging and Packaging Waste Regulation (PPWR) – Publications Office of the European Union
Below is a brief overview of seven of the most significant changes introduced in the updated FAQ. Each highlighted change includes a direct reference to the relevant section, allowing you to quickly locate the exact wording in the Commission's FAQ.
What: The producer is now defined as the economic operator that determines the design of the packaging, rather than necessarily the physical manufacturer or the company filling the product.
Where in the FAQ: Chapter II – Definitions, Questions 5, 6, 7 and 14.
Examples from the Commission of who is considered the producer of transport packaging:
Example 1: A cardboard box has reached its final form even if it is supplied flat and requires folding. If the box bears a name or trademark, the company whose name appears on the box or that owns the trademark will be considered the ‘producer’.
For standardised cardboard boxes without a name or trademark, the company that physically manufactures the boxes will be considered the ‘producer’. If a company merely applies a sticker to the box during shipping, this is not regarded as a name or trademark, and that company should therefore not be considered the ‘producer’.
Example 2: Stretch film used to stabilise palletised goods should be regarded as packaging when it is placed on the market in roll form, even though it is subsequently cut to size for wrapping pallets. The ‘producer’ is the company that physically manufactures the film and places it on the market as packaging if it does not bear a name or trademark, rather than the company that purchases the film and subsequently uses it to secure goods.
The Commission's Guidance on Who Is Considered the Manufacturer of Branded Products
"If the packaging or the packaged product bears a specific name or trademark, it may be assumed that the owner of that name or trademark is the manufacturer[...], since that entity will hold the decisive influence in the contractual relationship with its suppliers and will therefore also be able to determine the characteristics of the packaging."
The company that commissions another company to manufacture packaging or packaged products under its own name or trademark is in a position to determine the characteristics of the packaging, including its branding, which may affect the packaging's conformity assessment.
This also applies where an economic operator simply selects a standardised packaging solution and does not request any changes to the design or manufacturing process.
The Commission's Guidance: Who Is the ‘Producer’ if a Packaged Product Bears One Company's Name and Another Company's Trademark?
A name and a trademark appearing on packaging carry equal weight in determining producer status under the PPWR (Article 3(1), point (12)).
Accordingly, where one company manufactures, markets and distributes products under its own name - for example, as the responsible food business operator - but under another company's trademark, producer status will be assigned to the company that determines the packaging design and specifications.
What: Empty transport packaging is considered packaging. Transport packaging purchased from external suppliers and used internally may also fall within the scope of the Regulation.
Where in the FAQ: Chapter II – Definitions, Questions 5, 9, 10 and 13.
Example from the Commission: The Commission provides guidance on who is considered the producer of transport packaging.
The producer of transport packaging must be identified when the packaging is empty (see the further explanation above under "Who is the producer of transport packaging?").
The following are typical examples of who is considered the producer of transport packaging:
What: Requirements for documenting design, materials, traceability, technical drawings, and the EU Declaration of Conformity have been clarified and expanded.
Where in the FAQ: Chapter X - Obligations of Manufacturers, Questions 5-14.
The Commission provides guidance: What should happen to packaging that is in stock or has already been manufactured before 12 August 2026, but has not yet been placed on the market by that date? Are companies required to destroy, remanufacture, or relabel such packaging?
Packaging that has not been placed on the market by 12 August 2026, but has already been manufactured and is held in stock, does not need to be destroyed, remanufactured, or relabelled.
To comply with the requirements of Article 15(5) and (6), which require packaging to bear a unique identification as well as the manufacturer's name and address, the required information may be provided in an accompanying document. This also applies to reusable packaging that has already been placed on the market.
For packaging manufactured after 12 August 2026, however, an accompanying document may only be used where it is not possible to affix the unique identification, name, and address directly on the packaging.
What: All materials and components in packaging must be assessed. Small components (e.g. valves, caps, labels) are not automatically exempt.
Where in the FAQ: Chapter IV - Recyclability.
The Commission provides guidance: According to Article 6(9):
“Where a packaging unit contains integrated components, the assessment of compliance with the criteria for design for recycling and the requirements for recycling at scale shall include all integrated components. A separate assessment shall be carried out for integrated components that may become separated from each other as a result of mechanical stress during transport or sorting.”
What: Plastic components in packaging made primarily from other materials, such as glass or metal packaging (e.g. caps, lids, labels), are subject to recycled content requirements if their weight exceeds 5% of the total weight of the packaging unit.
Where in the FAQ: Chapter V – Recycled Content.
The Commission provides guidance: Do plastic caps and labels on a glass bottle also need to comply with recycled content requirements?
Article 7(5)(b) exempts plastic components that account for less than 5% of the total weight of a packaging unit from recycled content requirements. This exemption applies exclusively to plastic components and does not cover materials that are not plastic.
Example: In the case of a glass bottle with a metal cap and a plastic label, the metal cap is not a plastic component and is therefore not subject to recycled content requirements.
A plastic label, however, is exempt if its weight accounts for less than 5% of the total weight of the packaging unit, i.e. the bottle including the cap and label.
What: Importers must ensure full documentation and traceability for packaging from third countries. Responsibilities and control obligations have been clarified.
Where in the FAQ: Chapter X – Obligations of Manufacturers, Question 11 (NEW).
The Commission provides guidance: Article 18 sets out the obligations of importers. What should an importer be aware of?
Where packaging is imported from a third country, the importer is responsible for ensuring that the manufacturer established outside the EU has complied with the applicable requirements of the PPWR. In order to demonstrate compliance, importers must, from 12 August 2026, ensure that:
What: Products with non-compliant packaging may not be placed on the market after the applicable date. The enforcement approach has been clarified.
Where in the FAQ: Chapter XVI – Enforcement, Question 1 (NEW).
The Commission provides guidance: Will products be prohibited on the EU market if their packaging does not comply with the rules applicable from 12 August 2026?
No. The enforcement of the obligations applicable from 12 August 2026 should not disrupt trade flows, supply chains, or consumers’ access to goods (...).
Emballageretur recommends that you read the Commission’s updated FAQ and review your packaging portfolio and producer role in light of the new clarifications.
Please also remember that you can register for our PPWR courses and webinars, where you can ensure that your company’s packaging complies with current legislation.