[II.1] Does 'whether empty or with a product' change the definitions of packaging and manufacturer?

Art. 3(1)(1) contains the packaging definition, largely unchanged from the PPWD. The new wording does not modify the definition of packaging or of manufacturer; it is meant to cover all factual situations and packaging types within scope.

[II.2] Why does 'machine use' appear only in point (g), not point (f), of the tea/coffee packaging definition?

It distinguishes filter coffee/tea bag systems from coffee-extraction machine systems. Machine use, together with permeability, is key to deciding which point applies, which matters for the compostability rules under Art. 9. Permeable tea, coffee or beverage bags or soft single-serve units used and disposed of with the product (point f) are mandatorily compostable; non-permeable machine single-serve units (point g) are not, though Member States may make them mandatorily compostable locally under certain conditions such as suitable bio-waste infrastructure. Metal capsules cannot be banned or made mandatorily compostable by Member States.

[II.3] Why does 'making available on the market' sometimes refer to the Union market and sometimes to a Member State's territory?

'Making available on the market' (Art. 3(1)(9)) and 'placing on the market' (Art. 3(1)(10)) refer to the Union market, reflecting harmonised obligations on economic operators. Waste-management provisions such as waste reduction, recycling targets, separate collection and EPR are addressed to Member States and use 'making available on the territory of a Member State' (Art. 3(1)(11)), the same meaning but circumscribed to national territory.

[II.4] How do producers know if a packaged product is made available to an end user or made further available?

The determining factor is how the product is used, not the recipient's legal status. A professional end user is an end user when it uses the product in its own operations without reselling it in the same form. Producers must assess this based on the nature of the packaging and the marketing and distribution channels. Logistics companies that unpack, repack or divide imported goods are not end users.

[II.5] Is a farmer a 'producer' for EPR purposes?

It depends on the situation, and there is no blanket exemption for farmers. A farmer is generally a producer if selling under its own name or trademark to a retailer or consumer in the same Member State, or to an end user in another Member State. A farmer is generally not a producer if selling to a retailer in another Member State, if it is a micro-enterprise whose packaging supplier is in the same Member State, or if selling under a cooperative's name or trademark. If a farmer delivers apples in bulk transport packaging to a cooperative that packs them into sales packaging under its own name, the cooperative is the producer. The producer definition addresses packaging used in primary production, meaning the production, rearing or growing of primary products including harvesting, milking and farmed animal production prior to slaughter. Packaging material such as hay-bale foil or straps is only made available on the market when the bales are placed on the market, not when used within the same farm's production process.

[II.6] When is packaging 'composite packaging'?

When materials different from the main packaging material together constitute more than 5 percent of the total mass of the packaging unit (Art. 3(1)(24)), regardless of whether each individual other material is below 5 percent. An example is multilayer flexible packaging with polypropylene as the main structural and printable layer, at 83 to 90 percent, an aluminium foil or metallised PET barrier layer at 3 to 4 percent, and an LDPE or EVA heat-seal barrier at 3 to 4 percent. Printing inks and adhesives, at 1 to 2 percent, are not counted. 'Different materials' means different material categories or functional layers such as barriers, not variants within the same polymer family, so LDPE, LLDPE and HDPE count as the same material, while polypropylene combined with polyethylene layers, aluminium foil or metallised materials counts as different materials. This is without prejudice to the format classification in Annex II, Table 1. Manually separable components of different materials do not constitute composite packaging.

[II.7] Are crown corks for beverage bottles integrated or separate components?

They are separate components under Art. 3(1)(44), since they must be completely and permanently detached to access the product.

[II.8] Do Directive 2008/68/EC derogations apply to all dangerous-goods transport packaging, and to non-dangerous goods too?

The PPWR derogations for recyclability, recycled content and reuse targets apply to packaging used for transport of dangerous goods under Directive 2008/68/EC, even without UN approval, for example under limited quantities marking. They do not apply to UN-approved packaging used for non-dangerous goods, which follows the general rules.

[III.1] Are the ESPR Art. 2(27) criteria (a) to (d) cumulative, and what does 'negatively affects the reuse and recycling of materials' mean?

Only one criterion needs to be met for a substance to qualify as a substance of concern. The Commission and ECHA are conducting a study to identify substances of concern affecting human health and packaging reusability and recyclability.

[III.2] What is the difference between substances and substances of concern, and does the ESPR treat substances of concern the same way as the PPWR?

The substance of concern definition in the PPWR refers to the ESPR, so it is identical in both. It is mainly based on hazardous properties and CLP classification but also includes negative effects on reuse and recycling. The conditions are non-cumulative.

[III.3] How will the PPWR handle the addition of substances of concern and the use of recyclates?

Via identification of substances of concern through the ongoing Commission and ECHA study, then limitation through Design for Recycling criteria under Art. 6(4), or through updates to REACH restrictions.

[III.4] How many substances could be substances of concern?

No definite number or list exists yet; the ongoing Commission and ECHA study will produce one. Useful sources include ECHA's Candidate List of substances of very high concern and Annex VI of Regulation (EC) No 1272/2008 on classification, labelling and packaging.

[III.5] How must packaging suppliers comply with substance of concern data requirements?

Under Art. 16, suppliers must give manufacturers all information and documentation, on paper or electronically, needed to demonstrate conformity and to draft the declaration of conformity under Art. 5.

[III.6] At what level are substance of concern concentration limits set?

No general concentration limit exists; the driving principle is avoidance of unacceptable adverse effects. Specific limits exist for PFAS and certain heavy metals. Further limits may follow the Commission's 2033 evaluation or delegated acts under Art. 6(4).

[III.7] What is the application date for Art. 5(1)?

12 August 2026. The previous Packaging Directive already required minimisation of substances of concern in emissions, ash or leachate and set limits for four heavy metals: lead, cadmium, mercury and hexavalent chromium.

[III.8] Is the harmonised standard EN 13428:2004 still valid for substance of concern conformity?

No. From 12 August 2026, Annex C of EN 13428:2004 no longer creates a presumption of conformity, since the PPWR's substance of concern requirements are broader, covering substances of very high concern under REACH, CLP hazard classes and recyclability impacts, than the standard's focus on emissions and disposal.

[III.9] Does the substance of concern minimisation obligation apply to all economic operators?

It applies to all packaging placed on the market. The manufacturer, or the supplier if the manufacturer is a microenterprise, must ensure compliance.

[III.10] When does substance of concern minimisation start for packaging that is not food-contact sensitive?

The general obligation under Art. 5(1) and the heavy-metal limits under Art. 5(4) apply from 12 August 2026 to all packaging. The PFAS limits under Art. 5(5) apply only to food-contact materials.

[III.11] If Member States submit new substance of concern data before 31 December 2025, will it be available before the 2026 Commission report?

Member States must inform the Commission of relevant substance of concern information before that date under Art. 5(2), and it will feed into the ongoing study. Substance of concern monitoring is a permanent Commission task.

[III.12] Does the glass packaging heavy-metal derogation under Commission Decision 2001/171/EC still apply?

Yes, it continues to apply. Glass packaging may exceed the 100 ppm combined limit for lead, cadmium, mercury and hexavalent chromium where this results from recycled glass content, provided none of these metals is intentionally added. The Commission may only lower, not raise or delay, the Art. 5(4) limit.

[III.13] Will Regulation 1935/2004, Regulation 10/2011, Regulation 2019/1021 on persistent organic pollutants or REACH be amended to reflect the PPWR's PFAS provisions?

The PPWR does not ban PFAS outright but sets maximum concentration levels, and there is no automatic read-across into other legislation. The Commission will evaluate under Art. 5(5) whether the PFAS restriction needs amendment given overlaps with food contact material, REACH or persistent organic pollutant restrictions.

[III.14] Do PFAS restrictions apply to both intentionally added and unintentionally present PFAS?

Yes, without distinction. Preliminary laboratory tests show that, in practice, only packaging with intentionally added PFAS exceeds the limit values.

[III.15] Do the restrictions cover only packaging materials, or also inks, varnishes, glues and adhesives?

The limits apply to the packaging unit as a whole, including associated inks, varnishes, glues and adhesives placed on the market by the manufacturer, who is responsible for the technical documentation.

[III.16] Will a list of restricted PFAS with CAS numbers be published?

No. The limits apply to all PFAS meeting the PPWR definition, whether intentionally present or contaminating the packaging.

[III.17] How will PFAS limits be enforced in the absence of a harmonised EU test method?

The Commission is working with industry, civil society and Member State authorities, including the EU Reference Laboratory for Food Contact Materials, toward a harmonised PFAS testing protocol for food-contact packaging.

[III.18] What laboratories offer total fluorine testing, the likely enforcement starting point?

Numerous commercial and university laboratories already offer Total Fluorine and Total Organic Fluorine analysis, and capacity is expected to grow given the PPWR's PFAS limits.

[IV.1] How is a 'unit of packaging' defined, and what is the difference between integrated and separate components and the 'main body'?

A unit of packaging under Art. 3(1)(45) includes any integrated or separate components which as a whole serve a packaging function. For example, in a plastic ketchup bottle, the bottle and label are integrated components since the label is disposed of together with the bottle, a peelable lid that must be fully removed to access the product is a separate component, and a closure system not meant to be separated by consumers is integrated. The main body is generally the packaging part with the highest share by weight, except closures on flexible packaging. Under Art. 6(9), the assessment of design-for-recycling criteria and recycled-at-scale requirements must cover all integrated components, with a separate assessment for integrated components that may separate due to mechanical stress during transport or sorting.

[IV.2] Can packaging without a recyclable alternative on the market get an exemption under Art. 6?

Only the exemptions listed in Art. 6(11) apply, and the Commission cannot grant further ones. For genuinely innovative packaging, meaning new materials bringing significant functional improvement and demonstrable environmental benefit and excluding modifications aimed mainly at presentation or marketing under Art. 3(1)(46), Member State authorities may flag cases for the Commission to assess when updating or adopting delegated acts under Art. 6(4). The Commission will monitor the impact of the Art. 6(11) and 6(10) derogations and may propose amendments if necessary.

[IV.3] What is the process and timeline for the innovative-packaging derogation, and what criteria apply?

The process is set out in Art. 6(10), with Member States retaining discretion on national implementation. The criteria are in Art. 3(1)(46), and no further Commission guidance is currently envisaged, so manufacturers must evidence compliance in the technical documentation.

[IV.4] Can Member States apply their own eco-modulation criteria?

Under Art. 6(4)(d), the Commission will set a harmonised framework for modulating EPR financial contributions based on recyclability performance grades, to prevent market fragmentation, without setting actual fee amounts. Until it enters into force, Member States retain their existing national eco-modulation rules, notifiable via TRIS if they constitute technical regulations. Once the harmonised framework applies, Member States must follow it but may still eco-modulate on other bases such as recycled content, substance of concern presence, or reusability; recycled-content-based modulation must account for sustainability criteria and environmental cost, to be developed under Art. 7(9) by the end of 2026.

[IV.5] If Member States miss recycling targets, does this affect the 'at scale' assessment?

No. The 'at scale' assessment is based on a 55 percent EU-level recycling target per packaging category, 30 percent for wood, per Annex II Table 2, not on national recycling rates. Support measures such as deposit and return systems, harmonised sorting labels, mandatory collection targets, and landfill or incineration bans for recyclable packaging should help improve the overall EU rate.

[IV.6] What is the scope of the Art. 6(11)(e) exemption for baby food?

It follows the definition in Regulation (EU) No 609/2013, Art. 2(2f), and does not cover all fruit juices or purees marketed simply 'for babies'.

[IV.7] Does the 'at scale' assessment cover all packaging waste regardless of origin, sector or type?

Yes, all plastic packaging waste generated and recycled in the EU, whether household, commercial or industrial, calculated per the existing rules of Commission Decision 2005/270 as amended, soon to be replaced under Art. 56(7).

[IV.8] Does Art. 6 apply to reusable sales or transport packaging placed on the market before the Art. 6(1) requirements enter into force?

Packaging placed on the market before the relevant application date does not need to meet the new sustainability or labelling requirements or be withdrawn, per Recital 14. Art. 6(2) requires all packaging placed on the market 24 months after entry into force of the Art. 6(4) delegated acts to be design-for-recycling compliant. Since those acts are due by 1 January 2028, reusable or transport packaging placed on the market before 1 January 2030 can remain even if non-compliant.

[IV.9] Are the exemptions for cork, lightweight wood, textile, ceramics, rubber, porcelain and wax valid until 2035?

Art. 6(1) requires all packaging to be recyclable, and Art. 6(11) exempts these materials, for sales packaging only, from the recyclability assessment for market placement, to be reviewed by the Commission by 1 January 2035. However, such packaging must still undergo the recyclability assessment for the purpose of EPR fee modulation.

[V.1] How is compliance with recycled content requirements demonstrated?

Via technical documentation per Annex VII. For example, in a PET tray with a peelable PP lid manufactured at different plants, each plant must disclose recycled-content compliance for its own component under Art. 7(2), and the economic operator assembling and placing the product on the market draws up the technical documentation demonstrating overall compliance. The same principle applies to intermediate components and imported packaging, which must also meet sustainability and equivalence criteria to be set under Art. 7(9) and (10).

[V.2] What does 'average per manufacturing plant and year' mean?

A manufacturing plant is the industrial facility producing the packaging. The average per year is calculated over a calendar year, per packaging type and format, for each manufacturer supplied by that plant. Plants producing several formats must calculate targets separately per type and format. The implementing act under Art. 7(8) will set calculation and verification rules.

[V.3] Are adhesives, paints and inks covered by the recycled content requirements?

No, they are not deemed 'plastic' under the PPWR, regardless of their share of the packaging weight.

[V.4] Are environmental claims about recycled content in plastic packaging allowed?

Yes, where recycled content exceeds the applicable minimum under Art. 7(1) and (2). Per Art. 14, claims may relate to the packaging unit, the part containing the recycled content, or all packaging placed on the market by the operator over a calendar year. For example, for a PET bottle with a 30 percent requirement and a PP closure with a 10 percent requirement, a claim is allowed if content exceeds 30 percent for the bottle or 10 percent for the closure.

[V.5] How do operators know which recycled content requirements apply?

There are two steps: first, is the packaging contact-sensitive, and second, what polymer is it made from. For example, pallet wrap film, non-contact-sensitive and non-PET, falls under Art. 7(1)(d) at 35 percent; a beverage carton, contact-sensitive and non-PET, falls under Art. 7(1)(b) at 10 percent; and a single-use plastic beverage bottle, contact-sensitive and PET, falls under Art. 7(1)(c) at 30 percent.

[V.6] Do recycled content requirements apply to packaging placed on the market before 2030?

No, they apply from 1 January 2030 or three years after entry into force of the Art. 7(8) implementing act, whichever is later. No stock exhaustion period is envisaged for packaging supplied to, but not yet placed on the market by, manufacturers before that date.

[V.7] Do a plastic cap and label on a glass bottle need to comply with recycled content requirements?

Art. 7(5)(b) exempts plastic parts under 5 percent of total packaging unit weight, and this applies only to plastic parts. A metallic cap is not plastic and falls outside scope entirely, while a plastic label is exempt only if under 5 percent of the total unit weight.

[V.8] If the same caps are used for milk and infant formula, must they meet the recycled content target?

Milk is not exempted, so plastic caps used for milk packaging must meet the target. Caps for infant formula are exempted under Art. 7(4)(g). If the same cap is used for both, it must comply with the milk-related requirement.

[V.9] Is there a difference between 'contact-sensitive plastic packaging' and 'immediate packaging' as used in the Art. 7 exemptions?

'Immediate packaging', used in the medicinal products context, generally qualifies as 'contact-sensitive packaging' under Art. 3(1)(49). While not identical concepts, they should be understood consistently for Art. 7 purposes.

[V.10] How do PPWR and SUPD recycled content reporting obligations interact?

SUPD Art. 6(5)(a) and (b), covering beverage bottle targets in Annex Part F, and Art. 13(1)(e) reporting remain in force until 1 January 2030 or three years after the Art. 7(8) implementing act. The frameworks differ: the SUPD sets Member-State-level targets versus the PPWR's per-plant-and-format average; the SUPD has no composite-material threshold, while the PPWR has a 5 percent plastic-part exemption; and the SUPD has no compostable-plastic exemption.

[V.11] What applies for recycled content requirements for imported plastic packaging?

Regulation (EU) 2022/1616, especially Art. 6, applies to all recycled plastics for food-contact use, including imports, requiring separate collection of plastic waste, third-party certification of pre-processing, and proof of compliance with Regulation (EU) 10/2011. Non-compliant material cannot be used for food-contact purposes but may be used elsewhere.

[VI.1] Will packaging types newly covered by Art. 9(1) be accepted in the bio-waste stream before 12 February 2028?

Non-empty tea or coffee bags become 'packaging' from 12 August 2026, the application date of the Regulation. Since Art. 9 on compostability only applies from 12 February 2028, Member States are not required, though they are encouraged, to accept such packaging in bio-waste before then.

[VI.2] Must composting facilities operate per EN 13432:2000, and must all Member States accept certified compostable packaging?

This is not explicitly required, but the Commission expects it in practice. For example, Art. 9(2) conditions Member States' ability to add packaging to national mandatory-compostable lists on having appropriate waste collection schemes and waste management infrastructure. Industrial composting associations will be involved in updating the compostability standards.

[VI.3] Can currently compostable products remain on the market after the Regulation applies?

Yes, where there is a clear national legal requirement that a given format be compostable. Member States have until 12 August 2026 to decide on additional mandatorily compostable formats beyond Art. 9(1) and 9(2)(a).

[VII.1] Do both Art. 10(1) and (2) apply from 1 January 2030?

Yes. Until the end of 2029, the previous Packaging Directive's essential requirements, and EN 13428:2004, continue to apply under Art. 70(1)(b).

[VII.2] What does 'increase the perceived volume of the product' under Art. 10(2) mean?

It prohibits using double walls, false bottoms and similar features to make a product appear larger than it is. For example, a 50 ml facial cream jar minimised to the necessary volume would breach this if double walls, false bottoms or an outer cardboard box made it appear larger than 50 ml. Such features are only allowed where functionality cannot otherwise be ensured, demonstrated via tests in the technical documentation.

EU PPWR FAQ V2: The European Commission's Official Guidance…

UPDATE AUGUST 2026 - The EU's Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, entered into force on 11 February 2025 and becomes generally applicable on 12 August 2026, replacing the 1994 Packaging and Packaging Waste Directive with a single, directly applicable EU-wide rulebook. Unlike its predecessor, which left significant room for national transposition, the PPWR harmonises requirements across all 27 Member States, covering recyclability design rules, minimum recycled content, substances of concern, reuse targets, empty space limits, sorting labels, single-use bans and extended producer responsibility.

Stacked cardboard packaging boxes representing EU packaging and packaging waste compliance

Key PPWR provisions at a glance

Main provisions include:

Waste prevention targets: 5% by 2030, 10% by 2035, 15% by 2040 (vs. 2018 levels) (Art. 43)
Recyclability: all packaging must be recyclable in an economically viable way by 2030 (Art. 6)
Reuse targets: for transport, e-commerce, and beverage packaging (Art. 29)
Restrictions: ban on certain single-use formats from 1 January 2030 (Art. 25 and Annex V); PFAS in food-contact packaging prohibited from 12 August 2026 (Art. 5(5))
Empty space threshold: max 50% for grouped, transport, and e-commerce packaging (Art. 24)
Mandatory deposit-return systems: for beverage cans and plastic bottles (Art. 50)
Labelling: harmonised sorting labels for all packaging (Art. 12(1))
Extended Producer Responsibility (EPR): strengthened obligations (Art. 44–47)

Why this matters if you are already working on ESPR and the Digital Product Passport

For businesses already navigating the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport, the PPWR is a close relative rather than a separate compliance track. It shares the ESPR's definition of "substances of concern," follows a similar delegated-act structure for setting detailed technical criteria (design-for-recycling rules are expected by January 2028), and, like the DPP, relies heavily on documented, auditable evidence, such as technical documentation and declarations of conformity, that manufacturers, importers and distributors must be able to produce on demand. Several open questions, including which substances count as "of concern," how empty space is calculated for irregular products, and which beverages are exempt from reuse targets, are still being resolved through Commission guidelines expected through 2027 and 2028, which makes early, structured preparation valuable.

What the Commission's FAQ addresses

In March 2026, DG Environment published a first-edition FAQ addressing the most common interpretation questions raised by economic operators, national authorities and stakeholders since the Regulation's adoption. It covers definitions, substances of concern, recyclability, recycled content, compostability, minimisation, labelling, environmental claims, manufacturer obligations, empty space, packaging bans, reuse and refill, plastic carrier bags, conformity assessment, waste prevention, extended producer responsibility, collection systems, and deposit-return schemes. The FAQ accordion below reproduces this guidance question by question, organised the same way, so you can find the specific Commission answer for each point.

How to use this FAQ in your compliance process

Identify which of your packaging formats are contact-sensitive and which polymer they use, since this determines your recycled content target under Article 7.
Check whether your packaging design is protected by a trademark or design right registered before 11 February 2025 before assuming it needs to be exempted from minimisation.
Map your reuse system type (open loop vs. closed loop) now, since labelling and rotation-reporting obligations differ significantly between the two.
Track the Commission's forthcoming guidelines and delegated acts (design-for-recycling by January 2028, empty space methodology by February 2028, Annex V guidelines by February 2027) as they will convert several of today's open questions into binding rules.
Keep your technical documentation and declarations of conformity audit-ready, since this evidentiary logic mirrors what is already expected under the ESPR and the Digital Product Passport.

Legal status of this FAQ

This FAQ is a European Commission interpretation aid published by DG Environment. It does not create new rights or obligations beyond those set out in Regulation (EU) 2025/40, and it complements, without replacing, the Commission Notice - Guidance document for Regulation (EU) 2025/40. For any specific compliance decision, the binding text of the Regulation and the Commission guidance document remain the authoritative references.

Source: European Commission, DG ENV Unit B01, "Packaging and Packaging Waste Regulation (PPWR), Frequently Asked Questions," 1st edition, March 2026 (PDF ISBN 978-92-68-37678-2, doi:10.2779/6056528, KH-01-26-006-EN-N). Full document available at environment.ec.europa.eu.

141 official Commission answers, organised by chapter

The FAQ accordion below reproduces all 141 questions and answers from the Commission's PPWR FAQ document in full, sorted into the same 18 thematic chapters as the source text (sections II to XIX). Each entry carries an in-document reference, such as [V.7], so you can cite it exactly as the original PDF does and jump straight to the relevant clarification, whether you are researching substances of concern, recycled content targets, reuse obligations or deposit-return systems.

II. Definitions – 8 questions, including packaging vs. manufacturer definitions, "making available on the market," and when a farmer counts as a producer
III. Substances of concern – 18 questions on SoC criteria, PFAS limits, heavy metals and the ongoing ECHA study
IV. Recyclability – 9 questions on unit of packaging, design-for-recycling exemptions and the 55% recyclable-at-scale target
V. Recycled content in plastic packaging – 11 questions on per-plant targets, contact-sensitive packaging and imported plastics
VI. Compostability – 3 questions on mandatory compostable formats and bio-waste infrastructure
VII. Packaging minimisation – 7 questions on perceived volume, empty space and trademark or design-right exemptions
VIII. Labelling – 4 questions on reusable packaging labels, QR codes and deposit-return system labelling
IX. Environmental claims – 3 questions on when recycled-content and other sustainability claims are allowed
X. Obligations of manufacturers – 4 questions on manufacturer, importer and distributor responsibilities and application dates
XI. Empty space – 4 questions on the 50% threshold and the future calculation methodology
XII. Bans and use of certain packaging – 9 questions on Annex V single-use restrictions, HORECA and carrier bags
XIII. Reuse and refill – 15 questions on rotation targets, open- and closed-loop systems and beverage reuse exemptions
XIV. Plastic carrier bags – 3 questions on compostable bags and national bans
XV. Assessment of conformity of packaging – 14 questions on declarations of conformity, technical documentation and market surveillance
XVI. Waste prevention – 5 questions on national waste reduction targets and TRIS notification
XVII. Extended producer responsibility – 5 questions on EPR registration, online platforms and micro-enterprise exemptions
XVIII. Return and collection systems – 4 questions on separate collection and priority access to recyclates
XIX. Deposit and return systems – 5 questions on DRS exemptions, non-profit status and cross-border collection

August 2026 update: second edition of the Commission FAQ

In August 2026, DG Environment published a second edition of this FAQ, adding one new chapter and expanding several existing chapters with new questions. The new chapter, XVI, Enforcement of the new rules, clarifies that market surveillance authorities will give economic operators the chance to correct non-compliance before taking action such as withdrawing packaging from the market, rather than pulling products from sale immediately after the 12 August 2026 application date. The chapters on Definitions, Substances of concern, Manufacturer obligations, Reuse and refill, Conformity assessment and Extended producer responsibility were also expanded with new questions, several of them covering the practical treatment of packaging manufactured before 12 August 2026, and clarifying who counts as the manufacturer or producer of transport packaging. The FAQ below has been updated accordingly, with new entries using the same in-document numbering as the source, for example [XVI.1].

MANUFACTURER for PPWR

V2 update, Aug 2026: clarified definitions

Definition: the manufacturer is the party that specifies the packaging system and makes the final design decisions for the packaging placed on the EU market. This covers decisions on the 3D structure, materials, packaging components, label and artwork design, branding and the intended packaging configuration.

A design agency or a supplier's design team may create the packaging design, but they are normally not the manufacturer when they work on behalf of a brand owner, retailer or packaged goods company that specifies and approves the packaging system.

Simple rule: the manufacturer is not the party that draws the design. It is the party that owns and approves the packaging specification.

Role	What this role typically does	PPWR role	Comments
Packaging supplier	Supplies empty packaging, packaging components or packaging materials.	Supplier, or MANUFACTURER for transport packaging in some cases	Usually provides specifications, declarations and test data to the party further down the chain that fills or brands the packaging.
Filler or packer	Fills, seals or assembles the product into sales, grouped or transport packaging.	MANUFACTURER, or none	Often the manufacturer for sales, grouped or transport packaging, but not when it only packs under another party's name, trademark and specification.
Copacker or toll filler	Packs or fills on behalf of a brand owner, retailer or manufacturer.	Usually none, sometimes MANUFACTURER	Usually a service provider. Becomes manufacturer only when it owns the packaging specification or design, or places the packaging under its own name or trademark.
Importer into the EU	Brings packaging or packaged products from outside the EU onto the EU market.	Importer, possibly MANUFACTURER	Becomes manufacturer if using its own name or trademark, or modifying the packaging. Only applies to goods entering the EU from outside.
Intra-EU distributor	Makes packaging or packaged products available on the EU market after they have already been placed on it.	Distributor, possibly MANUFACTURER	Includes intra-EU movement, for example country to country transfers and national business to business distribution.
Retailer or e-commerce	Supplies packaging or packaged products directly to the end user.	Final distributor, sometimes MANUFACTURER	Covers retail stores, webshops, HoReCa, foodservice and direct delivery. Becomes manufacturer for service packaging, e-commerce packaging or private label packaging.

PRODUCER for EPR

V2 update, Aug 2026: clarified definitions

Definition: the producer for extended producer responsibility (EPR) is the legal entity that first commercially introduces the packaged product or packaging into the commercial market of a specific Member State, and is therefore responsible for EPR registration, reporting and EPR fees in that Member State. In practice, this is often the party that first sells, first supplies, first imports into that Member State, or first delivers directly to end users there.

The producer depends on the commercial route, the Member State, the packaging type and the selling technique, including direct e-commerce sales. A distributor, retailer, importer, wholesaler, marketplace seller or brand owner can all become the producer, depending on who first commercially introduces the packaged product into that Member State.

Simple rule: the EPR producer is not determined by who designed the packaging. It is determined by who first commercially introduces the packaging into a Member State.

Role	What this role typically does	PPWR role	Comments
Brand owner	Owns the product and packaging specification, and decides to place packaged goods on a given Member State market.	PRODUCER for its own directly sold ranges, or none if another party introduces the product on its behalf	Becomes producer whenever it is the first to commercially introduce the packaged product into a Member State, for example through direct sales or its own webshop.
Importer	Brings packaged product from outside the EU, or from another Member State, and first supplies it into a given Member State's market.	PRODUCER for that Member State	Whoever first imports the packaged product into a specific Member State usually becomes the producer for that State, regardless of where the packaging was designed.
Wholesaler	Buys packaged product in bulk and resells it onward, often to retailers, within a Member State.	Usually none, possibly PRODUCER	Becomes producer only if it is the first party to commercially introduce the packaged product into that Member State, for example when sourcing directly from outside the country.
Distributor	Makes packaged product available on the market of a Member State, often after another party has already introduced it there.	Usually none, possibly PRODUCER	Only becomes producer if it is the first to commercially introduce the packaged product into that specific Member State.
Retailer	Sells packaged product directly to end users in a Member State, through stores or other retail channels.	Usually none, possibly PRODUCER	Becomes producer if it is the first to commercially introduce the packaged product into that Member State, for example by importing directly or selling under its own private label.
Marketplace seller or direct e-commerce	Sells packaged product directly to end users, often across borders, through an online marketplace or its own webshop.	PRODUCER for each Member State it sells into	Direct e-commerce and marketplace sales frequently make the seller the producer in every Member State it delivers to, since it is typically the first to introduce the product there.

EU PPWR FAQ V2: The European Commission's Official Guidance on Packaging and Packaging Waste Regulation (AUG 2026)

Related documents

Key PPWR provisions at a glance

Why this matters if you are already working on ESPR and the Digital Product Passport

What the Commission's FAQ addresses

How to use this FAQ in your compliance process

Legal status of this FAQ

141 official Commission answers, organised by chapter

August 2026 update: second edition of the Commission FAQ

MANUFACTURER for PPWR

PRODUCER for EPR

Frequently Asked Questions

Related documents

Key PPWR provisions at a glance

Why this matters if you are already working on ESPR and the Digital Product Passport

What the Commission's FAQ addresses

How to use this FAQ in your compliance process

Legal status of this FAQ

141 official Commission answers, organised by chapter

August 2026 update: second edition of the Commission FAQ

MANUFACTURER for PPWR

PRODUCER for EPR

Frequently Asked Questions

[II.1] Does 'whether empty or with a product' change the definitions of packaging and manufacturer?

[II.2] Why does 'machine use' appear only in point (g), not point (f), of the tea/coffee packaging definition?

[II.3] Why does 'making available on the market' sometimes refer to the Union market and sometimes to a Member State's territory?

[II.4] How do producers know if a packaged product is made available to an end user or made further available?

[II.5] Is a farmer a 'producer' for EPR purposes?

[II.6] When is packaging 'composite packaging'?

[II.7] Are crown corks for beverage bottles integrated or separate components?

[II.8] Do Directive 2008/68/EC derogations apply to all dangerous-goods transport packaging, and to non-dangerous goods too?

[III.1] Are the ESPR Art. 2(27) criteria (a) to (d) cumulative, and what does 'negatively affects the reuse and recycling of materials' mean?

[III.2] What is the difference between substances and substances of concern, and does the ESPR treat substances of concern the same way as the PPWR?

[III.3] How will the PPWR handle the addition of substances of concern and the use of recyclates?

[III.4] How many substances could be substances of concern?

[III.5] How must packaging suppliers comply with substance of concern data requirements?

[III.6] At what level are substance of concern concentration limits set?

[III.7] What is the application date for Art. 5(1)?

[III.8] Is the harmonised standard EN 13428:2004 still valid for substance of concern conformity?

[III.9] Does the substance of concern minimisation obligation apply to all economic operators?

[III.10] When does substance of concern minimisation start for packaging that is not food-contact sensitive?

[III.11] If Member States submit new substance of concern data before 31 December 2025, will it be available before the 2026 Commission report?

[III.12] Does the glass packaging heavy-metal derogation under Commission Decision 2001/171/EC still apply?

[III.13] Will Regulation 1935/2004, Regulation 10/2011, Regulation 2019/1021 on persistent organic pollutants or REACH be amended to reflect the PPWR's PFAS provisions?

[III.14] Do PFAS restrictions apply to both intentionally added and unintentionally present PFAS?

[III.15] Do the restrictions cover only packaging materials, or also inks, varnishes, glues and adhesives?

[III.16] Will a list of restricted PFAS with CAS numbers be published?

[III.17] How will PFAS limits be enforced in the absence of a harmonised EU test method?

[III.18] What laboratories offer total fluorine testing, the likely enforcement starting point?

[IV.1] How is a 'unit of packaging' defined, and what is the difference between integrated and separate components and the 'main body'?

[IV.2] Can packaging without a recyclable alternative on the market get an exemption under Art. 6?

[IV.3] What is the process and timeline for the innovative-packaging derogation, and what criteria apply?

[IV.4] Can Member States apply their own eco-modulation criteria?

[IV.5] If Member States miss recycling targets, does this affect the 'at scale' assessment?

[IV.6] What is the scope of the Art. 6(11)(e) exemption for baby food?

[IV.7] Does the 'at scale' assessment cover all packaging waste regardless of origin, sector or type?

[IV.8] Does Art. 6 apply to reusable sales or transport packaging placed on the market before the Art. 6(1) requirements enter into force?

[IV.9] Are the exemptions for cork, lightweight wood, textile, ceramics, rubber, porcelain and wax valid until 2035?

[V.1] How is compliance with recycled content requirements demonstrated?

[V.2] What does 'average per manufacturing plant and year' mean?

[V.3] Are adhesives, paints and inks covered by the recycled content requirements?

[V.4] Are environmental claims about recycled content in plastic packaging allowed?

[V.5] How do operators know which recycled content requirements apply?

[V.6] Do recycled content requirements apply to packaging placed on the market before 2030?

[V.7] Do a plastic cap and label on a glass bottle need to comply with recycled content requirements?

[V.8] If the same caps are used for milk and infant formula, must they meet the recycled content target?

[V.9] Is there a difference between 'contact-sensitive plastic packaging' and 'immediate packaging' as used in the Art. 7 exemptions?

[V.10] How do PPWR and SUPD recycled content reporting obligations interact?

[V.11] What applies for recycled content requirements for imported plastic packaging?

[VI.1] Will packaging types newly covered by Art. 9(1) be accepted in the bio-waste stream before 12 February 2028?

[VI.2] Must composting facilities operate per EN 13432:2000, and must all Member States accept certified compostable packaging?

[VI.3] Can currently compostable products remain on the market after the Regulation applies?

[VII.1] Do both Art. 10(1) and (2) apply from 1 January 2030?

[VII.2] What does 'increase the perceived volume of the product' under Art. 10(2) mean?

[VII.3] How will minimisation be enforced for less-common packaging types and formats?

[VII.4] What are the 'most common packaging types and formats' under Art. 10(3)?

[VII.5] Which packaging is exempt from minimisation requirements under Art. 10(2)?

[VII.6] How does packaging 'shape' affect the minimisation assessment?

[VII.7] How does PPWR minimisation relate to ESPR minimisation requirements?

[VIII.1] Do reusable packaging labelling requirements under Art. 12(2) apply at individual-packaging level?

[VIII.2] When are marks, symbols, labels or inscriptions considered misleading?

[VIII.3] Should packaging bear a national deposit and return system label when imported from one Member State to another?

[VIII.4] Which substances of concern require labelling under Art. 12(7), second subparagraph?

[IX.1] Are claims about features equivalent to the Regulation's requirements allowed?

[IX.2] Which threshold applies for a recycled content claim, and can operators claim 10, 20 or 50 percent?

[IX.3] Does Art. 14 apply only to PPWR-regulated claims, or to all environmental claims on sustainable packaging?

[X.1] Does Art. 15(1), placing only compliant packaging on the market, apply exclusively to manufacturers?

[X.2] When do Art. 15 and 18 on manufacturer and importer obligations become effective?

[X.3] Must suppliers mark 'plain' packaging such as plastic carrier bags with a serial number?

[X.4] Do importers or distributors supplying packaging materials have compliance obligations under the Regulation?

[XI.1] Who must comply with the empty-space requirements under Art. 24?

[XI.2] How should 'minimum necessary' under Art. 24(4) be understood for sales packaging?