New PPWR FAQs Released: What Has Changed Since the First Edition?

The European Commission has published the second edition of the PPWR Frequently Asked Questions (FAQs), providing additional guidance on several areas that have generated uncertainty since the Regulation entered into force. While the Regulation itself has not changed, the expanded FAQs offer more practical interpretation of key provisions and answer many of the implementation questions raised by industry over recent months.

For businesses preparing for the PPWR, these updates are valuable because they clarify responsibilities, explain how certain requirements should be interpreted and help companies understand what evidence will be expected to demonstrate compliance.

1. Greater clarity on who is responsible

One of the largest additions to the new FAQs is the expanded explanation of the different economic operators under the PPWR.

The Commission now provides practical examples distinguishing the roles of manufacturer, importer and producer, explaining who becomes responsible for packaging compliance and Extended Producer Responsibility (EPR) obligations in different supply chain scenarios. Examples are also included for transport packaging, sales packaging used for transport and primary production packaging.

A particularly important clarification concerns EU branches. The Commission explains that a branch is generally not considered a separate legal entity, meaning that having a tax registration or branch office within the EU does not automatically make that branch the importer. Instead, the importer must be a legal person established within the Union that places the packaging or packaged product on the EU market. This clarification is especially relevant for non-EU companies selling directly into Europe through local branches or representative offices.

2. Clarification of what is—and is not—considered packaging

The updated FAQs also answer several practical questions that were previously left open.

For example:

• an envelope containing an invoice or letter is not considered packaging;

• an envelope containing a product, catalogue or magazine is packaging;

• empty envelopes sold as products are not packaging because they are the product being purchased.

Although these examples appear simple, they help clarify the boundary between products and packaging when applying the Regulation.

3. Packaging minimisation explained in more detail

The second edition of the FAQs provides much more practical guidance on how manufacturers should demonstrate compliance with the packaging minimisation requirements under Article 10.

The Commission clarifies that packaging must be reduced to the minimum volume and weight necessary while still ensuring product protection, safety, hygiene, functionality and transport performance. Importantly, marketing, branding or creating a perception of a larger product cannot justify additional packaging material or empty space. Features such as double walls, false bottoms, oversized containers or decorative elements are only acceptable where they perform a genuine technical function.

The FAQs also explain that manufacturers are expected to document and justify their packaging design decisions as part of the technical documentation supporting the Declaration of Conformity. This includes demonstrating how the packaging meets one or more of the recognised performance criteria, such as product protection, manufacturing requirements, logistics, legal requirements or the incorporation of recycled content or reusable features.

To help businesses assess compliance consistently across the EU, the Commission confirms that future harmonised standards will establish measurable design criteria for common packaging formats, including aspects such as weight, dimensions and, where appropriate, wall thickness. Until these standards are available, manufacturers remain responsible for demonstrating that any additional packaging material is technically necessary rather than commercially desirable.

4. The 50% empty space rule does not replace packaging minimisation

One of the most useful clarifications addresses a common misunderstanding across industry.

Many companies have assumed that meeting the maximum 50% empty space requirement automatically demonstrates compliance with packaging minimisation. The Commission confirms that this is not the case.

The empty space limit applies only to grouped, transport and e-commerce packaging, while Article 10 packaging minimisation applies independently to all packaging. Both requirements must therefore be assessed separately, meaning compliance with one does not guarantee compliance with the other.

5. Additional guidance on compostable packaging

The updated FAQs also expand the guidance relating to compostable packaging.

The Commission explains the distinction between industrial compostability and home compostability and clarifies the circumstances in which Member States may require additional packaging formats to be compostable. It also confirms that, until harmonised European standards become available, manufacturers may rely on national standards and certification schemes, although these do not provide the formal presumption of conformity available under future harmonised standards.

This provides greater certainty for businesses developing compostable packaging solutions while acknowledging that harmonised technical standards are still under development.

6. More detailed guidance on substances of concern

The second edition significantly expands the section dealing with chemical compliance.

The FAQs clarify that the requirements relating to substances of concern apply to all packaging, not only food-contact packaging. They also explain how manufacturers are expected to demonstrate compliance with the heavy metal restrictions and confirm that the new obligations begin applying from 12 August 2026.

Importantly, the Commission notes that compliance can no longer rely solely on the existing EN 13428 standard because the PPWR introduces broader requirements than those contained in the previous Packaging Directive.

7. Clarification for dangerous goods packaging

The Commission also clarifies how the Regulation applies to packaging used for dangerous goods.

Packaging approved under ADR rules, including Limited Quantity packaging, benefits from specific derogations under the PPWR. However, the same UN-approved packaging, when used to transport non-dangerous goods, must comply with the standard PPWR requirements.

This clarification is particularly relevant for industrial and chemical packaging suppliers.

8. More practical guidance on reusable packaging

The updated FAQs provide clearer guidance on how the PPWR reuse requirements should operate in practice. The Commission emphasises that packaging is only considered reusable if it forms part of a reuse system. Simply designing packaging to withstand multiple uses is not sufficient; economic operators must ensure there is a system for collection, reconditioning and repeated circulation of the packaging.

The FAQs also clarify the operation of open-loop and closed-loop reuse systems, explain that reusable packaging undergoing reconditioning is generally not considered waste, and provide further guidance on who is responsible for meeting reuse targets. Responsibility varies depending on the packaging application—for example, beverage reuse targets apply to the final distributor, while transport packaging obligations apply to the economic operators using that packaging within the supply chain.

Additional clarification is provided for reusable transport packaging, confirming that reusable formats such as pallets, plastic crates, foldable boxes, intermediate bulk containers and drums are expected to replace single-use alternatives in many business-to-business supply chains. Overall, the expanded guidance reinforces that compliance requires not only reusable packaging, but also documented reuse systems and supporting technical evidence demonstrating that the packaging can complete multiple rotations while maintaining its intended performance.

9. A new section explaining what applies from 12 August 2026

One of the most valuable additions to the second edition is an entirely new section dedicated to the requirements that become applicable from 12 August 2026.

Since the PPWR was published, many businesses have struggled to distinguish between obligations that apply immediately and those that depend on future delegated or implementing acts or only become mandatory from 2030 onwards. The Commission has now addressed this by identifying the provisions that manufacturers, importers and other economic operators should already be complying with from the Regulation's application date.

The FAQs explain that from 12 August 2026, companies placing packaging on the EU market should already be able to demonstrate compliance with several core obligations, including:

• Declaration of Conformity (DoC): Packaging placed on the market must be supported by an EU Declaration of Conformity confirming compliance with the applicable PPWR requirements. Manufacturers are responsible for preparing the declaration and maintaining the supporting technical documentation.

• Technical documentation: Manufacturers must hold sufficient evidence demonstrating how packaging complies with the Regulation, including packaging design, material composition, calculations, test reports where applicable and supporting supplier documentation.

• Packaging minimisation: Packaging must already comply with Article 10 by being reduced to the minimum volume and weight necessary to perform its function while maintaining product protection, safety and hygiene. This obligation applies independently of the future empty space methodology.

• Restrictions on substances of concern: The limits for heavy metals and the new PFAS restrictions for food-contact packaging begin applying from this date, requiring manufacturers to have appropriate evidence demonstrating compliance.

• Economic operator obligations: Manufacturers, importers and distributors must already comply with their respective responsibilities relating to conformity assessment, traceability and market surveillance requirements. Importers must ensure that packaging entering the EU market complies with the Regulation and that the required technical documentation is available for inspection.

The Commission also makes it clear that many other provisions do not yet apply, including recyclability performance grades, recycled-at-scale assessments, mandatory recycled content verification methodologies, harmonised labelling specifications and several reuse targets. These requirements depend on delegated acts, implementing acts or later application dates, primarily from 2030 onwards.

This distinction is particularly important because many companies have delayed PPWR preparation while waiting for future technical rules. The updated FAQs confirm that this approach presents a compliance risk. Although several technical methodologies are still under development, businesses are already expected to comply with the requirements that became applicable on 12 August 2026 and to maintain the supporting documentation necessary to demonstrate conformity if requested by market surveillance authorities.

What does this mean for businesses?

The second edition of the PPWR FAQs does not introduce new legal obligations, but it significantly improves the interpretation of the Regulation. For many companies, the clarifications will influence how they identify responsible economic operators, document packaging minimisation, assess compostability, prepare technical documentation and plan compliance activities over the coming years.

Businesses should not treat these FAQs as simply explanatory notes. They provide valuable insight into how the European Commission intends to interpret and implement the PPWR, making them an important reference when preparing technical files, Declarations of Conformity and broader packaging compliance programmes. Companies that review these updates now will be better positioned to demonstrate compliance as the Regulation begins to apply and as further delegated and implementing acts are published.

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FAQ PPWR Aug 2026.pdf

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