The date of application of Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR) is drawing ever closer. Many companies still need to clarify fundamental questions by August 12, 2026. Since March 30, 2026, there have been 2 official aids for this purpose.
PPWR FAQ
On March 30, 2026, the EU Commission published the official FAQs on the PPWR.
The FAQs answer questions such as
- When does one speak of "composite packaging"? (II-6)
- How are "substances of concern" defined and how does the PPWR relate to the Ecodesign Regulation? (III-2)
- Is the application of EN 13428:2004 (Packaging - Specific requirements for manufacture and composition - Resource efficiency through packaging minimization) sufficient to demonstrate the minimization of substances of concern? (III-8)
- Do the (substance) restrictions relate only to the packaging material or also to inks, adhesives and coatings? (III-15)
- How are "packaging unit", "integrated component" and "separate component" to be understood and what do the recycling requirements refer to? (IV-1)
- How can the packaging minimization of non-standard packaging or the void ratio for irregularly shaped products be calculated? (VII-3; XI-4)
- What is meant by the "marking for identification" of packaging? (XV-3)
- Should the conformity assessment be prepared for each individual packaging component, e.g. bottle, closure and label, or for the entire packaging unit? (XV-5)
- How is the presumption of conformity to be interpreted with regard to the European harmonized standards? (XV-10)
- If packaging is made of the same materials but has different sizes, should an EU Declaration of Conformity be drawn up for each size or is a single declaration sufficient for all sizes? (XV-11)
- Is a conformity assessment and a declaration of conformity also required for transport packaging? (XV-12)
- In which calendar year must manufacturers register with the register of manufacturers for the first time? (XVII-3)
- Does an online platform have to check every producer before allowing them to use the platform? (XVII-5)
PPWR Guidance
For further questions of interpretation, the EU Commission also published the "Commission Notice on the Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste" on March 30, 2026. In this document, the EU Commission explains how it interprets certain passages, such as
- Definitions of producer and manufacturer based on various scenarios
- Definitions of importer and establishment
- Exceptions to recycling quotas
- Packaging minimization - update of EN 13428:2004
- Presumption of conformity for recyclability according to EN 13430:2004
- Harmonized EU-wide marking and the admissibility of national packaging markings (Triman, etc.)
- Reuse targets for transport packaging
- The possibility for member states to set additional national requirements
Please note: The PPWR Guidance was released to the public before it was officially published. The official version dated, March 30, 2026 differs in some respects and is more detailed.
Conclusion
The Packaging Ordinance is extensive. For this reason, GLOBALNORM reports regularly on the changes, even though the regulation is not applicable until August 12, 2026. The issue of packaging compliance can no longer be dealt with quickly on the side or passed on to the supplier. Especially if your company specifies the packaging design. In this case, you become the producer and must prepare the technical documentation and issue an EU declaration of conformity. A lot of information needs to be collected and roles defined before the deadlines for the various obligations(Timeline Packaging Ordinance). Blocking products due to non-compliant packaging from August 12, 2026 is avoidable.
Use the assistance from the EU Commission described above or ask us.
Author's note
This article has been machine translated into English.
