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The PPWR, the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40), reached full application on 12 August 2026. Alongside this milestone, DG Environment of the European Commission published the second edition of its Frequently Asked Questions (FAQ) document on the PPWR, updating and replacing the first version released in March 2026.
The PPWR FAQ document is designed to assist economic operators, national authorities and citizens in the practical application of the Packaging Regulation, addressing interpretative questions that have emerged since the Regulation’s adoption. Below we break down the most relevant clarifications introduced in this new edition.
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What is the PPWR and why it matters
The PPWR (Regulation (EU) 2025/40) replaced the former Directive 94/62/EC, introducing a harmonised legal framework directly applicable across all Member States for packaging placed on the EU market — whether empty or filled, regardless of material or origin. Key objectives of the Packaging Regulation include mandatory recyclability, reuse targets, restrictions on hazardous substances, and harmonised labelling requirements.
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Key updates in the 2026 PPWR FAQ
Among the most relevant additions:
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- Substances of concern (Art. 5(1)). To demonstrate the minimisation of substances of concern (SoC) in packaging, manufacturers can refer to Annex C of the harmonised standard EN 13428:2004, pending the adoption of an updated standard.
- Traceability (Art. 15(5)). Individual marking of every single component of a packaging unit is not required: for a yoghurt cup made up of a cup, lid and label, for example, it is sufficient for the required information to appear on just one component.
- Manufacturer of unbranded custom-made packaging. Where a company commissions custom-made packaging with no name or trademark, the company that placed the order and defined the design specifications will be considered the “manufacturer” under the PPWR, since it holds decisive power over the product’s characteristics.
- Enforcement from 12 August 2026. The Commission clarifies that entry into application of the Regulation will not result in the immediate blocking of non-compliant products from the EU market. Under Article 62, Member States must first require the economic operator to remedy the non-compliance, granting an opportunity for corrective action, before adopting stricter measures such as product withdrawal or recall.
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Other topics covered in the PPWR FAQ document
Beyond the points highlighted above, the second edition of the PPWR FAQ also covers in detail:
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- definitions of packaging, manufacturer and producer;
- recyclability and recycled content in plastic packaging;
- compostability and packaging minimisation;
- bans on specific single-use formats;
- reuse and refill systems;
- extended producer responsibility (EPR);
- deposit and return systems (DRS).
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Not sure how to bring your business into line with the PPWR?
Our team closely follows the evolution of the Packaging Regulation and supports companies in interpreting regulatory requirements, assessing packaging conformity, and preparing the required technical documentation. Get in touch for dedicated PPWR consulting and find out how we can support you through this compliance journey.
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Link: https://analytical-group.com/wp-content/uploads/PPWR-FAQ-v2.pdf Source: European Commission, DG Environment, “Packaging and Packaging Waste Regulation (PPWR) – Frequently Asked Questions”, 2nd edition, August 2026.