On 30 March 2026, the European Commission published a guidance document C(2026) 2151 and a Frequently Asked Questions (FAQ) document on the implementation of the EU PPWR Regulation (EU) 2025/40 on packaging and packaging waste.

The key highlights related to common packaging manufacturers and importers are as follows:

1. (1) Beverage cups sold empty in a supermarket to consumers for their private use, (2) intravenous bags, (3) syringes, (4) waste bags or doggy bags are not considered to be packaging and therefore not covered by PPWR. However, dust bags for shoes and garments are deemed packaging by default.
2. If a packaging or packaged product carries a certain name or trademark, the owner of that name or trademark is presumed to be the manufacturer. For sales and grouped packaging, the filler (usually the product brand owners) will be the manufacturer. For transporting packaging, service packaging (in their final form) and primary production packaging, the company which manufactures the transport or service packaging will be the manufacturer, unless the user has branded the packaging. The manufacturer needs to carry out the conformity assessment and draft the technical documentation (TD) and the EU declaration of conformity (DoC) for the packaging.
3. If the company that has the packaging or packaged product designed or manufactured under its own name or trademark is a micro-enterprise, and the company supplying the packaging is located in the same Member State, then the supplier of the packaging is the manufacturer.
4. The producer is an economic operator who makes packaging available for the first time on the territory of the Member State where the packaging is expected to become waste. The producer shall finance the waste management in that Member State (extended producer responsibility (EPR)).
5. If the total fluorine content or organic fluorine content in a subject food contact packaging is below 50 mg/kg (0.005%), the packaging could be considered compliant with the per- and polyfluoroalkyl substances (PFAS) requirements. Non-compliant food contact packaging placed on the EU market before 12 August 2026 may remain on the EU market.
6. The permeable tea, coffee or other beverage bag, or soft after-use system single-serve unit that contains tea, coffee or another beverage, and which is intended to be used and disposed of together with the product, including paper-based single-serve units, shall be designed for composting by 12 February 2028.
7. Packaging containing not more than 5% of plastic is thus not covered by the plastic ban in Annex V. Composite packaging, including paper-based packaging containing 5% or more plastic, is covered by the packaging ban.
8. A list of substances of concern (SoC) will be published in the future, considering the EU REACH Substances of Very High Concern (SVHC) list (Candidate List) and the classification in the EU CLP Regulation (EC) No 1272/2008. Concentration limits and related delegated acts may be published.
9. For the recycled content targets, manufacturer shall demonstrate compliance in the technical documentation based on the information collected from its material (or component) manufacturing plants. For plastic packaging that is intended to come into contact with food, the manufacturer can demonstrate in the technical documentation that (1) Annex I to Regulation (EU) 2022/1616 does not list a suitable recycling technology for that polymer, and (2) no recycling technology is available at an industrial scale to manufacture that polymer in accordance with the processes described in Article 1(3) of that regulation.

For more details, please refer to the documents.

The guidance document will be translated into all official EU languages prior to formal adoption, and the FAQ may be updated as necessary. Further details will be proposed via several implementing measures, such as implementing acts, delegated acts, standardisation requests and guidelines, to be proposed by the European Commission in the coming 2-3 years.

Intertek China Hardlines labs will continue to monitor the implementation of the EU PPWR in the EU and the UK-NI and its subsequent implementing regulations and rules, to provide you with testing services and technical support in compliance with the EU packaging regulation and standards.

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