The European Commission has published an extensive set of answers to the questions raised by companies and national authorities since the adoption of the Packaging and Packaging Waste Regulation. The document provides important operational guidance ahead of 12 August 2026.
Packaging companies operating in the EU have had 12 August marked on their calendars for some time now: the day on which the PPWR, into force since 11 February 2025 enters its first phase of implementation. This has not been without controversy: in recent months, there has been a flurry of concerns, doubts, requests for clarification and calls for an extension. As regards extensions, there is no news as yet; however, further clarification has been provided for the most confusing points.
The European Commission’s Directorate-General for Environment published the new Frequently Asked Questions on the Packaging and Packaging Waste Regulation on 3 August 2026. The 69-page document is the second edition of a text first completed in March and updated in August, with new and revised answers clearly identified throughout. It complements the Commission’s broader PPWR guidance and covers issues ranging from the definition of packaging and the responsibilities of economic operators to recyclability, recycled content, reuse, environmental claims, extended producer responsibility and deposit return systems. The document clearly highlights the sections that have been added since the March edition, marked ‘NEW’, and those that have been updated (‘UPDATED’), to make it easier to read.
Let’s get a closer look to some key points: we will explore some of these in more detail in separate articles.
(To know more about PPWR, read our article “Navigating the PPWR” of last March, it’s #oldbutgold)
1- Existing stocks will not have to be destroyed or repackaged
Packaging produced before 12 August 2026 but not yet placed on the market will not have to be destroyed, remanufactured or relabelled. The required identification and manufacturer information may be supplied through an accompanying document, while packaging already placed on the market can remain in circulation.
2- Enforcement should begin with corrective action
The Commission clarifies that initial enforcement should not disrupt trade or supply chains. When non-compliance is identified, authorities should first request corrective action within a reasonable timeframe; recalls, withdrawals or market restrictions should follow only if the problem is not resolved.
3- Who is really the manufacturer?
The manufacturer is generally the operator under whose name or trademark the packaging is placed on the market, or the company that determines its design and specifications. For generic packaging, the physical producer may retain this role, while custom-made formats usually make the commissioning company responsible.
4- PFAS limits apply to the whole packaging unit
The PPWR sets concentration limits rather than a complete ban on PFAS in food-contact packaging. Compliance must be assessed across the entire packaging unit, including inks, coatings, varnishes, glues and adhesives, and covers both intentionally added and unintentionally present PFAS.
5- Traceability does not require a serial number on every pack
The FAQ confirms that each individual packaging item does not need its own serial number. Identification may refer to a packaging type, model or production batch, provided it allows authorities to connect the packaging with the relevant technical documentation and declaration of conformity.
6-Legal responsibility cannot be outsourced
Manufacturers may use laboratories, certification schemes or authorised representatives for certain compliance activities. However, the obligation to compile the technical documentation and the final legal responsibility for compliant packaging remain with the manufacturer and cannot be transferred by contract.
12 August: a starting line, not a single deadline
From 12 August 2026, provisions without a different application date begin to operate. These include, among other things, the general obligation to minimise substances of concern in packaging, the restrictions on PFAS in food-contact packaging and several obligations concerning manufacturers, importers, conformity documentation and packaging identification.
Other requirements follow a different timetable.
- The compostability provisions in Article 9, for example, apply from 12 February 2028.
- The principal recyclability requirements are expected to apply from 2030 or two years after the entry into force of the delegated acts establishing the design-for-recycling criteria.
- Minimum recycled content requirements for plastic packaging will apply from 1 January 2030 or three years after the relevant implementing act, whichever is later.
- Packaging minimisation, the restrictions on certain single-use formats and the first reuse targets are also largely associated with 2030.
- The 50% empty-space threshold for grouped, transport and e-commerce packaging will apply from 2030 or three years after the entry into force of the act establishing its calculation methodology.
The result is a regulatory framework that develops in stages. Companies therefore need a compliance roadmap divided by obligation, packaging type and date, rather than a single checklist built around 12 August.
The FAQ also prepares companies for the 2030 requirements
Although many obligations are not yet active, the document provides important guidance on how companies should prepare for the next stages.
For recyclability, the absence of a recyclable alternative will not in itself create an exemption. Packaging must either fall within one of the derogations expressly established by the Regulation or qualify as innovative packaging under the relevant criteria. Non-recyclable integrated components may reduce the recyclability performance grade of the entire packaging unit or, in some cases, make it non-compliant.
For recycled plastic content, the requirements will apply to plastic parts of sales, grouped and transport packaging. Compliance will generally be calculated for each packaging type and format as an annual average for each manufacturing plant. Plastic parts representing less than 5% of the total packaging-unit weight are exempt from the recycled-content obligation.
Environmental claims concerning properties regulated by the PPWR will be permitted only where the packaging goes beyond the applicable minimum legal requirements. The claim must also specify whether it refers to the entire packaging unit or to a particular component.
The FAQ makes an important distinction for aluminium packaging: claims concerning recycled aluminium content are not governed by Article 14 of the PPWR, since the Regulation does not establish a recycled-content requirement for aluminium packaging. They must instead comply with the wider EU consumer-protection rules applicable to environmental claims.
Empty space, bans, reuse and EPR remain major areas to watch
For sales packaging, the PPWR does not set a fixed maximum empty-space ratio. Companies must nevertheless minimise unnecessary space and justify their choices in the technical documentation. Filling materials such as air cushions, paper, bubble wrap, foam or polystyrene chips are considered empty space.
The separate 50% threshold applies to grouped, transport and e-commerce packaging. The calculation methodology, including rules for irregular products and protective space, will be established through a future implementing act.
The Commission is also preparing guidelines on the single-use packaging restrictions in Annex V, expected by February 2027. The FAQ already clarifies that the restriction on convenience grouping formats at the point of sale does not cover B2B situations. It also confirms that the definition of the HoReCa sector is broad enough to include hotel room service, sporting venues, entertainment facilities and festivals where food or beverages are served for immediate consumption.
On extended producer responsibility, the document confirms that there is no general exemption for micro-enterprises. Smaller producers may benefit from simplified reporting or specific supplier-related exceptions, but producer status and EPR responsibility still need to be assessed carefully. The first reporting under the future harmonised national-register rules is expected by 1 June 2030.
A clearer map, but not yet the complete rulebook
The FAQ resolves several practical uncertainties and gives businesses a more concrete basis for their compliance work. At the same time, it demonstrates how much of the PPWR implementation architecture is still under construction.
Design-for-recycling criteria, recycled-content methodologies, harmonised labels, calculation rules for empty space and reuse targets, standards for packaging minimisation and detailed guidance on packaging bans will all depend on further acts, standards or Commission guidelines.
The immediate priority is therefore not to treat 12 August 2026 as a final compliance destination. It is to identify which obligations enter their first application phase, map the roles of manufacturers, importers and producers, obtain the necessary information from suppliers and build documentation systems capable of evolving as the remaining PPWR measures are progressively introduced.
