EU PPWR FAQ Updated to the second Edition

In March 2026, the European Commission's Directorate-General for Environment (DG ENV) published a frequently asked questions (FAQ) document on Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). Our earlier article discussed packaging definitions, responsible economic operators, PFAS restrictions and recyclability requirements.

In August 2026, the European Commission updated the FAQ document. The second edition expanded from 56 to 69 pages, adding 26 new questions and updating 7 questions. It also introduced a new chapter entitled "Enforcement of the New Rules (Immediately after the Application Date of 12 August 2026)".

Key date: The PPWR entered into force on 11 February 2025 and has been generally applicable since 12 August 2026. This update addresses practical questions concerning supplier information, existing stock, packaging traceability, importer responsibilities and market surveillance.

It should be noted that the FAQ is intended to assist with understanding and applying the PPWR. It does not replace the Regulation itself or subsequent implementing acts.

Below is a quick overview of the main updates in the second edition.

Overview of Updates in the Second Edition

Compared with the first edition, the second edition adds guidance on issues widely raised by businesses during PPWR implementation, including responsible economic operators, treatment of existing stock, technical documentation and market surveillance.

01  Packaging Definitions and Responsible Economic Operators Further Clarified

New examples address envelopes, sales packaging, grouped packaging and transport packaging. The FAQ also further explains how to identify the manufacturer and producer for branded packaging, transport packaging and custom-made packaging.

02  Supplier Information Obligations Strengthened

Packaging suppliers must provide manufacturers with the information and technical documentation necessary to demonstrate packaging conformity. Manufacturers or importers remain legally responsible for the overall compliance of the packaging.

03  Treatment of Existing Stock Further Clarified

The second edition distinguishes between two categories of existing stock. Packaging placed on the market before 12 August 2026 may remain on the market. Packaging produced before that date but not yet placed on the market does not have to be destroyed, remanufactured or re-labelled. An accompanying document may be used to meet the requirements in Articles 15(5) and 15(6) concerning packaging identification and the manufacturer's name and address. Other PPWR requirements must be assessed in accordance with their respective dates of application.

04  Packaging Traceability and Conformity Documentation Further Detailed

Packaging may be traceable by type, model, production batch or another equivalent element; a separate serial number is not required for every individual unit. The second edition also clarifies conformity assessment for the entire packaging unit, retention periods for technical documentation, and language requirements for the EU declaration of conformity.

05  Import and Cross-Border Movement Requirements Supplemented

The second edition adds explanations on importer obligations, goods transiting the EU, information from manufacturers established outside the EU, and whether information provided under food legislation may also satisfy PPWR requirements.

06  Substances of Concern and Recycled Plastic Requirements Further Explained

It supplements guidance on minimising substances of concern, demonstrating compliance with the concentration limit for the four heavy metals, and requirements applicable to packaging used for the transport of dangerous goods. It also further explains the scope of the minimum recycled content requirements in Article 7 for plastic parts of packaging. Plastic parts representing less than 5% of the total weight of the whole packaging unit, among other cases, are exempt. The relevant targets apply from 2030 at the earliest, subject to the later date specified in the Regulation.

07  New Explanations on Reuse, EPR and Deposit and Return Systems

The second edition supplements guidance on producer responsibilities in reuse systems, information requirements that Member States may impose for EPR purposes, and whether deposit and return systems may register and report on behalf of producers.

08  New Guidance on Enforcement During the Initial Application Period

The second edition adds a dedicated enforcement chapter. It explains that, where packaging is found to be non-compliant after 12 August 2026, the competent authorities will normally first require the relevant economic operator to take corrective action. Only if the non-compliance persists may further measures be taken, such as prohibiting, withdrawing or recalling the non-compliant packaging.

Important note: The second edition not only adds new content, but also revises or removes certain explanations from the first edition. For example, the standalone question on the classification of "composite packaging" in the first edition was not retained in the second edition. Compliance assessments should therefore be based primarily on the second edition of the FAQ, the PPWR itself and subsequent implementing acts.

This update shows that the EU's focus is shifting from "what requirements the Regulation establishes" to "how businesses should prepare documentation, allocate responsibilities and respond to market surveillance".

CTT Recommendations

With the PPWR generally applicable from 12 August 2026, relevant businesses should complete the following actions as soon as possible:

Identify Responsible Economic Operators

Determine the identities of the manufacturer, producer, importer and supplier based on the brand, trademark, purchase order, decision-making authority over the packaging design, and supply-chain model.

Complete Supplier Documentation

Review purchasing agreements and supplier quality agreements, and clearly define obligations relating to technical documentation, material information, test reports, declarations of conformity and document updates.

Establish Packaging Traceability

Ensure that the packaging type or batch number can be linked to the supplier, raw materials, production date, test reports, technical documentation and the EU declaration of conformity.

Manage Existing Stock by Category

Distinguish between the production date, the date of placing on the market and the applicable requirements. Pay particular attention to PFAS in food-contact packaging, the four heavy metals and marking information.

Review Import Compliance Documentation

Confirm that the manufacturer established outside the EU has carried out the conformity assessment. Prepare the importer's contact details, accompanying documents and the language versions required by the Member State(s) of destination.

CTT Services: CTT provides testing for the four heavy metals and PFAS in food-contact packaging under the EU PPWR. Based on the product type and supply-chain circumstances, CTT can provide regulatory interpretation, risk screening, testing and compliance pathway planning to support businesses in meeting the PPWR requirements.

Official References

European Commission PPWR topic page:

https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en

Second edition of the FAQ:

https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1