The European Commission has issued a draft guidance document to support the interpretation and implementation of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). Published as an annex to Communication C(2026) 2151 final on 30 March 2026, the guidance provides clarification on selected provisions ahead of the Regulation’s application from 12 August 2026.
According to the Commission, the document addresses stakeholder questions and aims to ensure a more consistent application of PPWR requirements across the EU.
Clarifications on scope, definitions and roles
A central focus of the guidance is the interpretation of key definitions and the allocation of responsibilities within the supply chain. The Commission confirms that an item should be qualified as packaging based on its function. This means that items used for the containment, protection or delivery of goods fall within the scope of the Regulation, while integral product components that do not perform a packaging function are excluded.
The document also provides further detail on how obligations apply to economic operators. In particular, it clarifies the responsibilities of importers in relation to non-EU manufacturers, as well as situations in which distributors may assume responsibility, for instance when packaging is modified. These provisions are particularly relevant for complex supply chains and private label arrangements.
Application of requirements and material considerations
The guidance addresses how key PPWR requirements should be applied in practice, including with respect to recyclability, recycled content and the treatment of composite materials. For multi-component packaging it confirms that requirements may need to be assessed at the level of individual components where these can be separated.
Additional clarification is provided on packaging design, including expectations related to design-for-recycling and packaging minimisation. The document also addresses the role of multiple actors across the value chain in meeting compliance obligations.
Reuse, labelling and other implementation aspects
Further sections of the guidance cover reuse and refill systems, clarifying that packaging can only be considered reusable if it is part of a system that enables multiple uses. The Commission also addresses labelling requirements, deposit return systems and the interaction between the PPWR and other EU legislation, including the Single-Use Plastics Directive.
The guidance also includes a discussion of specific material and product categories, such as compostable packaging and the use of certain substances, including PFAS in food contact materials, reflecting areas of particular stakeholder interest.
The guidance document can be accessed here.
