New Questions
- When is an envelope considered packaging?
- What is the difference between sales packaging, secondary packaging, and transport packaging?
- Who is the producer of transport packaging? This includes: Who is the producer of cardboard boxes that are delivered flat and assembled by the customer?
- Who is the producer of packaging that has been branded (branded packaging)?
- Who is the producer of packaging if the packaging bears the name of Company A and the brand of Company B?
- Who is the manufacturer of shipping packaging?
- Who is the manufacturer of retail packaging that is also used for transport?
- Is packaging used for transport between manufacturing sites considered to have been placed on the market?
- How do producers demonstrate compliance with the heavy metal requirements?
- Must “refillable steel cylinders for various types of gas” (Annex I of the PPWR) meet the requirements of Article 5(4) of the PPWR, which sets a limit of 100 mg/kg for heavy metals?
- What should be done with packaging that was in stock or had already been manufactured before August 12, 2026, but had not yet been placed on the market by that date? Are economic operators required to destroy, remanufacture, or relabel such packaging?
- If the supplier of packaging that has already been manufactured no longer exists, or if a supplier is unwilling to provide the necessary information, how can the packaging manufacturer demonstrate compliance?
- Under what circumstances can the obligations under Article 15, paragraphs 5 and 6 (producer contact information and packaging identification) be fulfilled through accompanying documents?
- Do the requirements of Article 15(5) (packaging identification) mean in practice that every single component of a packaging unit must be traceable?
- Can producers delegate responsibilities to third parties?
- Producers and importers are required to retain documentation regarding the “concept design, manufacturing drawings, and materials of the components” of their packaging. Is it sufficient for suppliers to retain this design data and make it available to the authorities upon request?
- Article 18 sets out obligations for importers. What should an importer be aware of?
- Must packaging transported through the EU to destinations outside the EU comply with the provisions of the PPWR?
- Can information already required, for example, under food safety regulations, be considered sufficient to meet the requirements set forth in Article 15(5) and (6) of the PPWR (manufacturer contact information and packaging identification)?
- Who is the producer of custom-made transport packaging that bears neither a name nor a brand?
- Are reusable packaging systems required to fulfill extended producer responsibility on behalf of the manufacturers participating in the system?
- In which language must the declaration of conformity be written?
- Will products be excluded from the EU market if their packaging does not comply with the regulations taking effect on August 12, 2026?
- Can Member States require information that goes beyond the requirements set out in the PPWR to monitor compliance with extended producer responsibility obligations?
- Can deposit and return systems for single-use packaging submit registrations and reports on behalf of manufacturers to fulfill extended producer responsibility obligations?
Updated Questions
- Do the exemptions provided for in Directive 2008/68/EC on the inland transport of dangerous goods apply to all packaging used for the transport of dangerous goods? Do the exemptions also apply to the transport of non-dangerous goods?
- Can EN 13428:2004 be used for conformity assessment regarding substances of concern (SoC)?
- How do economic operators know which requirements regarding recycled content they must meet?
- Do plastic caps and labels on glass bottles also have to meet the requirements for recycled content?
- What obligations do importers or distributors who supply packaging materials have?
- Should the conformity assessment be conducted for each component of the packaging—such as the bottle, cap, and label—or for the entire packaging unit?
- Is a producer required to contact the competent authorities in every Member State where its packaging might end up?
Do you have questions about the PPWR Update or other product, material, or environmental compliance topics? We will be happy to provide you with further support. Simply send us an e-mail with your question or use our contact form.
Author's note
This article has been machine translated into English.
