Reference source : European Commission
Conformity Assessment Packaging Enforcement Packaging and Packaging Waste Regulation (PPWR) Market Surveillance Packaging Waste Economic Operators FAQ
The European Commission has published the second edition of its Frequently Asked Questions (FAQs) on Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). This introduces new and updated guidance ahead of the Regulation's general application on 12 August 2026. The revised FAQ complements the Commission's earlier guidance document and provides new clarifications on enforcement, the responsibilities of economic operators, substances of concern, recyclability, and conformity assessment.
New Guidance on Enforcement
A new section of the FAQs explains how Member States should enforce the PPWR once it comes into effect. According to the Commission, enforcement should not unnecessarily disrupt trade flows, supply chains, or consumer access to goods. Where non-compliance is identified, Member States should first require the relevant economic operator to remedy the non-compliance by providing an opportunity to take corrective action. Further measures, such as prohibiting, recalling or withdrawing non-compliant packaging, should only be taken if the non-compliance persists.
The Commission also encourages market surveillance authorities to support economic operators by raising awareness, requesting information and setting reasonable timeframes for corrective action, rather than adopting a sanction-oriented approach from the outset.
Expanded Clarifications for Economic Operators
The updated FAQ also adds numerous practical questions and examples to clarify the responsibilities of manufacturers and producers under the PPWR. Among other topics, the Commission explains the distinction between sales, grouped and transport packaging; identifies who is considered the manufacturer of transport packaging and branded packaging, clarifies responsibility where different companies own the product name and trademark; and provides examples for determining the producer in different supply chain scenarios.
Additional Updates
The revised FAQ also contains new and updated guidance on substances of concern, conformity assessment, declarations of conformity, recyclability requirements and other implementation questions raised by stakeholders since the publication of the first edition.
The full FAQ can be accessed here.
