In early August, the European Commission published an updated Frequently Asked Questions (FAQ) document on the Packaging and Packaging Waste Regulation (PPWR), offering new guidance on a range of implementation issues that will be relevant to food businesses placing packaged products on the EU market.
Among other topics, the FAQ document clarifies the recycled content requirements for different packaging components and provides guidance on demonstrating compliance with restrictions on substances of concern and heavy metals in packaging. It also addresses what companies should do if packaging suppliers cannot provide the information needed to demonstrate compliance. Additional clarifications cover who is considered the manufacturer or producer in a range of situations, including for transport packaging, branded packaging, packaging bearing the name of one company and the trademark of another, and sales packaging that is also used for transport purposes.
The updated guidance also explains how packaging produced before August 12, 2026, but not yet placed on the market, will be treated. It further outlines the obligations of importers, the documentation and traceability requirements manufacturers will need to meet, and the implications of placing non-compliant packaged products on the EU market after the Regulation becomes applicable.
The PPWR entered into force on February 11, 2025, and its general application date is August 12, 2026, although certain provisions—including those on recyclability, recycled content targets, packaging bans, and reuse targets—will apply later. The FAQ complements the Commission Notice – Guidance document for Regulation 2025/40 (EU) on packaging and packaging waste.
