PPWR FAQ

The Packaging and Packaging Waste Regulation (PPWR) is a new EU law designed to make all packaging more sustainable. Its main goals are:

• Standardising Rules: It creates identical standards across all EU countries, making cross-border logistics simpler and more predictable.
• Preventing Waste: It prioritises re-use over disposal, setting mandatory targets for transport packaging to be reusable by 2030.
• Increasing recycling: All packaging must be recyclable by 2030, and recycled material should be used where possible.

The PPWR aims to move Europe toward a circular economy where packaging is designed to be used many times and recycled at the end of its life – the same model that reusable transport packaging has been pioneering for decades.

The PPWR introduces several rules to ensure reusable transport packaging is high-quality, safe, and sustainable.

Notably, for the first time, reuse is mandated in law. Starting 1 January 2030, the PPWR introduces two different levels of re-use targets for transport packaging (such as plastic pallets, crates, foldable boxes, and IBCs) used within the EU.

40% General Target: For general logistics across the EU, companies must ensure that at least 40% of their transport packaging is reusable within a managed re-use system.

100% ‘Internal and Domestic’ Target: Re-use is mandatory (i.e. a 100% re-use target) when packaging is used for:

• Intra-company transfers: Moving products between different sites of the same business.
• Linked enterprises: Moving goods between partner companies.
• Domestic B2B deliveries: Delivering products to another business within the same EU country

Other requirements of the PPWR include: by 2030, all packaging must be designed to be recyclable, and plastic packaging must generally contain at least 35% recycled material (with exemptions applying). Furthermore, it mandates that reusable packaging must be durable enough to handle many trips and be part of a managed re-use system. The PPWR also restricts harmful chemicals to ensure the materials are safe for the environment and human health.

The general application of the PPWR begins on 12 August 2026. Because the PPWR is a complex framework, compliance deadlines are staggered across several years. The majority of administrative and general obligations for manufacturers, importers, and distributors must be complied by as of 12 August 2026 onwards. The compliance deadlines for specific PPWR requirements are laid out within the PPWR, mostly coming into effect between 12 August 2026 and 2030.

Packaging that does not meet sustainability and labelling requirements cannot be placed or made available on the EU market. This makes PPWR compliance a key part of ensuring your business can operate in the EU single market. Failing to comply can lead to severe operational, financial, and legal repercussions, such as:

• Corrective Actions and Recalls: If a market surveillance authority finds your packaging is non-compliant, they can force you to take immediate corrective measures, which may include withdrawing or recalling the packaging from the market.
• Financial Penalties: Member States are required to implement "effective, proportionate and dissuasive" penalties, which specifically include administrative fines for failing to meet re-use and prevention targets.

Under the PPWR, ‘packaging’ is broadly defined as any item, regardless of the materials used, that is intended for the containment, protection, handling, delivery, or presentation of products.

“‘packaging’ means an item, irrespective of the materials from which it is made, that is intended to be used by an economic operator for the containment, protection, handling, delivery or presentation of products to another economic operator or to an end user, and that can be differentiated by packaging format based on its function, material and design”

This applies whether the packaging is supplied empty or already filled with a product.

What is classified as transport packaging and what is sales packaging?

Under the PPWR, sales packaging (also known as primary packaging) is designed to form a single unit for the end user at the point of sale, consisting of the product and its immediate container. In contrast, transport packaging (or tertiary packaging) is designed to facilitate the handling and transport of multiple sales units to prevent damage during transit, including formats like pallets, crates, and IBCs. While some formats like drums or pails may serve both functions, they are generally classified based on whether their primary intent is for a retail sale or for the logistical movement of goods

Specific examples of plastic transport packaging covered by the regulation include:

• Pallets.
• Crates and boxes (including foldable plastic boxes
• Intermediate Bulk Containers (IBCs).
• Drums, pails, and canisters.
• Pallet wrappings and straps for stabilization.

What is NOT packaging? Items that are an integral part of a product and necessary to contain or preserve it throughout its lifetime, where all elements are intended to be used and disposed of together, are generally excluded.

Storage trays and containers used exclusively for internal operations do not fall under the PPWR, provided they are used solely for stationary storage or purely intra-site material flow.

Recommendation: Document the intended purpose of these trays and containers. Explicitly declare your products in the technical data sheets and sales documents as "storage and logistics containers for internal use (operating resources)".

Textile dunnage serving a protective/handling function is generally considered part of the overall packaging, not a separate non packaging item. It would be classified functionally as part of transport/grouped packaging categories in Annex II.

PPWR requirements that apply include: the reuse obligations for transport packaging from 2030, requiring design for multiple trip cycles, and the recyclability and material minimisation requirements where applicable. The PPWR obligations must be met for the packaging unit as a whole, and component materials, including textile dunnage, contribute to compliance as part of that unit.

No, you do not need a separate EU Declaration of Conformity (DoC) for every individual product variant. Instead, the manufacturer must draw up a DoC for each packaging type, i.e. the level where packaging shares the same characteristics regarding sustainability and labelling requirements.

The DoC needs to be able to be traceably linked back to the product placed on the market via a ‘unique identification of the packaging’ (as referred to in Annex VIII). While the PPWR does not define ‘unique identification of the packaging’, the Commission has clarified in its FAQ that this can refer to the type, batch, or serial number.

Manufacturers need to carry out the conformity assessment procedure for packaging before placing packaging on the market. This obligation applies only to packaging that has not yet been placed on the market. Therefore, the declaration of conformity must only be issued for packaging placed on the market after the application of the PPWR on 12 August 2026. The Commission has highlighted this timeline in their FAQ under Section XV Question 1.

The general 40% reuse target for transport packaging (like pallets and crates used across the EU) is to be met by 2030. Some specific internal or domestic flows must be entirely reusable (100%) – these re-use targets also apply from 1 January 2030.

The 100% targets apply to the following logistics scenarios:

• Intra-company and Linked Transfers: Transport packaging used for moving products between different sites of the same operator or between linked or partner enterprises within the EU.
• Domestic B2B Deliveries: Transport packaging used to deliver products to another economic operator within the same EU country.

The legal obligation to meet and demonstrate these targets begins on 1 January 2030. Companies will be required to submit their first report on achieving these targets by June 2031, covering the 2030 calendar year.

This should have no impact, as the reuse targets are calculated on the level of the company using the packaging, not the packaging item itself. The packaging would be liable to meet the 100% target when used in an inter-company scenario or B2B deliveries within the same EU member state, and the 40% target when used in B2B deliveries in another EU member state.

The Commission has exempted four different types of sales or transport packaging from the reuse targets:

• Packaging used for the transport of dangerous goods,
• Custom-fit packaging for large-scale machinery, equipment and commodities;
• Flexible packaging formats in contact with food or feed for animals;
• Cardboard boxes.

To make use of the exemption on custom-fit packaging, economic operators must provide the proper documentation to show that the packaging was custom-fit for an individual product.

The PPWR exempts “cardboard boxes” from the reuse targets. Other types of cardboard packaging are therefore not excluded and must comply, if the packaging type falls into the reuse targets. Pallets and trays made of cardboard are therefore not excluded. Layers of any material do not fall into the targets, so cardboard layers are excluded.

The requirement to calculate and report the number of rotations depends on the type of reuse system in which the RTP operates (i.e. an open or closed loop system).

Open-Loop Systems (without a system operator): Reusable packaging used in these unmanaged systems (e.g., generic Euro Pallets) is exempt from the obligation to calculate and report the achieved number of rotations (confirmed in Commission FAQ, part VIII question (1)).

Closed-Loop Systems (with a system operator): The exact requirements are still to be finalised in secondary legislation, however, in theory the system operator must report the number of rotations or trips. This can be done for each individual unit using a QR code or digital data carrier, but the regulation allows for an “average estimation” if tracking every individual unit is not feasible. While a digital data carrier is generally required to facilitate rotation tracking, the Commission has clarified that for B2B reusable transport packaging in closed-loop systems, this information can be provided via websites or accompanying documentation rather than physical markings on every single unit (confirmed in the Commission’s PPWR Guidance Document, question 14).

Design for Rotations: Regardless of whether the end user reports achieved rotations, the manufacturer (under the PPWR) must demonstrate in the technical documentation that the packaging is designed to accomplish a minimum number of rotations. The Commission will set these mandatory minimum rotation numbers for common formats by February 2027.

As of 26 May 2026, pallet wrappings and straps for stabilisation and protection of products put on pallets during transport are confirmed to be excluded from the 100% reuse targets (i.e. the targets in Article 29 (2) and (3) of the PPWR). Pallet wrappings and straps are, however, included in the 40% reuse target. In practice, 40% of an economic operator’s overall packaging mix – including pallet wrappings and straps – must be reusable by 2030.

The manufacturer is the economic operator whose name or trademark is visible on the packaging.

If the packaging carries multiple names or trademarks, the manufacturer is the economic operator who decided on the packaging design specifications based on specific requirements of the manufacturers of the packaged product or a reuse system operator. What design requests count as specific requirements is currently still being clarified by the European Commission.

If the packaging is unmarked, the design criterion applies.

To determine the ‘manufacturer’ in specific scenarios, please use the ‘RCTP manufacturer definition flowchart’ and the specific tool developed by the RCTP.

No, the role and responsibilities of the ‘manufacturer’ cannot be transferred. They always remain with the economic operator defined as the ‘manufacturer’ under the PPWR (see Question 15: Who is the ‘manufacturer’ of packaging under the PPWR?).

The PPWR defines the ‘producer’ as the economic operator (manufacturer, importer, or distributor) who makes the packaging or a packaged product available for the first time in the EU Member State where it is located, or directly to an end user in another EU Member State.

The ‘producer’ is responsible for paying the costs for the collection and recovery of packaging waste in the respective EU Member State. To this end, a producer must register and report to the relevant national authorities and pay the extended producer responsibility (EPR) fee in the EU Member State in which the packaging is expected to become waste.

Extended producer responsibility (EPR) means that the ‘producer’ remains responsible for the end-of-life management of packaging when it becomes waste. This includes the responsibility for the collection and recovery of packaging waste, which is financed through an EPR fee that producers have to pay.

To this end, the ‘producer’ must register and report to the relevant national authorities and pay the EPR fee in the EU Member State in which the packaging is expected to become waste. For each EU Member State where it is not established but makes packaging or packaged products available for the first time, the ‘producer’ must appoint an authorised representative for the EPR.

If EPR fees are paid in an EU Member State, and afterwards a distributor makes the packaging available for the first time in another EU Member State, the fees must be reimbursed. The rules and procedures for EPR registration and reporting, as well as the level of fees, vary across EPR schemes and EU Member States.

If the packaging is exported outside the EU, where it is expected to become waste, extended producer obligations of the Packaging and Packaging Waste Regulation (PPWR) do not apply.

The ‘producer’ is responsible for paying the costs for the collection and recovery of packaging waste through an extended producer responsibility (EPR) fee in the respective EU Member State where the packaging is expected to become waste.

The ‘manufacturer’ must ensure that the packaging complies with the sustainability and labelling requirements before it is made available on the territory of the EU for the first time. There is only one manufacturer throughout the EU.

If the packaging design follows specific requirements of a reuse system operator and carries its label, this operator is the ‘manufacturer’ and ‘producer’ of the packaging. In this case, the RTP company is the ‘supplier’. This applies in the same way if the packaging design follows the specific requirements of a manufacturer of a packaged product.

An exemption applies when the reuse system operator (or manufacturer of a packaged product) is a micro-enterprise and located in the same EU Member State as the RTP company. Then, the RTP company is the ‘manufacturer’, while the reuse system operator (or manufacturer of a packaged product) is the ‘producer’.

If the RTP supplier and micro-enterprise are located in the same EU Member State, the RTP supplier is always the ‘manufacturer’ and therefore responsible for issuing the Declaration of Compliance. This is the case even when the supplier itself is a micro-enterprise.

If the RTP supplier and micro-enterprise are located in different EU Member States, whoever is defined as the ‘manufacturer’ under the PPWR is responsible for issuing the Declaration of Compliance. For identifying the ‘manufacturer’, please refer to Question 15: Who is the ‘manufacturer’ of packaging under the PPWR? and the dedicated tool: www.rctp.eu/ppwr-tool/. If the micro-enterprise is defined as ‘manufacturer’, the RTP supplier is responsible for providing the relevant information to the micro-enterprise to issue the Declaration of Compliance.

Most reusable transport packaging is exempt from carrying the reuse label:

• Open-Loop Systems without an Operator: Generic reusable packaging (like standard unmanaged Euro Pallets) does not need the reusability label or the QR code.
• B2B Closed-Loop Systems: For reusable transport packaging used in B2B environments managed by a system operator, the information can be provided via websites or accompanying documentation rather than physical markings on each individual unit.

For packaging that does not meet the exemption criteria above, starting from 12 February 2029 (or 30 months after the relevant implementing act is adopted), reusable packaging placed on the market must bear a physical label informing users that it is reusable. It must also bear a QR code (or other digital data carrier) providing information on the re-use system and collection points.

Member States will not be allowed to keep their national reuse label next to the harmonised European reuse label after 12 February 2029. Until that date, packaging can use a national reuse label, but it will be required to have the harmonised European label if it was put on the market after 11 February 2025 (More information in Question 25: Relabelling: what is happening with existing pools?).

No, reusable transport packaging is exempt. While the PPWR mandates a harmonised label to inform consumers about material composition to aid sorting, this obligation specifically does not apply to transport packaging, unless it is used for e-commerce.

RTP placed on the market before February 2025 can be kept in the pool until its end-of-life and does not need to be relabelled. Only the newer units added to your pool during the transition period (2025–2029) will need to meet the new labelling standards by 2032, and even then, B2B closed-loops can often fulfil this digitally (More information in Question 22: Which packaging needs to carry the reuse label? Can the label be an insert?).

The requirement to relabel existing pools depends on when the packaging was first placed on the market. The PPWR makes a clear distinction between older "legacy" pools and newer packaging.

• Pools placed on the market BEFORE 11 February 2025: Any RTP already in circulation before the PPWR entry into force is exempt from the new sustainability and labelling requirements. These units may remain in circulation until they are naturally removed from the system due to functional obsolescence or damage; they do not need to be retrofitted with new labels.
• Pools placed on the market AFTER 11 February 2025: Any RTP placed on the market between 11 February 2025 and the application date of the labelling rules (12 February 2029) must be brought into full compliance with the new rules by February 2032. The rules will be known by August 2026, so companies can already start complying from that date.

For B2B closed-loop systems, the Commission has clarified that the required reusability and rotation information can be provided via websites or accompanying documentation rather than physical markings on every unit. This significantly reduces the logistical burden of "relabelling" existing pools. (More information in Question 22: Which packaging needs to carry the reuse label? Can the label be an insert?).

The PPWR mandates manufacturers of packaging to reusable packaging to include a data carrier with information on reusability and on availability of reuse systems and collection points. This only applies to packaging that circulates in a closed-loop system in a B2C context. An example for such would be the circulation of beverage crates. The data carrier should also allow the tracking of the packaging and enable the calculation of the rotations.

The Commission will publish further clarification on the requirements and information of the data carrier by 12 August 2026, at the same time when establishing the rules for the reuse label. Currently, a QR code or another standardised open digital data carrier are allowed to provide this information.

Packaging will have to be classified in Recyclability Performance Grades, which are developed by the Commission and the Joint Research Centre by 1 January 2028. The grades are based on the Design-for-Recycling criteria, which the Commission has to publish by the same date. Packaging will receive recyclability performance grades based on its adherence to the Design-for-Recycling criteria, which provide requirements on the material composition of the packaging. Currently, the European Committee for Standardization (CEN) has been tasked by the Commission to develop these criteria.

The Design-for-Recycling criteria apply from January 2030 onwards, and packaging with a grade lower than C will not be allowed to be placed on the market from January 2030 onwards. Subsequently, packaging with a grade lower than B will not be allowed to be placed on the market from January 2038 onwards.

Under the PPWR, recycled content targets are not calculated for each individual item, but rather as an average per manufacturing plant and per year for each specific packaging type and format. The annual average of post-consumer recycled plastic must meet the 35% threshold by 2030 and the 65% threshold by 2040 per manufacturing plant.

Compliance is measured over the course of a calendar year. This provides flexibility to vary recycled content between batches, provided the year-end average for that plant and format meets the target.

The European Commission is required to establish the exact methodology for this calculation and the verification steps required by 31 December 2026. As such, it is not clear yet how the recycled content should be calculated, but compliance is only required for packaging placed on the market as of 2030. Until 2030, there is no requirement. There will be 3 years between 31 December 2026 – 2030 to ensure packaging placed on the market in 2030 is fully compliant.

Under the PPWR, there is no explicit legal requirement to perform a laboratory test on every single individual unit produced. The manufacturer is legally responsible for ensuring that food-contact packaging complies with strict PFAS concentration limits as of 12 August 2026, and this compliance must be documented. A risk-based approach is sufficient: this is achieved through a combination of supplier statements and regular validation testing of raw materials to ensure they meet the standards.

No, the bottle itself is the primary (food-contact) packaging. The crate serves as transport packaging (tertiary packaging) to facilitate handling and protect the bottles. Because the crate does not touch the food product (the beverage) itself, it is not "food contact packaging". Reusable plastic crates used strictly for bottled products are therefore not subject to the PPWR’s PFAS restriction from 12 August 2026.

At the European level, producers of all types of packaging, including reusable packaging, are mandated to register within the national register of producers, needing to be established by mid 2027.

Additionally, the European Commission will publish guidelines for national EPR schemes to include ecomodulation fees, based on the recyclability of packaging. The mandatory ecomodulation of EPR fees will start from August 2029 onwards.

From 2025 onwards, Member States were obliged to establish EPR fees for packaging. These national systems have the possibility to include reusable packaging in their scope, but it is not mandated. Thus, the inclusion of reusable packaging is done at the discretion of national authorities, and whether or not your product is included will depend on the Member State where you have to pay EPR fees (More information in Question 17: Who is the ‘producer’ of packaging under the PPWR, and what is their role?).

All packaging registered in the national product register will have to report to the national authority information on the weight of packaging placed on the market for each calendar year. The Commission will specify with what granularity producers will have to report the data. According to the PPWR, producers will have to report for the first time by 1 July 2029 for the full calendar year of 2028. However, national producer registers can require reporting at an earlier time.