SUMMARY

• The European Commission has published a new notice containing guidance on selected provisions of the Packaging and Packaging Waste Regulation (PPWR). Members can find the document attached.
• The guidance document is intended to support the uniform interpretation and timely implementation of the PPWR ahead of its application from 12 August 2026. It is complemented by the Commission’s existing set of frequently asked questions.
• While the official publication of the Notice is a useful development, the document appears to largely reflect the version already made available by DG ENV earlier this year (in March), with only limited changes. As such, it does not seem to provide substantial additional clarification on several of the operational questions previously raised by FESI members.

MORE INFORMATION

The Commission Notice covers a broad range of PPWR-related topics, including key definitions, recyclability timelines, recycled content exemptions, compostable packaging, packaging minimisation, harmonised labelling, re-use targets and Deposit and Return Systems. However, compared to the previous version published on the DG ENV website, the officially published Notice appears to contain only very limited changes. In particular, it does not seem to provide substantial new clarification on several practical implementation questions raised by FESI members, including identification requirements, traceability obligations, the possible use of digital means, and the organisation of Declarations of Conformity across complex packaging components and supply chains.

One point of particular relevance concerns system harmonisation for packaging material identification. The guidance clarifies that Commission Decision 97/129/EC, which establishes the current system of numbering and abbreviations to identify packaging materials, will continue to apply until 12 August 2028. Its use remains voluntary for manufacturers; however, where an identification system is used, Member States must ensure that no system other than the one established under Decision 97/129/EC is applied. The use of these abbreviations will no longer be allowed after 12 August 2028.

NEXT STEPS

FESI will continue monitoring PPWR implementation and any updates to the Commission guidance and FAQs.

FESI will also continue following the forthcoming PPWR implementing and delegated acts, including those relevant to EPR registration and reporting, harmonised labelling, recyclability and recycled content.

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